Privacy Policy

1. Introduction

F9 ("we," "us," "our," or "Platform") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our freelance marketplace platform.

This Privacy Policy is designed to comply with:

• Nigeria Data Protection Regulation (NDPR) 2019
• Federal Competition and Consumer Protection Act (FCCPA)
• Other applicable Nigerian data protection laws

2. Definitions

For purposes of this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person
• "Processing" means any operation performed on personal data, including collection, storage, use, and disclosure
• "Data Subject" means you, the individual whose personal data we process
• "Data Controller" means F9, determining the purposes and means of processing
• "Third Party" means any person or entity other than you or F9
• "Services" means all features, content, and functionality available through the Platform

3. Information We Collect

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Information from Third-Party Sources

3.4 Information We Do NOT Collect

4. How We Use Your Information

4.1 Platform Operation and Service Delivery

We use your information to:

• Create and manage your account
• Authenticate your identity
• Process transactions and payments
• Facilitate communication between users
• Deliver services you request
• Provide customer support
• Resolve disputes and enforce agreements

4.2 Platform Improvement and Personalization

We use your information to:

• Personalize your Platform experience
• Recommend relevant services or jobs
• Analyze user behavior and preferences
• Improve Platform features and functionality
• Develop new products and services
• Conduct research and analytics
• Test new features and updates

4.3 Security and Fraud Prevention

We use your information to:

• Detect and prevent fraud, abuse, and illegal activity
• Verify user identities
• Monitor for suspicious transactions
• Enforce our Terms of Service
• Protect user safety and Platform integrity
• Comply with legal obligations
• Respond to legal processes

4.4 Communication and Marketing

We use your information to:

• Send transactional emails (order updates, payment confirmations)
• Provide important Platform announcements
• Send promotional materials (you may opt out)
• Conduct surveys and request feedback
• Notify you of policy changes
• Respond to your inquiries

4.5 Legal and Compliance

We use your information to:

• Comply with applicable laws and regulations
• Respond to lawful requests from authorities
• Protect our legal rights and interests
• Enforce our Terms of Service
• Resolve disputes and legal claims
• Prevent harm to users or the public

4.6 Business Operations

We use your information to:

• Manage business operations
• Conduct financial reporting
• Process payroll and contractor payments
• Maintain business records
• Conduct audits and assessments

5. Legal Basis for Processing (NDPR Compliance)

Under Nigerian Data Protection Regulation, we process your personal data based on:

5.1 Consent

You explicitly consent to data processing when creating an account. You may withdraw consent at any time (may limit service availability).

5.2 Contractual Necessity

Processing necessary to fulfill our contract with you (Terms of Service), facilitating transactions between users, and providing Platform services you requested.

5.3 Legal Obligations

Compliance with Nigerian laws and regulations, tax reporting and financial compliance, anti-money laundering requirements, and response to legal processes.

5.4 Legitimate Interests

Fraud prevention and Platform security, improvement of services and user experience, business analytics and operations, balanced against your rights and interests.

6. How We Share Your Information

6.1 With Other Users

6.2 With Service Providers and Business Partners

We share information with trusted third parties who assist us:

6.3 For Legal and Safety Reasons

We may disclose information:

• To comply with legal obligations
• In response to lawful requests from authorities
• To enforce our Terms of Service
• To protect against fraud or illegal activity
• To protect rights, property, or safety
• In connection with legal proceedings
• To prevent harm to individuals or the public

6.4 Business Transfers

If we are involved in a merger, acquisition, or sale of assets: your information may be transferred, you will be notified via email and Platform notice, and the new entity will be bound by this Privacy Policy.

6.5 With Your Consent

We may share information for other purposes with your explicit consent.

6.6 Aggregated and De-identified Data

We may share:

• Aggregated statistics (number of users, transaction volumes)
• De-identified data that cannot be linked to you
• Industry research and reports

This data is not considered personal information.

7. Data Retention

7.1 Active Account Data

We retain your information while your account is active and for the periods necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements.

7.2 Specific Retention Periods

7.3 Deletion Requests

You may request deletion of your account and data. However, we may retain:

• Information required by law
• Information necessary for ongoing legal matters
• De-identified or aggregated data
• Backup copies (deleted within 90 days)

8. Your Data Protection Rights

Under Nigerian Data Protection Regulation (NDPR), you have the following rights:

8.1 Right to Access

• Request a copy of your personal data
• Receive information about how we process your data
• Obtain data in a structured, commonly used format

How to Exercise: Email support@f9.ng with "Data Access Request"

8.2 Right to Rectification

• Correct inaccurate personal data
• Complete incomplete personal data
• Update outdated information

How to Exercise: Update through account settings or email us

8.3 Right to Erasure ("Right to be Forgotten")

• Request deletion of your personal data
• Subject to legal retention requirements
• May limit or prevent future use of Platform

How to Exercise: Email support@f9.ng with "Deletion Request"

8.4 Right to Restrict Processing

• Request limitation of data processing
• Challenge accuracy of data
• Object to processing based on legitimate interests

