Draft for legal review — not yet in force. Verify all [REVIEW] items with qualified Nigerian / EU counsel before publishing.
Legal Document · Privacy Policy

Your data.
Your rights.
Our obligations.

AppSafeZone NG
OperatorBigBite Intercontinental Ltd
RC Number1573129
Effective Date[REVIEW — insert date]
Version1.0 Draft
01

Who We Are

SafeZone NG is operated by BigBite Intercontinental Ltd, a company incorporated in Nigeria (RC No. 1573129), with its registered address at No. 5 Lewis Aindero Street, Egan Igando, Alimosho, Lagos, Nigeria.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the SafeZone NG mobile application. It applies to all users of the app, regardless of location.

We are committed to compliance with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Act (NDPA) 2023, and — where applicable to users in the European Economic Area — the General Data Protection Regulation (GDPR).

Minimum age: SafeZone NG is intended for users aged 18 years and above. We do not knowingly collect data from persons under 18. If you become aware that a minor has created an account, please contact us immediately.

02

Data We Collect

Account & Identity Data

Location Data

Incident Reports

Incident reports are submitted anonymously by default. We do not attach your identity to the public-facing report unless you choose to identify yourself.

Emergency Contact Data

Device & Technical Data

Payment Data

03

How We Use Your Data

Purpose Data Used Legal Basis
Account creation & authentication Phone number, OTP Contract performance
Display nearby security alerts Foreground location Contract performance
Silent Tracker Mode (kidnap tracking) Background location (72hr max) Explicit consent
Incident report submission Photos, voice notes, location, text Contract performance / Legitimate interest (public safety)
SOS alert delivery Your location, trusted contacts list Vital interests / Explicit consent
Push notifications (alerts) FCM token Contract performance
SMS OTP delivery Phone number (via Termii API) Contract performance
Subscription management Transaction reference, subscription status Contract performance
Satellite environmental data Location (anonymised, via Copernicus/Sentinel-2) Legitimate interest
Conflict/alert intelligence enrichment Location (anonymised, via ACLED API) Legitimate interest (public safety)
Text-to-speech alert narration Alert text (via Google Cloud TTS) Contract performance
04

Third-Party Services

We use the following third-party services to operate SafeZone NG. Each processes data under their own privacy policies:

Service Provider Purpose Data Transferred
Firebase Authentication Google LLC (USA) Phone OTP sign-in Phone number
Cloud Firestore Google LLC (USA) App database User profile, reports, contacts
Firebase Storage Google LLC (USA) Photo & voice note storage Media files
Firebase Cloud Messaging Google LLC (USA) Push notifications FCM token, notification payload
Firebase Cloud Functions Google LLC (us-central1) Backend logic Processed in Google Cloud
Google Maps SDK Google LLC (USA) Map rendering Location (foreground)
Google Cloud TTS Google LLC (USA) Alert narration Alert text
Paystack Paystack Inc. (Nigeria/USA) Payment processing Payment details (not stored by us)
Termii Termii Inc. (Nigeria) SMS OTP delivery Phone number
ACLED API ACLED (USA) Conflict data enrichment Anonymised location
Copernicus/Sentinel-2 European Space Agency (EU) Environmental satellite data Anonymised location
Hive N/A (on-device only) Local app storage No data leaves device

Data transfers to Google LLC and other US-based providers occur under Standard Contractual Clauses (SCCs) in accordance with GDPR Article 46 requirements.

[REVIEW] Confirm Google Firebase Data Processing Addendum (DPA) has been accepted in your Firebase console. Required for GDPR compliance.
05

Data Retention

Data Type Retention Period
Account data (profile, phone number) Until account deletion + 30 days
Incident reports (text, location) 12 months from submission, then anonymised
Incident photos & voice notes 12 months from submission, then deleted from Firebase Storage
Silent Tracker location data 72-hour session maximum, then auto-deleted
FCM push notification tokens Active until account deletion or token refresh
Trusted contact data Until removed by user or account deletion
Subscription & payment records 7 years (legal / tax obligation)
[REVIEW] The 12-month incident retention policy is a recommended default — implement automated Firestore TTL rules or scheduled Cloud Functions to enforce deletion. Confirm with counsel whether longer retention is justified for public safety purposes under NDPR Article 2.1(d).
06

Your Rights

Under the NDPR, NDPA 2023, and GDPR (where applicable), you have the following rights regarding your personal data:

Right of Access

Request a copy of all personal data we hold about you.

Right to Rectification

Request correction of inaccurate or incomplete data.

Right to Erasure

Request deletion of your account and associated personal data.

Right to Portability

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

Right to Object

Object to processing based on legitimate interests.

Right to Withdraw Consent

Withdraw consent (e.g. Silent Tracker) at any time without penalty.

Right to Restrict Processing

Request that we limit how we use your data in certain circumstances.

Right to Lodge a Complaint

File a complaint with the Nigeria Data Protection Commission (NDPC) or your local supervisory authority.

To exercise any of these rights, email us at bigbiteintercontinental@gmail.com with the subject line "Data Rights Request." We will respond within 30 days.

[REVIEW] Account deletion is currently a manual process. Implement an in-app "Delete Account" button that triggers a Cloud Function to purge Firestore documents, Firebase Auth record, Storage files, and FCM tokens — ideally within 30 days of request.
07

Security

We implement the following measures to protect your data:

No system is perfectly secure. In the event of a data breach that poses a risk to your rights, we will notify affected users and the NDPC within 72 hours of becoming aware, in accordance with NDPA 2023 Section 40.

08

Children's Privacy

SafeZone NG is not directed at persons under the age of 18. We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has registered on the platform, please contact us at bigbiteintercontinental@gmail.com and we will promptly delete their data.

09

Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via in-app notification and update the "Last Updated" date at the top of this document. Continued use of the app after the effective date constitutes acceptance of the updated policy.

Contact Our Data Controller

BigBite Intercontinental Ltd

No. 5 Lewis Aindero Street, Egan Igando, Alimosho, Lagos, Nigeria

RC No. 1573129

Email: bigbiteintercontinental@gmail.com

For GDPR-specific enquiries, you may also contact the Nigeria Data Protection Commission (NDPC) at ndpb.gov.ng