1. Introduction
TrueVoix Nigeria Limited (‘TrueVoix’, ‘we’, ‘us’, ‘our’, ‘Company’), recognises your privacy rights as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria, the Nigerian Data Protection Act 2023 (NDPA), the Nigerian Data Protection Regulation 2019 (NDPR), and the privacy provisions in other relevant laws applicable to our business in Nigeria. It is important to us as a law-abiding organisation that your Personal Data is managed, processed, and protected in accordance with the provisions of the applicable laws. During our business and/or your engagement with us and third parties through our Platforms (including our websites, mobile applications, and any related services), we may collect, use, and share your Personal Data as described in this Privacy Policy.
By creating an account, completing identity verification, or otherwise using TrueVoix, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform.
2. Information We Collect
We collect the following categories of information in connection with your use of TrueVoix:
2.1 Information You Provide to Us
- Identity information: full name, date of birth, gender, phone number, and email address.
- Government identification: National Identification Number (NIN), Bank Verification Number (BVN), International Passport, or Driver’s Licence.
- Biometric data: a live facial capture used for face verification during KYC.
- Civic information: your constituency, senatorial district, and Local Government Area (LGA), used to connect you with the correct representative.
- Content you submit: poll responses, town hall contributions, topic suggestions, comments, and videos you upload to the Platform.
- Communications: messages you send to our support team or through in-app reporting features.
2.2 Information Collected Automatically
- Device information: device model, operating system, unique device identifiers, and mobile network information.
- Usage data: app interactions, session duration, features used, and crash/diagnostic logs.
- Location data: general or precise location, where enabled, used primarily to tag video uploads and confirm constituency eligibility.
2.3 Information from Third Parties
- Verification results from identity partners engaged to confirm your NIN/BVN and biometric data against government records.
- Representative and constituency data validated against records from the Independent National Electoral Commission (INEC).
- Civic news content aggregated from third-party news providers to power the in-app news feed.
3. How We Use Your Information
We use the information we collect to:
- Create and manage your TrueVoix account.
- Verify your identity and eligibility to participate as a Constituent or Representative, and prevent duplicate accounts, fraud, and impersonation.
- Connect you with your correct elected representative based on your constituency, senatorial district, or LGA.
- Enable participation in polls, Town Halls, the Lobby, and other civic engagement features.
- Personalise the civic news feed based on your constituency and representative activity.
- Send you service notifications, OTPs, and important updates via SMS and email.
- Moderate content to maintain a safe, respectful civic environment and enforce our Terms & Conditions.
- Investigate reports of abuse, misconduct, or violations of our Acceptable Use Policy.
- Comply with applicable Nigerian law, including obligations under the NDPA 2023.
- Improve, secure, and develop new features for the Platform.
4. Legal Basis for Processing
We process your Personal Data on one or more of the following legal bases recognised under the NDPA 2023: your consent, the necessity of processing to perform our contract with you (i.e., to provide TrueVoix's services), compliance with a legal obligation, and our legitimate interests in operating a secure, trustworthy civic platform — provided such interests do not override your fundamental rights and freedoms.
5. How We Share Your Information
We do not sell your Personal Data. We may share your information in the following circumstances:
- Identity verification partners: to validate your NIN, BVN, and biometric data against authorised government and financial databases.
- Government bodies: including the National Identity Management Commission (NIMC) and the Independent National Electoral Commission (INEC), for identity and representative validation.
- Service providers: infrastructure, messaging, and email providers engaged to host the Platform and deliver SMS/OTP and email communications on our behalf, bound by confidentiality and data protection obligations.
- Representatives: limited, aggregated, or profile-level information necessary for a Representative to engage with their verified constituents (e.g., poll results, Town Hall participation).
- Legal and regulatory authorities: where disclosure is required by law, court order, or to protect the rights, safety, or property of TrueVoix, our users, or the public.
- Business transfers: in connection with a merger, acquisition, or sale of assets, subject to continued protection of your data under this Policy.
6. Data Storage & Security
Your data is stored on secure cloud infrastructure with access controls, encryption in transit and at rest, and regular security reviews. Biometric and government identification data are treated as sensitive Personal Data and are subject to enhanced safeguards. While we take reasonable technical and organisational measures to protect your data, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
7. Data Retention
We retain your Personal Data for as long as your account remains active and as necessary to fulfil the purposes described in this Policy, including legal, regulatory, tax, or accounting requirements. Where you request account deletion, we will delete or anonymise your Personal Data within a reasonable period, except where continued retention is required by applicable law or to resolve disputes.
8. Your Rights
Subject to applicable law, including the NDPA 2023, you have the right to:
- Access the Personal Data we hold about you.
- Request correction of inaccurate or incomplete data.
- Request deletion of your Personal Data, subject to legal retention obligations.
- Withdraw consent for non-essential processing at any time, without affecting the lawfulness of processing carried out before withdrawal.
- Object to or request restriction of certain processing activities.
- 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 us at support@truevoix.com. We may need to verify your identity before actioning your request.
9. Cookies & Similar Technologies
Our website and app may use cookies, SDKs, and similar technologies to remember your preferences, keep you signed in, and understand how the Platform is used. You can manage cookie preferences through your browser or device settings; disabling certain cookies may affect Platform functionality.
10. Children's Privacy
TrueVoix is intended for users who are at least 18 years old, consistent with Nigeria's voting age and our civic purpose. We do not knowingly collect Personal Data from individuals under 18 without the consent of a parent or legal guardian. If we become aware that we have collected data from a minor without appropriate consent, we will take steps to delete it.
11. International Data Transfers
Where your Personal Data is processed or stored outside Nigeria (for example, by cloud infrastructure or service providers), we take steps to ensure such transfers are conducted in accordance with the NDPA 2023 and with appropriate safeguards to protect your data.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes through the app or by other reasonable means. Continued use of TrueVoix after such changes constitutes your acceptance of the updated Policy.
13. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your Personal Data, please contact us: