Privacy Policy

1. Introduction

We are committed to protecting your privacy. This policy explains what personal information we collect, how we use it, who we share it with, and the choices and rights you have. Some features of our services may have additional privacy notices—please read them alongside this policy.

2. Who we are & scope

This policy applies to the Digital Pivot website at dipivot.com, our mobile applications, and related services for gift card redemption, bill payments, and local flight bookings (when available).

Controller: Digital Pivot LLC, 1 Omozogie Road, off Uselu Lagos Road, Benin City, Nigeria. Email: privacy@dipivot.com / info@dipivot.com

3. Definitions

Personal information means information that identifies or could reasonably be linked to an individual. Examples include name, contact details, government ID, account identifiers, device and network information, and transaction data.

4. What we collect

5. Sources of personal information

• You — when you create an account, use features, or contact support.
• Your device — through logs, analytics, and security telemetry.
• Third parties — identity verification, fraud prevention, payments, messaging, analytics, and business partners you connect.

6. How we use information

7. Legal bases for processing

• Contract — to provide services you request.
• Consent — for specific features (e.g., marketing, certain analytics) where required. You can withdraw consent at any time.
• Legal obligation — to meet AML/KYC and other regulatory requirements.
• Legitimate interests — to secure our services, prevent fraud, and improve features, balanced against your privacy.

8. Sharing & disclosures

We share personal information with:

• Service providers (processors) — identity verification, fraud/risk, cloud hosting, analytics, communications, and customer support.
• Payments partners — banks, processors, and payout networks to settle transactions.
• Business partners you connect — when you authorize integrations or transfers.
• Affiliates — for internal operations aligned with this policy.
• Authorities — to comply with law, enforce our Terms, or protect rights, safety, and security.
• Corporate events — as part of a merger, acquisition, or asset sale, subject to confidentiality.

We do not sell personal information.

9. International transfers

We operate globally and may transfer personal information to countries with different data protection laws. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) and implement technical and organizational measures to protect your data.

10. Retention

We retain personal information only as long as necessary for the purposes described, to comply with law, or to resolve disputes. When no longer needed, we delete or anonymize information. In limited cases we may securely archive information for legal obligations.

11. Security

We use a combination of administrative, technical, and physical controls to protect personal information (encryption in transit and at rest, access controls, monitoring, and secure development practices). No system is 100% secure. If you suspect an account issue, contact support immediately.

12. Managing preferences

13. Your rights

Depending on your location, you may have rights to:

• Access — receive a copy of personal information we hold about you.
• Correction — rectify inaccurate or incomplete data.
• Deletion — request deletion when no longer needed or where required by law.
• Restriction — limit processing in certain circumstances.
• Objection — object to processing based on legitimate interests or direct marketing.
• Portability — receive data in a machine‑readable format.
• Withdraw consent — where processing is based on consent.
• Complain — to a supervisory authority in your region.

To exercise rights, email privacy@dipivot.com. We may ask for information to verify your identity and will respond within timeframes required by applicable law.

14. Children’s privacy

Our services are not directed to children, and we do not knowingly collect personal information from individuals under the age of 13 (or the age of digital consent in your region). If you believe a child has provided us information, contact us to request deletion.

15. Automated decision‑making

We do not make decisions based solely on automated processing that produce legal or similarly significant effects. We may use automated tools to help detect fraud or abuse; you can contact us to contest a decision or request human review.

16. Changes to this policy

We review this policy periodically and may update it to reflect changes to our products, legal obligations, or best practices. If changes are material, we will notify you via the site, app, or email. The “Effective date” at the top shows when this policy last changed.

17. Regional notices

18. Contact us

Questions about this policy or our data practices? Contact our privacy team:

• Email: privacy@dipivot.com or info@dipivot.com
• Address: Digital Pivot LLC, 1 Omozogie Road, off Uselu Lagos Road, Benin City, Nigeria
• Support: dipivot.com/contact-us

Appendix: Data categories & purposes