Privacy Policy

1. Introduction

This Privacy Policy explains how we collect, store, process, and share Personal Data about you. We are committed to protecting your privacy and complying with applicable data protection laws.

Pink Africa is operated by MySubApp Limited, a company registered in the Federal Republic of Nigeria with RC Number 1956588, with its registered office at 125, Ugwuaji Road, Independence Layout, Enugu, Enugu State, Nigeria. References in this Privacy Policy to “we”, “us” and “our” are to MySubApp Limited.

2. What is Personal Data?

“Personal Data” means any information that relates to an identifiable individual. Information that is anonymised so that you cannot be identified from it is not Personal Data.

3. Informing Us of Changes

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes by updating your account or by contacting us at privacy@pink.africa.

4. Applicability

Pink Africa is intended exclusively for adults aged 18 or over. We do not knowingly collect Personal Data about anyone under 18.

5. Third-Party Links

Pink Africa may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party sites and are not responsible for their privacy notices.

6. If You Do Not Wish to Provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In that case, we may have to cancel or refuse to provide a product or service you have requested.

7. Updates to this Policy

We may update this Privacy Policy from time to time. If we make material changes, we will Notify you. Your continued use of Pink Africa after any change indicates your acceptance of the updated Privacy Policy.

8. Categories of Personal Data

We may collect, use, store, and transfer different kinds of Personal Data about you, which we have grouped as follows:

• User Data: first name, last name, username, date of birth, gender, country of residence, and any additional information you choose to provide.
• Third-Party Onboarding Data: data we receive from third-party services you use to register or sign in (such as a social login provider).
• Account Data: email address, password, account preferences, communication preferences, and verification status.
• Financial Data: bank account details, payment card details, e-wallet details, and Payout Option details.
• Transaction Data: details about Fan Payments, Creator Earnings, refunds, chargebacks, and other transactions related to your use of Pink Africa.
• Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Pink Africa.
• Usage Data: information about how you use Pink Africa, the Content you view, and your interactions with other Users.
• Face Recognition Data: biometric data derived from photos or videos you submit during identity verification.
• Background Screening Data: the results of identity, age, and sanctions screening conducted as part of onboarding.

9. Our Onboarding Processes

As part of onboarding (especially for Creator accounts), we may request government issued ID, additional photos, and other verification information. We use this information to verify your identity, comply with applicable laws, and protect Pink Africa and our Users from fraud.

We may use trusted third-party service providers to conduct identity, age, and sanctions screening. These providers process your Personal Data on our behalf and are bound by confidentiality and data protection obligations.

10. How and Why Your Personal Data is Used

We will only use your Personal Data when the law allows us to. Most commonly, we use your Personal Data in the following circumstances:

• Consent: where you have given us clear consent to process your Personal Data for a specific purpose.
• Performance of contract: where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests.
• Compliance with legal obligations: where we need to comply with a legal or regulatory obligation.
• Task in public interest: where processing is necessary for the performance of a task carried out in the public interest.

11. Obtaining Your Personal Data

We use different methods to collect Personal Data from and about you including through:

• Direct interactions: you may give us your Personal Data by filling in forms, registering an account, or by corresponding with us by post, phone, email, or otherwise.
• Automated technologies or interactions: as you interact with Pink Africa, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns.
• Third parties or publicly available sources: we may receive Personal Data about you from various third parties, including identity verification providers, payment service providers, and analytics providers.

12. Sharing Your Personal Data

We may share your Personal Data with the following categories of recipients:

• Other Users — where you choose to make information visible to them.
• Service providers who provide IT, hosting, identity verification, payment processing, customer support, analytics, and similar services.
• Professional advisers such as lawyers, accountants, and auditors.
• Regulators and other authorities where required by law or to protect our rights.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes.

13. International Data Transfers

Your Personal Data may be transferred to, stored at, or processed in a country outside your country of residence. Whenever we transfer your Personal Data out of your jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection.
• Where we use certain service providers, we may use specific contracts approved by regulators which give Personal Data the same protection it has in your jurisdiction.

14. Your Rights Regarding Personal Data

Under applicable data protection laws, you may have the following rights in relation to your Personal Data:

• Request access to your Personal Data.
• Request correction of your Personal Data.
• Request erasure of your Personal Data.
• Object to the processing of your Personal Data.
• Request restriction of processing of your Personal Data.
• Request the transfer of your Personal Data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your Personal Data.

15. Exercising Your Rights

You can exercise your rights by contacting us at privacy@pink.africa. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will Notify you and keep you updated.

16. Retention of Personal Data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further Notice to you.

17. Assistance and Contact Information

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us:

• By email: privacy@pink.africa
• By post: MySubApp Limited, 125 Ugwuaji Road, Independence Layout, Enugu, Enugu State, Nigeria

You also have the right to make a complaint at any time to the data protection authority in your jurisdiction.