Privacy Policy

Applies to: www.iqly.net and all iQLY Websites and Services

Governed by the Nigeria Data Protection Act 2023 (NDPA), Nigeria Data Protection Regulation 2019 (NDPR), and the General Application and Implementation Directive 2025 (GAID)

iQLY Global Ltd, doing business as iQLY (“iQLY,” “we,” “us,” or “our”), is committed to protecting the personal data of everyone who uses our platform. This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, how long we retain it, and what rights you have in relation to it.

We operate a challenge-based crowdsourcing platform that connects businesses (“Challengers”) with individuals (“Solvers” or “Contributors”) who submit ideas, insights, and solutions. Everything we do with your personal data is governed by this Policy and applicable Nigerian data protection law.

Plain-English summary: We collect only what we need to run the platform, process payments, and keep things secure. We do not sell your data. You are in control of your data and can request access, correction, or deletion at any time.

WHO WE ARE AND HOW TO REACH US

iQLY Global Ltd is the Data Controller responsible for the personal data collected and processed through this platform.

Registered Name: iQLY Global Ltd (dba iQLY)

Registered Address: OAU Quarters Maitama, Abuja, Nigeria

Platform: www.iqly.net

Data Protection Contact: privacy@iqly.net

If you have any questions about this Policy or how we handle your personal data, please contact us at the Data Protection Contact address above.

WHAT THIS POLICY COVERS

This Policy applies to all personal data collected, used, or processed by iQLY in connection with:

Your use of www.iqly.net and all iQLY Websites and Services;
Your registration and account management on the platform;
Your participation in iQLY Challenges as a Solver or your posting of Challenges as a Challenger;
Payments, rewards, and transactions conducted through the platform; and
Any communications between you and iQLY.

This Policy does not apply to third-party websites or services that may be linked from our platform. We encourage you to review the privacy policies of any third-party platforms you access through our Websites.

PERSONAL DATA WE COLLECT

We collect personal data through direct interactions with you, through your use of the platform, and in limited cases from third parties. Below is a description of the categories of data we collect.

Solver / Contributor Data
When you register as a Solver or participate in Challenges, we collect:
1. Full name, email address, and phone number;
2. Date of birth and location (city, state, country);
3. Occupation, education, skills, and areas of interest;
4. Challenge submissions, responses, and supporting materials;
5. Profile information and platform activity history; and
6. Identity verification data where required for payment disbursement.
Challenger / Business Data
When you register as a Challenger or post a Challenge, we collect:
1. Legal business name, business registration details, personal identification details and documents (where necessary);
2. Business address, industry, and company size;
3. Contact person details, including name, role, phone number, and email address;
4. Challenge Brief content and associated challenge requirements; and
5. Usage data and platform activity.
Account and Technical Data
When you access the platform, we automatically collect:
1. IP address, device type, browser, and operating system;
2. Pages visited, actions taken, and features used;
3. Log data, session timestamps, and analytics data; and
4. Cookies and similar tracking technology data (see Section 15).
Payment and Transaction Data
In connection with Challenge Rewards and platform fees, we collect:
1. Transaction records and payment confirmations;
2. Financial metadata provided by payment processors (e.g., Paystack); and
3. Bank account details or mobile money information required for reward disbursement.
  
  Note: We do not store full payment card numbers. Payment processing is handled by our authorised payment partners under their own security standards.
Communications Data
We retain records of:
1. Emails and messages you send to us;
2. Support tickets and help requests; and
3. Feedback, survey responses, and platform reviews.
Sensitive Personal Data
We do not intentionally request or require sensitive personal data (such as health information, biometric data, political opinions, or religious beliefs) as part of our standard platform operations. If you voluntarily include such data in a Challenge submission or communication, you consent to its processing for the purposes described in this Policy. We will handle any such data with the additional protections required under applicable law.

HOW WE COLLECT PERSONAL DATA

We collect personal data through the following means:

Directly from you: when you create an account, complete your profile, or contact us;
Automatically: through your use of the platform via cookies, log files, and analytics tools;
From payment processors: transaction confirmations and financial metadata from authorised payment partners;
From identity verification providers: where identity checks are required to disburse rewards; and
From communications: emails, support interactions, and feedback you provide.

Where data is required to provide a specific service, and you decline to provide it, we may be unable to deliver that service.

WHY WE PROCESS YOUR DATA AND OUR LAWFUL BASIS

We process personal data only where we have a valid lawful basis under the Nigeria Data Protection Act 2023. The list below sets out our processing purposes and the corresponding lawful basis for each.

Account creation and management
Enabling you to register, log in, and manage your profile on the platform.
Lawful Basis: Contract
Challenge participation
Matching Solvers to relevant Challenges and enabling submission of Solutions.
Lawful Basis: Contract
Sharing submissions with Challengers
Providing your Challenge submissions to the Challenger for evaluation.
Lawful Basis: Contract / Legitimate Interest
Payment and reward processing
Disbursing Challenge Rewards and collecting platform fees.
Lawful Basis: Contract / Legal Obligation
Platform improvement
Analytics, testing, and optimisation of platform features.
Lawful Basis: Legitimate Interest
Fraud prevention and security
Detecting and preventing abuse, fraud, and unauthorised access.
Lawful Basis: Legitimate Interest / Legal Obligation
User communications
Sending service updates, support responses, and platform notifications.
Lawful Basis: Contract
Marketing and promotions
Sending updates about new features, challenges, and opportunities.
Lawful Basis: Consent
Legal and regulatory compliance
Meeting obligations under Nigerian law and responding to regulatory requests.
Lawful Basis: Legal Obligation

Where we rely on legitimate interest as our lawful basis, we have assessed that our interests are not overridden by your rights and interests. You may contact us to obtain further information about this assessment.

HOW WE USE YOUR PERSONAL DATA

In addition to the purposes described above, we use personal data to:

Operate, maintain, and improve the platform and its features;
Verify your identity and eligibility to host Challenges, participate in Challenges or receive rewards;
Personalise your experience on the platform, including recommending relevant Challenges;
Enable Challengers to review, evaluate, and select winning Solutions;
Comply with applicable laws, regulations, and court orders; and
Protect the rights, property, and safety of iQLY, its Users, and the public.

HOW WE SHARE YOUR PERSONAL DATA

We do not sell your personal data to any third party. We may share your personal data in the following limited circumstances:
With Challengers
When you submit a Solution to a Challenge, the following data may be shared with the relevant Challenger for the purpose of evaluating and selecting a Winning Solution:
1. Your Challenge submission and all associated Deliverables;
2. Relevant profile information you have made available on the platform; and
3. Supporting data necessary for the Challenger’s evaluation process.
  
  By participating in a Challenge, you acknowledge and accept that your submission and relevant profile data will be shared with the Challenger in this manner.
With Service Providers
We share data with trusted third-party service providers who assist us in operating the platform, including hosting providers, analytics platforms, payment processors, and identity verification services. All service providers are bound by data processing agreements and are permitted to use your data only for the purposes we specify.
With Legal and Regulatory Authorities
We may disclose personal data to government authorities, regulators, law enforcement agencies, or courts where we are legally required to do so, or where disclosure is necessary to protect the rights, safety, or property of iQLY or others.
In Connection with Business Transfers
In the event of a merger, acquisition, restructuring, or sale of all or part of iQLY’s business, personal data may be transferred to the acquiring entity as part of that transaction. We will notify affected Users of any such transfer and ensure that appropriate confidentiality obligations are in place.
With Professional Advisers
We may share data with our lawyers, auditors, insurers, and other professional advisers where necessary, subject to strict confidentiality obligations.

AGGREGATED AND ANONYMISED DATA

We may generate aggregated, anonymised data derived from personal data collected on the platform. Once data is fully anonymised and can no longer be linked to any identifiable individual, it is no longer personal data and is not subject to this Policy. We may use such anonymised data freely for analytics, product research, business intelligence, and marketing purposes.

CROSS-BORDER DATA TRANSFERS

iQLY is based in Nigeria and primarily processes data within Nigeria. However, some of our service providers and infrastructure partners may be located outside Nigeria. Where your personal data is transferred outside Nigeria, we take the following steps to ensure it remains protected:

We enter into data transfer agreements incorporating appropriate contractual safeguards;
We assess the data protection standards of the recipient country or organisation; and
We restrict transfers to those that are necessary for the delivery of our services.

By using our platform, you acknowledge that your data may be processed outside Nigeria in accordance with these safeguards.

HOW LONG WE KEEP YOUR DATA

We retain personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by law. Our standard retention periods are as follows:

Account and profile data
Duration of account + up to 2 years after closure.
Reason: Service continuity and dispute resolution
Challenge submissions and Solutions
Duration of account + up to 3 years after closure.
Reason: IP and legal compliance
Verification data
For the duration of the active verification process.
Reason: Regulatory compliance
Transaction and payment records
Up to 7 years.
Reason: Legal and tax obligations under Nigerian law
Communications and support records
Up to 3 years.
Reason: Quality assurance and dispute resolution
Analytics and usage data
Up to 12 months (raw); aggregated data retained indefinitely.
Reason: Platform improvement
Legal compliance records
As required by applicable law.
Reason: Regulatory obligation

Where retention beyond these periods is necessary to comply with a legal obligation, resolve an active dispute, or enforce our agreements, we will retain the relevant data until those purposes are fulfilled. Upon expiry of the applicable retention period, data will be securely deleted or anonymised.

YOUR DATA PROTECTION RIGHTS

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

Right of Access: You may request a copy of the personal data we hold about you and information about how we process it.
Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other lawful basis applies.
Right to Restrict Processing: You may request that we limit our processing of your data in certain circumstances, for example while the accuracy of your data is disputed.
Right to Object: You may object to processing based on legitimate interest or for direct marketing purposes.
Right to Data Portability: You may request that we provide your data in a structured, commonly used, and machine-readable format for transfer to another service.
Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please submit a written request to our Data Protection Contact at privacy@iqly.net. We will respond within the timeframes required under applicable law. Where we are unable to comply with a request, we will explain why.

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe we have handled your personal data in a manner inconsistent with applicable law. The NDPC can be reached at www.ndpc.gov.ng.

DATA SECURITY

We implement and maintain appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

Encryption of data in transit and at rest where applicable;
Role-based access controls limiting data access to authorised personnel only;
Secure hosting infrastructure with continuous monitoring;
Audit logging of access and processing activities; and
Incident response and data breach notification procedures.

While we take all reasonable steps to protect your data, no system is entirely immune to security risks. 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 within 72 hours of becoming aware of the breach, and will notify affected Data Subjects without undue delay, in accordance with the NDPA 2023.

YOUR RESPONSIBILITIES

You play an important role in keeping your personal data secure. You are responsible for:

Maintaining the confidentiality of your account login credentials;
Ensuring that all information you provide to us is accurate and up to date; and
Notifying us immediately at contact@iqly.net if you become aware of any unauthorised access to your account or any security breach relating to your credentials.

iQLY will not be liable for any loss or damage arising from your failure to comply with these responsibilities.

PERSONALISATION AND TARGETED CONTENT

We may use your personal data to personalise your experience on the platform, including recommending Challenges that may be relevant to your profile, skills, and interests. Where we use your data for targeted content or marketing communications, we will do so only where we have a valid lawful basis — either your consent or our legitimate interest in promoting the platform.

You may opt out of personalised marketing communications at any time by following the unsubscribe instructions in any marketing email.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies (such as pixels and local storage) to operate and improve the platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and understand how you use our platform.

Types of Cookies We Use
1. Essential cookies: Required for the platform to function correctly. These cannot be disabled.
2. Analytics cookies: Help us understand how Users interact with the platform so we can improve it.
3. Functional cookies: Remember your preferences and settings to enhance your experience.
4. Marketing cookies: Used to deliver relevant content and track the performance of our communications. These require your consent.
Your Cookie Choices
You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the platform. We will take reasonable steps to respect “Do Not Track” signals from your browser where technically feasible.

A more detailed Cookie Policy is available on request.

CHILDREN

Our platform is not intended for individuals under the age of 18. We do not knowingly collect, process, or store personal data from minors. If you are under 18, you must not use our platform or submit any personal data to us.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data. If you believe a minor has provided us with personal data without appropriate consent, please contact us at privacy@iqly.net.

THIRD-PARTY LINKS AND SERVICES

Our platform may contain links to third-party websites or services that are not operated by iQLY. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party platforms you visit through links on our Websites.

Our platform may also integrate with third-party services such as payment processors. Where such integrations involve the transfer of personal data, we ensure that appropriate data protection agreements are in place.

SUPPLEMENTAL PRIVACY NOTICES

From time to time, we may provide supplemental privacy notices in connection with specific features, promotions, or services offered through the platform. Where a supplemental notice applies, it should be read together with this Policy. In the event of any conflict between a supplemental notice and this Policy, the supplemental notice shall prevail in respect of the specific feature or service to which it relates, unless otherwise indicated.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform features. Where we make material changes, we will notify you through one or more of the following means:

By email to the address registered to your account;
By a prominent notice on www.iqly.net; or
By an in-platform notification.

The date of the most recent update is indicated at the top of this Policy. Your continued use of the platform following notification of any material change constitutes your acceptance of the updated Policy.

CONTACT US

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact us using the details below:

Data Protection Contact: privacy@iqly.net

General Support: contact@iqly.net

Registered Address: OAU Quarters Maitama, FCT Abuja, Nigeria

Website: www.iqly.net

You may also submit a complaint to the Nigeria Data Protection Commission (NDPC) if you are dissatisfied with how we have handled your personal data. The NDPC’s contact information is available at www.ndpc.gov.ng.