PRIVACY POLICY

1. INTRODUCTION

Ugamy Technologies ("Ugamy," "we," "our," or "us") operates the website Ugamy.io and provides digital tutorials, gaming education, and esports learning tools (collectively, the "Services").

We are committed to safeguarding your privacy and ensuring compliance with the Nigeria Data Protection Regulation (NDPR 2019), its Implementation Framework, and global best practices.

This Privacy Policy explains:

• What personal data we collect
• How we use, store, and protect it
• Your rights under Nigerian law
• How you can contact us

By accessing or using Ugamy.io, you consent to the collection and processing of your personal data in accordance with this Policy.

2. DEFINITIONS

• Personal Data: Any information relating to an identified or identifiable individual under NDPR.
• Data Subject: The individual whose data is processed.
• Processing: Any operation performed on personal data (collection, storage, retrieval, use, etc.).
• Data Controller: Ugamy, which determines the purpose and means of processing personal data.
• Third Parties: Payment processors, service providers, and partners who assist us in operating the Services.

3. PERSONAL DATA WE COLLECT

We may collect and process the following categories of data:

3.1 Information You Provide

• Full name
• Email address
• Username
• Phone number (optional)
• Payment details (handled securely by third-party gateways)
• Profile information or avatars
• Communications with Ugamy (support requests, inquiries)

3.2 Automatically Collected Data

• IP address
• Browser type and version
• Device identifiers
• Operating system
• Usage logs and activity history
• Cookies and tracking technologies
• Referrer URLs

3.3 User-Generated Content

• Comments
• Forum posts
• Uploaded videos or images
• Messages shared within interactive features

3.4 Sensitive Personal Data

Ugamy does not intentionally collect sensitive personal data (e.g., biometrics, religious beliefs). If you provide such information voluntarily, you consent to its processing as required under NDPR.

4. LEGAL BASIS FOR PROCESSING (NDPR REQUIREMENTS)

We process personal data under the following lawful bases:

• Consent: When you create an account or accept cookies.
• Contractual necessity: To deliver our Services and manage your account.
• Legitimate interest: Improving platform performance, security monitoring, fraud prevention.
• Legal obligation: Compliance with Nigerian laws, regulatory requests, law enforcement disclosures.

Where consent is the lawful basis, you may withdraw consent at any time.

5. HOW WE USE YOUR DATA

We process your personal data to:

• Operate and maintain the Services
• Personalize tutorial content and recommendations
• Provide customer support
• Process payments and verify transactions
• Improve functionality, analytics, and user experience
• Send important account notifications
• Prevent fraud, abuse, cheating, and security breaches
• Enforce our Terms of Service
• Comply with NDPR and regulatory requirements

We do not sell your personal data.

6. COOKIES AND TRACKING TECHNOLOGIES

Ugamy uses cookies and similar technologies to:

• Recognize returning users
• Save preferences
• Provide personalized recommendations
• Perform analytics
• Improve performance

You may disable cookies through your browser settings, though some features may become unavailable.

7. DATA SHARING AND THIRD-PARTY ACCESS

We may share your personal data with:

7.1 Service Providers

• Payment processors (Paystack, Flutterwave, Stripe, etc.)
• Cloud hosting and storage providers
• Analytics providers (e.g., Google Analytics)
• Customer support tools
• Email marketing platforms (with opt-out)

7.2 Legal & Regulatory Authorities

We may disclose data when required to:

• Comply with Nigerian law
• Respond to valid law enforcement requests
• Enforce our legal rights

7.3 Corporate Transactions

If Ugamy undergoes a merger, acquisition, or asset sale, your data may be transferred under confidentiality protections.

All third-party processors are bound by Data Processing Agreements in compliance with NDPR.

8. INTERNATIONAL DATA TRANSFERS

Where personal data is transferred outside Nigeria (e.g., cloud hosting, analytics tools), we ensure:

• Adequate data protection safeguards
• Contractual protections under NDPR
• Use of reputable processors with high security standards

You consent to such transfers by using our Services.

9. DATA RETENTION

We retain personal data only for as long as necessary to:

• Provide Services
• Meet legal obligations
• Resolve disputes
• Enforce agreements

Retention periods vary depending on the type of data but generally do not exceed seven (7) years, unless legally required.

10. DATA SECURITY

We implement technical and organizational security measures including:

• Encryption of data in transit and at rest
• Firewalls and intrusion detection
• Access controls and authentication procedures
• Regular vulnerability assessments
• Strict third-party data handling policies

However, no online service can guarantee complete security; you use Ugamy at your own risk.

11. CHILDREN'S PRIVACY

Ugamy does not knowingly collect personal data from children under 13.

If you are under 18, you must use the Platform with parental consent.

If we learn that data from a minor was collected without parental approval, we will delete it promptly.

12. DATA SUBJECT RIGHTS (NDPR)

Under NDPR, you have the following rights:

12.1 Right to Access

Request a copy of your personal data.

12.2 Right to Correction

Request correction of inaccurate or outdated data.

12.3 Right to Deletion ("Right to be Forgotten")

Request deletion of your data where legally permissible.

12.4 Right to Withdraw Consent

Withdraw consent for any processing relying on it.

12.5 Right to Data Portability

Receive your data in a structured, machine-readable format.

12.6 Right to Object

Object to processing based on legitimate interests.

12.7 Right to Restrict Processing

Limit the ways your data is used.

Requests may be submitted to our Data Protection Officer (DPO).

13. DATA PROTECTION OFFICER (DPO)

Ugamy has appointed a Data Protection Officer in compliance with NDPR.

14. YOUR CHOICES & CONTROL

You may:

• Update profile information
• Opt-out of marketing emails
• Delete your account
• Manage cookies
• Request to close or restrict processing

15. THIRD-PARTY LINKS

Ugamy may contain links to third-party websites or services.

We are not responsible for their privacy practices.

We encourage you to review their privacy policies.

16. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically.

Any changes will be posted on this page with a new "Last Updated" date.

Continued use of the Platform constitutes acceptance of the updated Policy.

17. CONTACT INFORMATION

For questions, concerns, or privacy requests, contact: