Nigeria Data Protection Act (NDPA) 2023 Compliant

Privacy Policy & Data Protection Charter

Flapjack Technologies Ltd. · Effective Date: September 10, 2026 · Version 1.0 · Applies to flapjack.top, mobile apps, and the Chrome extension.

1Data Controller & Scope

This Privacy Policy describes how Flapjack Technologies Ltd. (“Flapjack”, “we”, “our”, or “us”) collects, stores, processes, discloses, and protects your personal data when you use our web platform, mobile applications, Chrome extension, and related services.

Flapjack operates as a Data Controller in compliance with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) overseen by the Nigeria Data Protection Commission (NDPC).

Flapjack is a skill-based gaming platform where users wager coins on gameplay objectives, submit video recordings as proof, and receive prizes after verification. This policy covers all data processing related to accounts, wallets, bets, recordings, identity verification, and social features.

2Categories of Personal Data Collected

2.1 Identity & Account Data

Full name, email address, profile display name, authentication identifiers, and account preferences. Authentication is managed through our identity provider (Clerk). We do not store your password in plaintext.

2.2 KYC & Age Verification Data

National Identification Number (NIN), date of birth, NIN lookup results (including name, photo, and verification PDF returned by our KYC provider), KYC submission timestamps, verification status, and consent records. KYC is required before creating bets and confirms users are 18 or older.

2.3 Wallet & Financial Data

Coin balance, deposit and withdrawal history, Paystack payment reference tokens, transaction amounts and statuses, bank account name, account number, and bank name (for approved withdrawals). We do not store raw debit or credit card numbers — payments are processed by Paystack.

2.4 Gaming, Bet & Recording Data

Bet codes, game URLs, stake amounts, objectives, multiplayer participation, recording tokens, gameplay video uploads, scores, rankings, admin review notes, prize distributions, and reward history.

2.5 Social & Communication Data

Friend requests, friendships, in-app chat messages, notifications, and activity timestamps (such as last seen).

2.6 Chrome Extension Session Data

When using the Flapjack Chrome extension, your email and recording token are stored locally in your browser during an active recording session to upload gameplay proof. This data is cleared after a successful upload.

3Lawful Bases for Processing

Pursuant to Section 25 of the NDPA 2023, we process personal data only when a lawful basis applies:

  • Contractual Necessity: To create and manage your account, process bets, verify gameplay, operate your wallet, facilitate withdrawals, and deliver platform features you request.
  • Legal & Regulatory Obligation: To verify age and identity (NIN/KYC), maintain financial records, and respond to lawful regulatory or law enforcement requests.
  • Consent: For optional notifications, marketing communications (where offered), and KYC data processing — which you may withdraw at any time.
  • Legitimate Interests: To prevent fraud, enforce platform rules, resolve bet disputes, protect user safety, and maintain service integrity.

4Data Sharing & Third-Party Sub-Processors

We share personal data only as necessary to operate Flapjack:

  • Between matched players: When you join a multiplayer bet, other participants may see your display name, bet participation, and submitted recordings as part of verification.
  • Clerk Inc.: Authentication, session management, and account security.
  • Paystack Payments Ltd.: CBN-licensed, PCI-DSS Level 1 certified payment gateway for wallet deposits. We never view or store raw card numbers.
  • Mono (WithMono): NIN lookup and identity verification for KYC compliance.
  • Neon (Lakebase Postgres): Encrypted managed PostgreSQL database for application data storage.
  • Vercel Inc.: Application hosting, edge delivery, and infrastructure with DDoS protection.
  • Expo (EAS): Mobile app build and distribution infrastructure for iOS and Android releases.

Zero Commercial Sale Guarantee: We do not sell, rent, or lease personal data to third-party advertisers or data brokers under any circumstances.

5International & Cross-Border Data Transfers

In accordance with Sections 41–43 of the NDPA 2023, Flapjack uses international cloud infrastructure (including Neon, Vercel, Clerk, and Paystack service regions) that may process data outside Nigeria.

Adequacy Safeguards Employed:

  • Data Processing Agreements (DPAs): Contracts with sub-processors requiring data protection standards equivalent to the NDPA.
  • Encryption in transit: TLS 1.2+ for all network transmissions.
  • Encryption at rest: Provider-managed encryption for database and stored recordings.
  • Data minimization: Only necessary data is shared with each sub-processor for its specific function.

6Technical & Organizational Security Measures

Encryption Standards

TLS encryption in transit; provider-managed encryption at rest for databases and uploaded gameplay recordings.

Access Controls

Role-based admin access for KYC review, bet adjudication, and withdrawal approval. User data is scoped to authenticated sessions.

Authentication Security

Passwords and OAuth credentials are managed by Clerk using industry-standard cryptographic hashing. We never store plaintext passwords.

Recording & KYC Isolation

Gameplay videos and NIN verification data are accessible only to authorized admins for review and dispute resolution.

7Data Retention & Erasure Schedule

Personal data is retained only for as long as necessary to fulfill the purposes in this Policy:

Data CategoryRetention PeriodRationale
Account profile & contact infoDuration of active account + 12 months after closureAccount management and post-closure support inquiries
KYC / NIN verification dataDuration of verified status; purged within 30 days of account deletionAge verification, fraud prevention, and regulatory compliance
Bet history & gameplay recordings5 yearsDispute resolution, payout verification, and platform integrity
Wallet & Paystack transaction logs6 yearsFinancial audit and payment reconciliation
Bank account details (withdrawals)Until account deletion or bank details are removed by userProcessing approved withdrawal payouts
Chat messages between usersDuration of active account + 12 monthsUser communication and abuse-report investigations

8Data Subject Rights (NDPA 2023)

Under Part V of the NDPA 2023, you may exercise the following rights free of charge:

  1. 1. Right of Access

    You may request a copy of the personal data we hold about you.

  2. 2. Right to Rectification

    You can update inaccurate profile information via Settings or by contacting us.

  3. 3. Right to Erasure

    You may request deletion of your account and associated personal data, subject to legal retention requirements.

  4. 4. Right to Restrict Processing

    You can ask us to limit processing while a data accuracy dispute is resolved.

  5. 5. Right to Data Portability

    You may receive your personal data in a structured, machine-readable format where applicable.

  6. 6. Right to Object & Withdraw Consent

    You can object to non-essential processing or withdraw consent for optional features at any time.

To exercise any of these rights, contact our Data Protection Officer at privacy@flapjack.top. We will acknowledge and respond within 30 days as required by law.

9Personal Data Breach Management

In accordance with Section 40 of the NDPA 2023, Flapjack maintains an incident response protocol:

  • 72-hour regulatory notification: Confirmed breaches likely to affect rights and freedoms will be reported to the NDPC within 72 hours of discovery.
  • User notification: Where a breach poses high risk, affected users will be notified without undue delay via email and in-app notice.
  • Containment: Immediate steps to revoke compromised access, patch vulnerabilities, and preserve forensic audit trails.

10Regulatory Oversight & Complaints

If you have concerns about how your data is handled, contact our DPO first. You also have the right to escalate complaints to the national supervisory authority:

Nigeria Data Protection Commission (NDPC)

No. 5, Charles de Gaulle Close, Asokoro, Abuja, FCT, Nigeria

info@ndpc.gov.ng · ndpc.gov.ng

11Contact & Policy Updates

We may update this Privacy Policy to reflect product changes, new features, or legal requirements. Material changes will be communicated via email or in-app notification before taking effect.

Flapjack Technologies Ltd.

For platform rules, wagering terms, and user conduct standards, please review our Terms of Service.