Privacy Policy

Overview

Lagos Markets is a digital discovery platform for physical markets in Lagos. We help buyers find products and stores before they travel, and we help store owners, market agents and verification agents present their work online.

This policy explains what personal data we collect, why we collect it, who we share it with and the choices you have. It applies to the website and app at lagosmarkets.app and any related services, and it forms part of our Terms of Service.

The data controller is Lagos Markets, Ikeja, Lagos, Nigeria. We handle personal data in line with the Nigeria Data Protection Act 2023 (NDPA).

Information we collect

What we collect depends on how you use Lagos Markets.

• Account details: your email address, display name and phone or WhatsApp number, so you can sign in and so that stores, agents and buyers can reach each other where you choose.
• Store and role information: if you apply as a store owner, market agent or verification agent, the details of your shop or role, such as shop address, opening hours, specialties and coverage area.
• Identity information: for market agents and verification agents, your ID type, ID number and, where requested, a photo of your ID, used to confirm who you are.
• Payout details: for verification agents, your bank name and account number, and a record of your payouts.
• Verification evidence: photos of a shop's exterior, interior, signage and shop number, photos of the owner or operator inside the shop, ownership or tenancy documents, and GPS coordinates captured during the visit. These photos may include other people who happen to be in the shop.
• Marketplace content: listings, prices, stock status, store descriptions, photos and reviews that you choose to publish. Reviews are public and shown with your name.
• Requests and offers: if you use “Find Me a Deal”, we store your request details, the offers agents submit, and your approximate location, which is captured automatically when you make a request and used only to help match you with nearby agents.
• Shared location: after an offer is accepted, you and the agent can each choose to share your location. This is a one-time snapshot taken when you tap the button, and it replaces your previous snapshot. We don't track you continuously and we don't request background location access.
• Payment information: if you pay a verification fee or subscription, our payment provider processes your payment details. We receive a record that you paid, but we don't store your full card details.
• Notification data: if you enable push notifications, we store a device token so we can send you updates you have asked for.
• Usage data: pages viewed, searches made, and actions such as store views, WhatsApp, call and directions clicks, used to improve the platform and to show store owners how buyers interact with their listings.

How we use your information, and our legal basis

We use personal data only where we have a lawful basis to do so under the NDPA:

• To provide the service you asked for (contract): displaying listings and stores, routing buyer requests to agents, processing offers, running verification and paying verification agents.
• To keep the platform trustworthy (legitimate interests): verifying stores and agents, preventing fraud and counterfeit listings, moderating reviews, keeping accounts secure and keeping an audit trail of verification decisions.
• To send you notifications and optional communications (consent): push notifications and similar updates, which you can switch off at any time.
• To improve the platform (legitimate interests or consent, depending on the tool): analytics, search relevance and product development.
• To meet legal obligations: keeping financial records, responding to lawful requests from authorities and handling regulatory duties.

Who can see what

Your contact details stay under your control, and the platform is built so they are shared only at the point they are needed.

• Buyers: your phone or WhatsApp number is shared with an agent only after you accept that agent's offer, and is never shown to a store before the agent introduces the parties. Your approximate location is visible to agents only as a rough distance, never as an address.
• Agents: your name, photo, rating, specialties and the stores you work with are visible to buyers, and your phone or WhatsApp number is shared with a buyer once an offer is accepted. Agent margins are never shown to buyers or stores.
• Store owners: your store name, address, phone, WhatsApp, opening hours, listings and reviews are public. Stores see buyer requests in their market without buyer contact details.
• Verification agents: your identity and payout details are visible only to the team that manages verification and payments.
• Identity documents, ID numbers, verification evidence and bank details are never shown publicly and are visible only to the small team that reviews verification and payouts.

People in verification photos

Verification agents photograph shops, including the registered owner or operator inside the shop, and photos may also capture staff or customers. We use these photos only to confirm a shop's existence, location and operator, and we don't publish them.

If you appear in a verification photo and have a concern, or want it reviewed, email support@lagosmarkets.app and we'll look into it.

Third-party services

We use a small number of providers to run Lagos Markets, and each receives only the data it needs to do its job:

• Supabase, for hosting our database, authentication and file storage.
• Cloudinary, for image uploads such as store photos and verification evidence (shop photos, signage, ownership and tenancy documents), which must be stored privately.
• Google Maps Platform, for maps, location and directions.
• Firebase Cloud Messaging, for push notifications.
• Google Analytics, for usage statistics.
• Paystack, for payment processing, if you pay a fee or subscription.
• Meta (WhatsApp Business), for WhatsApp communication between buyers and stores or agents.
• Generative AI models, for suggesting listing details from product photos. Images you upload for this are processed by these providers, whose own terms may allow them to use submitted content to improve their services.

Sharing, legal disclosure and business changes

We do not sell your personal data. We share it only with the providers above, with other users as described in “Who can see what”, and where the law requires.

We may disclose data to Nigerian authorities or courts where we are legally required to, or where it is necessary to investigate fraud or protect the safety of our users. If Lagos Markets is sold, merged or restructured, personal data may be transferred to the new owner, who must honour this policy or tell you before any change.

Transfers outside Nigeria

Many of our providers store or process data outside Nigeria. When we transfer personal data abroad, we do so only where the NDPA allows it, for example where the recipient provides an adequate level of protection, where there are suitable contractual safeguards, or where you have consented.

Security

We protect personal data with access controls, encrypted connections and limits on which staff can see identity documents and verification evidence. No system is perfectly secure, so we also encourage you to keep your sign-in details safe.

If a data breach is likely to put your rights and freedoms at risk, we will notify the Nigeria Data Protection Commission and affected users within the time the law requires.

Cookies and local storage

We use a small amount of browser storage to keep the site working: a session cookie to keep you signed in, local storage to remember preferences such as your selected market, recent searches and notification settings, and a service worker cache that lets the app load faster and work with a weak connection. We also use analytics cookies to understand how the site is used.

You can clear or block storage in your browser settings, and you can opt out of analytics cookies through Google's opt-out browser add-on. The site will still work, but you may need to sign in again.

How long we keep your data

We keep personal data only as long as we need it for the purposes above. The periods below are our current approach, and they may be longer where the law requires.

• Account details: for as long as your account is open, and deleted within 30 days of a confirmed deletion request, apart from the records listed below.
• Active verification evidence and ID documents: for as long as the verification is valid (90 days plus a 7-day grace period), plus 12 months to handle disputes and re-verification.
• Historical verification records: a minimal record of each decision, who made it and when, kept for 3 years for audit and fraud prevention, without the underlying photos.
• Payment, fee and payout records: for 6 years, or as long as tax and accounting law requires.
• Buyer requests and offers: for 6 months after they close, then deleted or anonymised.
• Shared location snapshots: deleted 30 days after the deal is completed or expires.
• Backups and cached copies may persist for a short additional time before they are overwritten.

Your rights

Under the NDPA you have the right to access your personal data, correct it, delete it, restrict or object to how we use it, receive a portable copy, and withdraw your consent at any time where we rely on it. Withdrawing consent doesn't affect anything we did before you withdrew.

To use any of these rights, email support@lagosmarkets.app. We aim to respond within 30 days, and we may need to confirm your identity first. Some records, such as payment history, we must keep by law, and we'll explain if that applies to your request.

If you are unhappy with how we've handled your data, you also have the right to complain to the Nigeria Data Protection Commission.

Children

Lagos Markets is for people aged 18 and over, and it is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has created an account, contact us and we will remove it.

Changes to this policy

We may update this policy as the platform grows. When we make meaningful changes, we will update the “Last updated” date at the top of this page and, where appropriate, notify account holders directly.

Contact us

Questions about this policy or your data? Email support@lagosmarkets.app or write to Lagos Markets, Ikeja, Lagos, Nigeria.

No data protection officer has been appointed; this will be updated if one is appointed.