Privacy Policy

ThinkRich Naija ("we," "us," "our") operates the ThinkRich Naija website, mobile application, and related quiz show platforms (collectively, "Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our Services.

This policy complies with the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act 2023. By using our Services, you consent to the practices described in this Policy.

Our Data Protection Officer can be reached at info@thinkrichnaija.com.

We collect different types of information depending on how you interact with us:

• Category: Identity Data; Examples: Full name, date of birth, gender, nationality; Required?: Yes (contestants)
• Category: Contact Data; Examples: Email address, phone number, WhatsApp number, home address; Required?: Yes
• Category: Profile Data; Examples: Username, profile picture, quiz history, points, rankings; Required?: Yes (app users)
• Category: Application Data; Examples: Education, employment, skills, social media handles, video submissions; Required?: Yes (applicants)
• Category: Usage Data; Examples: IP address, browser type, device info, pages visited, time spent; Required?: Automatic
• Category: Financial Data; Examples: Bank account details (for prize payments only); Required?: Yes (winners)
• Category: Media Data; Examples: Video recordings, photographs from show appearances; Required?: Consent-based

We do not collect sensitive data (health, biometrics, religious beliefs) unless legally required or explicitly consented to.

The ThinkRich Naija mobile application (available on Google Play and Apple App Store) collects additional data specific to the app experience. This section is provided to meet Google Play and Apple App Store disclosure requirements.

• Data Type: Device Identifiers; What Is Collected: Device ID, advertising ID, OS version, device model; Why: Analytics, crash reporting, fraud prevention; Shared With Third Parties?: Analytics providers (anonymised)
• Data Type: Push Notification Token; What Is Collected: Expo/FCM push token unique to your device; Why: Sending quiz reminders, leaderboard alerts, reward notifications; Shared With Third Parties?: Expo Push Notification Service, FCM (Android), APNs (iOS)
• Data Type: App Usage Data; What Is Collected: Screens visited, quiz sessions played, time in app, button interactions; Why: Improve UX, personalise experience, analytics; Shared With Third Parties?: Analytics providers
• Data Type: Quiz Data; What Is Collected: Questions answered, scores, session outcomes, prize amounts; Why: Score calculation, prize disbursement, leaderboard ranking; Shared With Third Parties?: No
• Data Type: Wallet & Financial Data; What Is Collected: Bank account details (for withdrawal only), transaction history; Why: Prize payment processing, financial compliance; Shared With Third Parties?: Payment gateways (Paystack, Flutterwave)
• Data Type: Referral Data; What Is Collected: Referral codes generated and used; Why: Points attribution, reward calculation; Shared With Third Parties?: No

Data not collected: We do not collect precise GPS location, camera/microphone access (except where explicitly granted for content submission), contacts, health data, or biometric data through the App.

Push notifications: The App uses Expo Push Notification Service, which routes through Firebase Cloud Messaging (Android) and Apple Push Notification Service (iOS). Notification tokens are stored securely on our servers and used solely for sending you relevant in-app communications. You may disable push notifications at any time in your device Settings > Notifications.

Wallet security: Bank account details are collected solely for prize withdrawal purposes and are transmitted only over encrypted HTTPS connections to licensed payment processors. We do not store full bank account numbers or card details on our servers.

We collect data through the following means:

• Direct submission: When you register, apply to be a contestant, fill out contact forms, or communicate with us.
• Automated technology: Cookies, web beacons, and analytics tools that collect usage data as you navigate our platforms. See our Cookie Policy for details.
• Third parties: Social media platforms (if you sign up via social login), payment processors (for prize disbursements), and analytics providers.
• Show participation: Data gathered during filming, audience registration, or on-location Street Quiz interactions.

We process your personal data only for the following lawful purposes:

• Service delivery: To operate the app, manage user accounts, run quizzes, and maintain the leaderboard.
• Contestant management: To review applications, schedule appearances, verify identities, and coordinate prize payments.
• Communication: To respond to inquiries, send notifications about your application or account, and share service updates.
• Marketing: To send newsletters and promotional content where you have opted in. You may opt out at any time.
• Analytics & improvement: To understand how users interact with our Services and improve platform performance.
• Legal compliance: To meet our obligations under Nigerian law, including tax and financial reporting.
• Safety: To detect and prevent fraud, abuse, and security breaches.

