Privacy Policy

1. Who We Are

Reineur Limited with registration number RC. 8151941 having its business office at Plot 76A Fiditi Avenue, Off Ordinance Road, Trans Amadi Industrial Layout, Port Harcourt, Rivers State, Nigeria (hereinafter referred to as "we", "our", or "us") is the data controller responsible for your personal data collected through the Service.

Data Protection Compliance Organisation: Reineur Limited.

Data Protection Officer Email: privacy@reineur.com

2. Personal Data We Collect

2.1. Information You Provide

2.1.1. Account information, name, username, email address, phone number, password, date of birth, profile photo, academic information, career information

2.1.2. Profile content, bio, posts, photos, videos, comments, messages

2.1.3. Communications inclusive of messages sent through the app, support requests

2.2. Information Collected Automatically

2.2.1. Device information inclusive of device type, operating system, unique device identifiers, mobile network information

2.2.2. Usage data inclusive of features used, time spent, interactions, content viewed, search queries

2.2.3. Location data inclusive of approximate or precise location, if you grant permission

2.2.4. Log data inclusive of IP address, access times, app crashes, referring URLs

2.3. Information from Third Parties

2.3.1. Information from social media platforms if you connect or log in through them

2.3.2. Information from advertising partners and analytic providers

2.3.3. Information from other users (for example, if someone tags you or uploads a contact list that includes you)

2.4. Sensitive Personal Data

We do not collect sensitive personal data including data revealing racial or ethnic origin, religious or similar beliefs, health status, sexual life, genetic or biometric data, political opinions, trade union membership, and criminal records.

3. Lawful Basis for Processing

We process your personal data on one or more of the following lawful bases recognised under NDPA:

3.1. Consent: you have given clear, specific, and informed consent

3.2. Contractual necessity: processing is necessary to provide the service you requested

3.3. Legal obligation: processing is required to comply with a legal obligation

3.4. Vital interest: processing is required for the protection of someone's life

3.5. Public Interest / official function (where applicable)

3.6. Legitimate interest: processing is necessary for our legitimate interest (for example, security, fraud prevention, service improvement), provided this does not override your fundamental rights and freedoms. Where we rely on Legitimate Interest, we carry out a Legitimate Interest Assessment as contemplated by NDPC guidelines.

4. How We Use Your Information

We use collected information to:

4.1. Create and maintain your account

4.2. Provide, operate, and improve the Service

4.3. Personalise content, recommendations, and advertisements (ads)

4.4. Enable communication between users

4.5. Send notifications, updates, and marketing communications (where permitted)

4.6. Monitor and analyse usage trends

4.7. Detect, prevent, and address fraud, abuse, and security issues

4.8. Comply with legal and regulatory obligations, including those owed to the NDPC

5. How We Share Your Information

We may share information with:

5.1. Other users based on your privacy settings and the nature of the platform (for example, public posts, followers)

5.2. Service providers (data processors) who perform services on our behalf under a written processing agreement (hosting, analytics, customer support, payment processing)

5.3. Advertising partners, in aggregated or de-identified form, or as permitted by your consent/settings

5.4. Regulators and legal authorities, including the NDPC, when required by law or to respond to legal process

5.5. Business transferees, in connection with a merger, acquisition, or sale of assets

We do not sell your personal data to third parties for money.

6. Cross-Border Transfer of Personal Data

6.1. Where we transfer your personal data outside Nigeria (for example, to cloud hosting or analytics providers located abroad), we ensure the transfer is made:

6.1.1. To a country or sector subject to the provision of the law; or

6.1.2. Subject to appropriate safeguards, such as standard contractual clauses or a Cross-Boarder Data Transfer Instrument recognised under the law; or

6.1.3. With your explicitly consent, or under another exception permitted by the law

7. Your Rights as a Data Subject

7.1 The following are your rights under the law:

7.1.1 Be informed about how your personal data is processed

7.1.2. Access a copy of your personal data in a commonly used electronic format

7.1.3. Request rectification of inaccurate or incomplete personal data

7.1.4. Request erasure of your personal data in certain circumstances

7.1.5. Request restriction of processing in certain circumstances

7.1.6. Receive your data in a structured, commonly used, machine readable format

7.1.7. Object to processing based on legitimate interest or public interest grounds

7.1.8. Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal

7.1.9. Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, and to request human review

7.1.10. Seek legal redress: lodge a complaint with the NDPC or redress through the courts

7.2. You can typically manage privacy settings, notification preferences, and account deletion directly within Reineur.

To exercise any of the above rights contact us at privacy@reineur.com

We will respond to your request within 30 days of receiving it. Where a request is complex or requires additional time to process, we may extend the response period where permitted by applicable law. In such circumstances, we will inform you of the reason for the delay and, where applicable, the expected timeframe for completing the request.

8. Children's Data

The Service is not directed at or intended for persons under eighteen (18) years of age. If we learn we have collected a child's personal data, we will delete it promptly.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal or regulatory obligations, resolve disputes, and enforce agreements, consistent with the storage limitation principle under the law.

10. Data Security

In line with the NDPA's requirement for appropriate technical and organisational measures, we implement safeguards such as security reviews to protect your personal data against unauthorised access, loss, or disclosure. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. 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 NDPC within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay where the breach is likely to result in a high risk to their rights, in accordance with the law.

12. Cookies and Tracking Technologies

We and our partners use cookies and Software Development Kits (SDKs), and similar technologies to recognise your device, remember preferences, analyse usage, and deliver relevant advertising. You can manage preferences through your device settings or our in-app controls. See our Cookie Policy for details.

13. Third-Party Links and Services

The Service may contain links to or integration with third-party services. We are not responsible for the privacy practices of those third parties. Review their policies separately.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes via the app or email and update the "Last Updated" date above. Continued use of the Service after changes constitutes acceptance.

15. Contact Us and Complaints

If you have questions, requests, or complaints regarding the Privacy Policy or our handling of your personal data, contact us at:

Reineur Limited

Email: privacy@reineur.com

Address: Plot 76A Fiditi Avenue, Off Ordinance Road, Trans Amadi Industrial Layout, Port Harcourt, Rivers State, Nigeria.

If you are not satisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.