Privacy Policy

1. Introduction

Welcome to NewBanger. This Privacy Policy explains how NewBanger Digital Limited ("NewBanger", "we", "our", or "us") collects, uses, shares and protects your personal information when you access or use our platform, website and services ("Platform").

This policy is issued in compliance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR), and the guidelines issued by the Nigeria Data Protection Commission (NDPC). Where our services are used by individuals outside Nigeria, we also comply with applicable international data protection laws.

By using NewBanger, you consent to the data practices described in this policy. If you do not agree, please do not use the Platform.

2. Data Controller

For the purposes of the NDPA, the data controller responsible for your personal data is:

3. Lawful Basis for Processing

Under the NDPA, we process your personal data based on one or more of the following lawful grounds:

• Consent: You have given clear consent for us to process your personal data for specific purposes, such as creating an account or receiving marketing communications.
• Contractual Necessity: Processing is necessary to perform our contract with you — delivering campaign services, processing payments, and managing your account.
• Legitimate Interest: Processing is necessary for our legitimate business interests (platform improvement, fraud prevention, analytics) where such interests are not overridden by your rights.
• Legal Obligation: Processing is necessary to comply with Nigerian law, including tax, financial reporting, and regulatory requirements.

4. Information We Collect

Account Information

When you create an account, we collect your first name, last name, email address, phone number, account type (musician or curator), and profile details such as genre preferences, platform links, bio information, date of birth, and profile photo.

Payment & Financial Information

When you make a purchase or receive a payout, our third-party payment processor (Paystack, regulated by the Central Bank of Nigeria) collects your payment details. NewBanger stores wallet balances, transaction references, and payout records but does not store sensitive card details on our servers.

Campaign & Content Data

We collect data related to campaigns you create or participate in, including song titles, artwork, platform links (TikTok, Instagram, Spotify, etc.), video submissions, proof of work, and curator feedback.

Usage Data

We automatically collect information about how you interact with the Platform, including pages visited, features used, campaign activity, search queries and referral sources.

Device & Technical Information

We may collect device type, operating system, browser type, IP address and general location data to improve our services and ensure platform security.

5. How We Use Your Information

• Service Delivery: To create and manage your account, process campaigns, match artists with curators, and deliver promotional services.
• Payment Processing: To process wallet transactions, campaign payments, curator payouts, and manage refunds through our secure payment partners.
• Communication: To send you transactional notifications (campaign updates, submission reviews, payout confirmations) and, with your consent, marketing communications about new features and promotions.
• Platform Improvement: To analyse usage patterns, fix bugs, improve existing features and develop new functionality.
• Security & Fraud Prevention: To detect, investigate and prevent fraudulent transactions, abuse of the Platform, and other harmful activity.
• Legal Compliance: To comply with applicable Nigerian laws, regulations, and lawful requests from authorities.

6. Sharing of Information

We do not sell your personal data. We may share your information in the following circumstances:

• Payment Processors: Transaction data is shared with Paystack to process payments and payouts securely. Paystack is licensed by the Central Bank of Nigeria.
• Campaign Participants: When you create or join a campaign, limited profile information (name, curator type, platform handles) is shared with the other party to facilitate service delivery.
• Cloud Infrastructure: Your data is stored on secure cloud servers provided by our hosting partners, with appropriate data processing agreements in place.
• Analytics Providers: We use Google Analytics and similar tools to understand Platform usage. These providers process data in accordance with their own privacy policies.
• Legal Compliance: We may disclose information where required by Nigerian law, court order, or lawful government request.

7. International Data Transfers

Some of our service providers may process your data outside Nigeria. In accordance with the NDPA and NDPC guidelines, we ensure that any international transfer of personal data is subject to adequate safeguards, including data processing agreements that provide a level of protection consistent with Nigerian data protection law. We will not transfer your data to any country that the NDPC has determined does not provide an adequate level of data protection without implementing appropriate additional safeguards.

8. Cookies & Tracking Technologies

NewBanger uses cookies and similar tracking technologies for the following purposes:

• Essential Cookies: Required for the Platform to function — session management, authentication, and security.
• Analytics Cookies: Help us understand how users interact with the Platform so we can improve the experience.
• Preference Cookies: Remember your settings and preferences across sessions.

You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect core Platform functionality.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Account Data: Retained while your account is active and for 30 days after deletion, unless longer retention is required by law.
• Transaction Records: Retained for a minimum of 6 years to comply with Nigerian financial record-keeping requirements.
• Campaign Data: Retained for the duration of the campaign and 12 months after completion for dispute resolution purposes.
• Usage & Analytics Data: Retained in anonymised form for up to 24 months for platform improvement.

10. Data Security Measures

In compliance with the NDPA, we implement appropriate technical and organisational measures to protect your personal data, including:

• •Encryption of data in transit using TLS/SSL protocols
• •Secure server infrastructure with access controls and firewalls
• •Password hashing and secure authentication mechanisms
• •Regular security reviews and vulnerability assessments
• •Role-based access controls limiting employee access to personal data
• •Incident response procedures for data breaches

While we take all reasonable steps to protect your data, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.

11. Your Rights Under the NDPA

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

• Right of Access: You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to legal retention requirements.
• Right to Restrict Processing: You have the right to request that we limit how we use your data in certain circumstances, such as while a complaint is being investigated.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit that data to another controller.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

To exercise any of these rights, contact our Data Protection Officer at dpo@newbanger.com. We will respond to your request within 30 days.

12. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach, in accordance with the NDPA. Where the breach is likely to result in a high risk to you, we will also notify you directly without undue delay, providing details of the breach, its likely consequences, and the measures we have taken to address it.

13. Children's Privacy

NewBanger is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected data from a minor without appropriate parental consent, we will take steps to delete it promptly and notify the NDPC where required.

14. Automated Decision-Making

NewBanger may use automated processes to match campaigns with curators and to calculate pricing. These processes do not produce legal effects or similarly significant effects on you. You have the right to request human intervention in any automated decision that affects you.

15. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements, including updates to the NDPA or NDPC guidelines. We will notify you of material changes by updating the "Last Updated" date above and, where appropriate, by email notification. Continued use of the Platform after changes constitutes acceptance of the updated policy.

16. Contact Information & Data Protection Officer

If you have questions, concerns, or wish to exercise your data protection rights, please contact us: