Privacy Policy

1. About This Policy

This Privacy Policy describes how Steady Technologies Limited ("Steady.ng", "we", "us", or "our") collects, uses, stores, and discloses information about you when you use the Steady.ng website and related services (collectively, the "Platform").

By accessing or using our Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue use of the Platform.

2. Information We Collect

2.1 Information You Provide Directly

• Account registration data: name, email address, phone number, and password when you create an account.
• Vendor application data: business name, CAC registration number, business address, product categories, and contact information submitted through our vendor application form.
• Contact form submissions: name, email, and message content when you contact us.
• Newsletter subscription: email address.
• Community contributions: fuel prices, cooking gas prices, and location submissions you voluntarily submit to our community data tools.
• Token purchase data: meter number, DisCo selection, and transaction amount for electricity token purchases.
• Delivery requests: delivery address, contact details, and fuel order specifications.

2.2 Information Collected Automatically

• Usage data: pages visited, search queries, tools used, time on page, click patterns, and navigation paths.
• Device data: browser type and version, operating system, screen resolution, device type, and IP address.
• Log data: server access logs, error logs, and request timestamps retained for security and debugging purposes.
• Cookies and similar technologies: session identifiers, CSRF tokens, and preference cookies. See Section 5 for details.

2.3 Information from Third Parties

• Payment processors: we receive transaction confirmation and reference numbers from BuyPower and Flutterwave but do not store card numbers or bank account details.
• WhatsApp interaction tracking: when you click a vendor's WhatsApp link, we record the click event to improve vendor analytics.

3. How We Use Your Information

3.1 Service Delivery

• Creating and managing your account
• Processing electricity token purchases and fuel delivery orders
• Displaying vendor listings and product information relevant to your queries
• Providing personalised energy spending insights where you have opted in
• Operating the cooking gas locator and fuel price tracker using community data

3.2 Communications

• Sending transaction confirmations and receipts (electricity tokens, delivery bookings)
• Responding to your support and contact enquiries
• Sending our weekly Nigerian Energy Price Index newsletter (subscribers only; unsubscribe at any time)
• Notifying you of changes to our policies or platform features

3.3 Platform Improvement and Analytics

• Analysing aggregate usage patterns to improve tools and content
• Identifying and resolving technical errors
• Understanding search behaviour to improve product discovery

3.4 Legal and Safety

• Detecting and preventing fraud, fake listings, and platform abuse
• Complying with applicable Nigerian laws and court orders
• Protecting the rights and safety of Steady users and the public

4. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We share data only in the following limited circumstances:

4.1 Vendors

When you click a vendor's WhatsApp button or submit an inquiry, we share your contact details with that specific vendor solely to facilitate your enquiry. You agree to this sharing by initiating contact with a vendor.

4.2 Service Providers

We use the following third-party processors who handle data on our behalf under data processing agreements:

• BuyPower / Flutterwave: electricity token payments and fuel delivery billing
• Google Fonts: font delivery (your IP address is transmitted to Google)
• Hosting and infrastructure providers: for server infrastructure in compliance with Nigerian data residency guidelines

4.3 Legal Obligations

We may disclose information if required by applicable Nigerian law, court order, or competent regulatory authority, or where necessary to protect the safety of our users.

4.4 Business Transfers

In the event of a merger, acquisition, or asset sale, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

5. Cookies and Tracking

We use essential session cookies and CSRF protection cookies necessary for the Platform to function. We also use preference cookies to remember your location and display settings. We do not use advertising or cross-site tracking cookies.

For full details, see our Cookie Policy.

6. Data Retention

We retain personal data for as long as necessary to provide our services and meet legal obligations:

• Active accounts: data retained while your account is active
• After account closure: core account data deleted within 24 months (2 years) of account closure or inactivity
• Transaction records: electricity and delivery transaction records retained for 7 years for financial compliance purposes
• Community contributions: fuel and gas price reports are anonymised after 90 days
• Server logs: retained for 90 days for security purposes

7. Your Rights

Under the Nigeria Data Protection Regulation (NDPR) and applicable Nigerian law, you have the following rights regarding your personal data:

• Right of access: request a copy of the personal data we hold about you
• Right to rectification: request correction of inaccurate or incomplete data
• Right to erasure: request deletion of your account and associated data (subject to legal retention requirements)
• Right to restrict processing: object to or restrict how we use your data in certain circumstances
• Right to data portability: receive your data in a structured, machine-readable format
• Right to withdraw consent: unsubscribe from marketing communications at any time

To exercise any of these rights, email [email protected] with subject line "Data Rights Request". We will respond within 30 days.

8. Security

We implement technical and organisational measures proportionate to the risk of processing, including: encrypted connections (HTTPS/TLS) for all data transmission, hashed and salted password storage, access controls limiting employee access to personal data, and regular security reviews.

No internet transmission is completely secure. In the event of a data breach affecting your rights and freedoms, we will notify you and the Nigeria Data Protection Bureau (NDPB) within 72 hours of becoming aware, as required by the NDPR.

9. Children's Privacy

Steady.ng is not directed at children under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, contact us immediately at [email protected] and we will delete it.

10. NDPR Compliance Statement

Steady Technologies Limited processes personal data in accordance with the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act 2023. We have appointed a Data Protection Officer (DPO) responsible for overseeing compliance. Our data processing activities are based on one or more lawful grounds: contract performance, legitimate interests, legal obligation, or consent.

Complaints regarding our data handling may be submitted to the Nigeria Data Protection Bureau (NDPB) at ndpb.gov.ng.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email (for registered users) or a prominent notice on the Platform at least 14 days before taking effect. The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of the Platform after the effective date constitutes acceptance of the revised policy.

12. Contact Us

For all privacy-related enquiries, data rights requests, or concerns:

• Email: [email protected]
• General contact: Contact form
• Address: Steady Technologies Limited, Lagos, Nigeria