Privacy Policy

Last updated: [DATE — to be inserted upon counsel approval]

1. Who We Are

Adaka ("we", "us") operates a platform connecting Clients with independent Lawyers for legal services in Nigeria. This policy explains what personal data we collect, why we collect it, and your rights under the Nigeria Data Protection Act 2023 (NDPA).

2. Data We Collect

• Account data: name, phone number, email address
• Identity data: ID type, ID number, ID expiry date, scanned ID document, signature (uploaded or drawn) — collected for company registration, will, and affidavit services
• Company registration data: company name, share capital, registered address, director/shareholder/secretary details (name, date of birth, gender, nationality, occupation, phone, email, addresses)
• Financial data: payment records processed via Paystack (Adaka does not directly store your card or bank account numbers — these are handled by Paystack)
• Lawyer-specific data: Supreme Court Enrollment Number, practising certificate, Call to Bar certificate, bank account details for payout
• Communications: messages exchanged with your matched Lawyer through the platform (automatically filtered to block sharing of external contact details)
• Usage data: login timestamps, service request history, ratings given/received

3. Why We Collect It

• To verify your identity and the identity of Lawyers on the platform
• To facilitate company registration, will drafting, affidavit, and case-matching services
• To process payments and hold funds in escrow
• To match you with a suitable, verified Lawyer
• To communicate with you about your service requests
• To comply with legal obligations (e.g. CAC filing requirements, NDPA record-keeping)

4. Who We Share Data With

• Your matched Lawyer — receives the information necessary to perform your requested service (e.g. company registration details, uploaded documents)
• Paystack — for payment processing
• Termii (or successor SMS provider) — for OTP/account verification messages
• Resend (or successor email provider) — for account and case notifications
• CAC, court registries, or other government bodies — where necessary to complete your requested filing
• The Nigeria Data Protection Commission or law enforcement — where required by law

We do not sell your personal data to third parties.

5. Data Retention

We retain your personal data for as long as necessary to provide our services and comply with applicable legal obligations. Specific retention periods are set out in our internal data retention schedule and will be updated here following review by our Data Protection Officer.

6. Data Security

Uploaded documents (ID scans, signatures, certificates) are access-controlled: only the Client who owns a service request, their matched Lawyer, and platform administrators can access them. We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction.

7. Your Rights Under the NDPA

You have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data, subject to our legal retention obligations
• Object to certain processing
• Lodge a complaint with the Nigeria Data Protection Commission

To exercise these rights, contact us at the address in Section 11 below.

8. International Data Transfers

Where any personal data is transferred to or processed in a country outside Nigeria, we take steps to ensure an adequate level of protection in accordance with the NDPA and any relevant NDPC guidance. Further details will be provided here following review by our Data Protection Officer.

9. Children's Privacy

Adaka's services are not directed at individuals under 18. We do not knowingly collect data from minors.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to users via the platform or email before they take effect.

11. Contact

Data Protection Officer: [Name/Email — to be assigned]
Registered business address: [To be inserted once Adaka's entity registration is complete]

This document is a structural starting draft prepared to accelerate legal/DPO review. It has not been reviewed or approved by a licensed Nigerian lawyer or qualified Data Protection Officer and must not be published or relied upon until such review is complete.