How to Exercise: Email support@f9.ng

8.5 Right to Data Portability

• Receive your data in a portable format
• Transfer data to another service provider
• Applies to data processed by automated means

How to Exercise: Email support@f9.ng with "Data Portability Request"

8.6 Right to Object

• Object to processing based on legitimate interests
• Object to direct marketing
• Object to profiling for marketing purposes

How to Exercise: Opt-out links in emails or email support@f9.ng

8.7 Right to Withdraw Consent

• Withdraw consent at any time
• Does not affect lawfulness of prior processing
• May limit service availability

How to Exercise: Account settings or email support@f9.ng

8.8 Right to Lodge a Complaint

• File a complaint with Nigeria Data Protection Bureau (NDPB)
• Contact: info@ndpb.gov.ng
• We prefer you contact us first to resolve concerns

8.9 Response Timeline

• We respond to requests within 30 days
• Complex requests may take up to 60 days (we'll notify you)
• Verification of identity required for all requests

9. Cookies and Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files stored on your device that help us provide and improve our Platform.

9.2 Types of Cookies We Use

9.3 Third-Party Cookies

Our Platform may include cookies from: Google Analytics, social media platforms, payment processors, and advertising networks.

9.4 Cookie Management

How to Control Cookies:

• Browser settings (block or delete cookies)
• Opt-out tools provided by third parties
• Platform cookie preferences (when available)

Note: Disabling essential cookies may impair Platform functionality.

9.5 Do Not Track Signals

We currently do not respond to "Do Not Track" browser signals, as there is no industry standard for compliance.

9.6 Mobile Identifiers

We may use mobile advertising identifiers (IDFA, AAID) for: app analytics, personalization, and advertising.

You can reset or limit identifier use through device settings.

10. Data Security

10.1 Security Measures

We implement industry-standard security measures:

10.2 Data Breach Response

In the event of a data breach:

• We investigate immediately
• We notify affected users within 72 hours (as required by NDPR)
• We report to Nigeria Data Protection Bureau
• We provide information about the breach and remediation steps
• We implement additional safeguards to prevent recurrence

10.3 User Responsibilities

You are responsible for:

• Maintaining password confidentiality
• Using strong, unique passwords
• Enabling two-factor authentication (when available)
• Reporting suspected unauthorized access
• Protecting your devices from malware

10.4 Limitations

11. International Data Transfers

11.1 Data Storage Locations

Your data may be stored and processed in: Nigeria, cloud service provider data centers globally, and locations where our service providers operate.

11.2 Transfer Safeguards

When transferring data internationally, we ensure: adequate data protection measures, contractual commitments from recipients, compliance with NDPR requirements, and standard contractual clauses where applicable.

11.3 Your Consent

By using the Platform, you consent to international data transfers as described.

12. Children's Privacy

12.1 Age Restriction

12.2 Parental Notice

If you believe a child under 18 has provided us with personal information: email support@f9.ng immediately. We will investigate and delete the information, and the account will be terminated.

12.3 Verification

We may request proof of age if we suspect a user is under 18.

13. Third-Party Links and Services

13.1 External Links

Our Platform may contain links to third-party websites. We are NOT responsible for:

• Privacy practices of external sites
• Content of third-party websites
• Security of third-party services

We encourage you to read third-party privacy policies.

13.2 Third-Party Services

Integrated third-party services (Flutterwave, Google Analytics, etc.) have their own privacy policies. We are not responsible for their data practices.

13.3 Social Media Features

Social media features on our Platform may allow third parties to collect information, use cookies or other tracking technologies, and be governed by the privacy policies of those platforms.

14. Marketing Communications

14.1 Types of Marketing

We may send you:

• Promotional emails about new features
• Special offers and discounts
• Newsletter and updates
• Survey invitations
• Event announcements

14.2 Opt-Out Options

You can opt out of marketing communications:

• Click "Unsubscribe" link in emails
• Update preferences in account settings
• Email support@f9.ng with "Unsubscribe"

Note: You cannot opt out of transactional emails (order confirmations, security alerts).

14.3 Opt-Out Effect

Opting out stops promotional emails within 10 business days, does not affect transactional emails, and does not delete your account.

15. Updates to This Privacy Policy

15.1 Right to Modify

We may update this Privacy Policy to reflect: changes in our data practices, new features or services, legal or regulatory requirements, and industry best practices.

15.2 Notification of Changes

We will notify you of material changes via: email to your registered address, prominent notice on the Platform, and in-app notification.

15.3 Effective Date

Changes are effective 30 days after notification for material changes, and immediately for minor, clarifying changes.

15.4 Continued Use

Your continued use after notification constitutes acceptance of the updated Privacy Policy.

16. Contact Information

For privacy-related inquiries, requests, or concerns:

17. Nigeria Data Protection Bureau

For complaints or concerns about our data practices, you may contact:

We encourage you to contact us first to resolve any concerns.

18. Consent and Acknowledgment