Legal Document

Privacy Policy

This Privacy Policy describes how PrimLogistics Technologies Limited ("PrimLogistics", "we", "us", or "our") collects, uses, stores, and protects your personal information when you use our platform, mobile application, or website.

Effective Date: 1 January 2025  ·  Governing Law: Federal Republic of Nigeria

Contents

1. Information We Collect

2. How We Use Your Information

3. Information Sharing

4. Data Security

5. Data Retention

6. Your Rights

7. Cookies & Tracking Technologies

8. Changes to This Policy

9. Contact Us

1

Information We Collect

We collect information you provide directly and information generated through your use of our services:

a. Account & Identity Information

  • Full name and profile photograph
  • Email address
  • Phone number
  • Government-issued identification (for agents: NIN, BVN, or driver's licence)
  • Date of birth (to verify age eligibility)

b. Delivery & Transaction Information

  • Sender and recipient names, phone numbers, and addresses
  • Package descriptions, declared values, and special handling requirements
  • Delivery history, tracking events, and delivery confirmation codes
  • PrimWallet transaction records (top-ups, payments, withdrawals, and transfers)
  • Payment instrument details (card tokens — we do not store raw card numbers)
  • Bank account details provided for withdrawal purposes

c. Device & Usage Data

  • IP address, browser type and version, operating system
  • Device identifiers and push notification tokens
  • Pages visited, features used, and time spent on the platform
  • Approximate geolocation data (for matching agents and estimating delivery time)
  • Precise GPS location (agents only, during active delivery — with your permission)
  • Crash reports and diagnostic logs

d. Communications

  • Messages sent through our in-app chat or support channels
  • Feedback, ratings, and reviews you submit
  • Enquiries submitted via our contact form or email
2

How We Use Your Information

We use the information we collect for the following purposes:

a. Service Delivery

  • Processing and fulfilling delivery orders from booking to completion
  • Matching senders with available, verified delivery agents
  • Providing real-time tracking updates to senders and recipients
  • Generating and verifying delivery confirmation codes

b. Wallet & Payment Management

  • Processing PrimWallet top-ups, payments, and withdrawals
  • Crediting agent earnings (80% of fare) upon delivery confirmation
  • Maintaining accurate transaction histories and generating receipts
  • Fraud detection and prevention

c. Account Management & Support

  • Creating and managing your PrimLogistics account
  • Verifying agent identity and eligibility
  • Responding to enquiries, disputes, and support requests
  • Sending service-related notifications (delivery updates, payment receipts, security alerts)

d. Legal & Compliance

  • Complying with applicable Nigerian laws and regulations
  • Responding to lawful requests from regulatory authorities or law enforcement
  • Enforcing our Terms of Service and other policies

e. Marketing & Communications (Opt-Out Available)

  • Sending promotional emails, SMS, or push notifications about new features, offers, and updates
  • Conducting surveys and collecting feedback to improve our services

Opt-out: You may unsubscribe from marketing communications at any time by clicking the "Unsubscribe" link in any marketing email, replying STOP to any SMS, or adjusting notification settings in your account dashboard.

3

Information Sharing

We do not sell, rent, or trade your personal information to third parties. We share information only in the following limited circumstances:

a. Delivery Agents

When a delivery is assigned to an agent, that agent receives the sender's and recipient's name, phone number, and delivery address — solely for the purpose of completing the delivery. Agents are contractually prohibited from using this information for any other purpose.

b. Payment & Financial Partners

We share payment information with licensed payment processors and financial institutions (such as Paystack, Flutterwave, or partner banks) to facilitate wallet transactions and withdrawals. These partners are bound by their own privacy policies and applicable Nigerian financial regulations.

c. Technology Service Providers

We use trusted third-party service providers for hosting, analytics, push notifications, and customer support tools. These providers access your data only as necessary to perform services on our behalf and are bound by data processing agreements.

d. Legal Disclosure

We may disclose your information where required by law, court order, or governmental authority, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of PrimLogistics, our users, or the public.

e. Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity. We will notify you via email or prominent notice on our platform before your information is transferred and becomes subject to a different privacy policy.

4

Data Security

We implement industry-standard technical and organisational measures to protect your personal information against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

  • Transport Layer Security (TLS) encryption for all data transmitted between your device and our servers
  • AES-256 encryption for sensitive data stored at rest
  • PIN-based authentication for PrimWallet transactions
  • Two-factor authentication (2FA) support for account access
  • Access controls limiting staff access to personal data on a need-to-know basis
  • Regular security audits and vulnerability assessments
  • Secure disposal of data when no longer required

While we take all reasonable steps to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We encourage you to use a strong, unique password for your PrimLogistics account and to enable 2FA.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the Nigeria Data Protection Commission (NDPC) in accordance with the Nigeria Data Protection Act 2023.

5

Data Retention

We retain your personal information for as long as your account is active or as needed to provide our services. Specific retention periods:

  • Active account data: Retained for the duration of your account's existence plus a minimum of 5 years for financial records, in compliance with Nigerian tax and financial regulations.
  • Delivery records: Retained for 3 years from the date of delivery to support dispute resolution.
  • Account closure: Upon a valid account deletion request, we will delete or anonymise your personal data within 30 days, except where retention is required by law.
  • Legal holds: Where data is subject to an active legal dispute or regulatory investigation, it will be retained until the matter is fully resolved.

You may request deletion of your account and associated personal data by contacting us at privacy@primlogistics.ng. We will confirm receipt of your request within 48 hours and complete the deletion within 30 days.

6

Your Rights

Under the Nigeria Data Protection Act 2023 (NDPA) and applicable regulations, you have the following rights with respect to your personal information:

  • Right of Access: You may request a copy of the personal information we hold about you.
  • Right to Rectification: You may request correction of inaccurate or incomplete personal information.
  • Right to Erasure: You may request deletion of your personal information, subject to legal retention obligations.
  • Right to Data Portability: You may request your personal information in a structured, machine-readable format.
  • Right to Object: You may object to the processing of your personal information for direct marketing purposes at any time.
  • Right to Restrict Processing: You may request that we restrict the processing of your personal information in certain circumstances.
  • Right to Withdraw Consent: Where processing is based on your consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Protection Officer at:

Data Protection Officer

Email: privacy@primlogistics.ng

Address: 14 Commerce Road, Ikeja, Lagos State, Nigeria

We will respond to all data rights requests within 30 days. If you are unsatisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

7

Cookies & Tracking Technologies

We use cookies and similar tracking technologies (such as web beacons and local storage) to enhance your experience on our platform. These include:

  • Essential Cookies: Necessary for the platform to function (e.g., session management, authentication). These cannot be disabled.
  • Analytics Cookies: Help us understand how users interact with our platform so we can improve it (e.g., page visit counts, feature usage). We use anonymised or aggregated data wherever possible.
  • Preference Cookies: Remember your settings and preferences (e.g., language, notification preferences).
  • Marketing Cookies: Used to deliver relevant promotional content. You may opt out via our cookie preference centre or your browser settings.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our platform.

8

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will:

  • Update the effective date at the top of this policy
  • Display a prominent notice on our website and/or mobile application
  • Send a notification to your registered email address if the changes are significant

Your continued use of PrimLogistics services after the effective date of any revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this policy periodically.

9

Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

PrimLogistics Technologies Limited

Email: privacy@primlogistics.ng

Support: support@primlogistics.ng

Address: 14 Commerce Road, Ikeja, Lagos State, Nigeria

Registered under the laws of the Federal Republic of Nigeria

This Privacy Policy was last updated on 1 January 2025 and is effective as of that date. It is governed by the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act 2023 (NDPA).