We will never sell your personal data to third parties for their marketing purposes.

We may share your data with the following categories of recipients:

• Production partners: TV stations, broadcasters, and production companies involved in airing ThinkRich Naija shows.
• Payment processors: Banks and financial services providers used to disburse prize money.
• Technology providers: Cloud hosting, analytics, and app development partners who process data on our behalf under strict confidentiality agreements.
• Regulators and law enforcement: When required by law, court order, or to protect the rights and safety of ThinkRich Naija and its users.

Any third parties who process data on our behalf are bound by data processing agreements and may not use your data for their own purposes.

Your data is stored on secure servers located in Nigeria and/or in certified cloud environments. We implement industry-standard technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest.
• Access controls limiting who within our organization can view personal data.
• Regular security audits and vulnerability assessments.
• Staff training on data handling and privacy best practices.

No method of internet transmission is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

We retain personal data only for as long as necessary for the purposes outlined in this Policy:

• Active user accounts: Data retained while account is active, plus 2 years after account closure.
• Contestant applications: Retained for 3 years after the application date.
• Financial records: Retained for 6 years in compliance with Nigerian financial regulations.
• Marketing preferences: Until you withdraw consent.
• Analytics data: Aggregated and anonymized after 24 months.

After the applicable retention period, data is securely deleted or anonymized.

Under the Nigeria Data Protection Act 2023, you have the following rights regarding your personal data:

• Right to Access: Request a copy of all personal data we hold about you.
• Right to Rectification: Correct inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data in certain circumstances.
• Right to Object: Object to processing of your data for marketing or profiling purposes.
• Right to Portability: Receive your data in a structured, machine-readable format.
• Right to Withdraw Consent: Withdraw consent for processing at any time where consent is the basis.

To exercise any of these rights, contact us at info@thinkrichnaija.com. We will respond within 30 days. We may need to verify your identity before processing your request.

You have the right to request deletion of your personal data and ThinkRich Naija account at any time. We honour this right as required by the Nigeria Data Protection Act 2023 and as mandated by Apple App Store guidelines.

How to request deletion:

1. Via the App (recommended): Go to Settings > Account > Delete Account within the ThinkRich Naija App. Follow the on-screen prompts to confirm your request.
2. Via email: Send a deletion request to info@thinkrichnaija.com with subject line "Account Deletion Request" and your registered email address. We will process your request within 30 days.

What happens when you delete your account:

• Your profile, quiz history, points, and leaderboard data are permanently deleted from active systems.
• Any outstanding wallet balance must be withdrawn before deletion. Remaining unclaimed balances are forfeited after 30 days.
• Your personal data will be erased from our databases, subject to the retention exceptions below.

Data we may retain after deletion (legal/compliance basis only):

• Financial transaction records — retained for 6 years as required by Nigerian financial regulations.
• Fraud and abuse records — retained where necessary to prevent re-registration by banned users.
• Aggregate anonymised analytics data — no longer linked to your identity.

For a detailed guide on the deletion process, visit our dedicated Account Deletion page.

Our Services are not directed to children under the age of 13. We do not knowingly collect personal data from children under 13 without verifiable parental consent. If we discover that we have inadvertently collected data from a child under 13, we will delete it promptly.

Users aged 13 — 17 may participate in our Schools Quiz Show and app with parental consent. Parents may contact us to review, update, or delete their child's information.

Our Services may contain links to third-party websites and social media platforms (Instagram, TikTok, YouTube, etc.). These third parties operate under their own privacy policies, which we encourage you to review. We are not responsible for the privacy practices of third-party sites and have no control over how they collect or use your data.

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated policy on this page with a new "Last updated" date.
• Sending an email notification to registered users for significant changes.
• Displaying a notice within the app.

Your continued use of our Services after any changes constitutes acceptance of the updated Privacy Policy.

For all privacy-related questions, data subject requests, or concerns about how we handle your personal data, please contact our Data Protection Officer:

• Email: info@thinkrichnaija.com
• Phone: +234 8125073965 / +234 7054167227
• Address: 31 Afolabi Aina Street, Royal Bed Estate, Ikeja, Lagos State, Nigeria

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).