1. Preamble
This Privacy Policy "Policy" governs the collection, processing, and use of personal data by Votesphere ("We," "Us," or "Our"), a digital voting platform. This Policy is drafted in compliance with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR) 2019, and relevant provisions of the Cybercrimes (Prohibition, Prevention, etc.) Act 2015.
By accessing or using the Votesphere platform (the "Service"), you ("User," "Voter," or "Organizer") consent to the data practices described in this Policy.
2. Interpretation and Definitions
- Data Controller: The entity that determines the purposes and means of processing personal data. (Note: The Event Organizer is the Data Controller for Voter Data).
- Data Processor: The entity that processes data on behalf of the Controller. (Note: Votesphere is the Data Processor for Voter Data).
- Personal Data: Any information relating to an identified or identifiable natural person.
- Organizer: The entity or individual creating an event on Votesphere.
3. Data We Collect
3.1. As a Data Controller (Data We Own)
We collect the following to manage your account and our business relationship with you:
- Identity Data: Name, email address, phone number (for 2FA/OTP).
- Financial Data: Transaction history for monetized elections (processed via third-party gateways. We do not store PAN/CVV).
- Technical Data: Login timestamps, IP addresses, and device type.
3.2. As a Data Processor (Data We Process for Organizers)
When an Organizer uploads a voter register or candidates, we process:
- Voter Identifiers: Matriculation numbers, Student IDs, or Email addresses.
- Election Data: Candidate names, images, and manifestos.
- Vote Cast: The encrypted record of the choice made by a Voter.
4. Automated Data Collection (Anti-Rigging)
To maintain the integrity of events (our "Legitimate Interest" under Section 25(1)(b)(v) of the NDPA 2023), we automatically collect:
- Device Fingerprinting: Information about your browser, operating system, and screen resolution to identify unique devices.
- Geolocation Data: Approximate location derived from IP addresses to detect suspicious "vote farming" from a single location.
- Session Metadata: Time spent on the voting page and interaction patterns.
5. Lawful Basis of Processing
| Purpose | Data Type | Lawful Basis (NDPA 2023) |
|---|---|---|
| Service Provision | Account Data | Contract |
| Voter Authentication | Voter IDs | Public Interest / Contract |
| Fraud Prevention | Device/IP Data | Legitimate Interest |
6. Data Retention
- Election Audit Trail: Voter logs and results are retained for six (6) months post-election to allow for dispute resolution. After this period, data is anonymized or deleted.
- Account Information: Retained for the lifetime of the account plus two (2) years.
- Financial Records: Retained for five (5) years as required by Nigerian financial regulations.
7. Your Rights
Under the NDPA 2023, you have the right to request access, rectification, erasure, or withdrawal of consent.
8. Limitation of Liability
To the fullest extent permitted by law, Votesphere serves solely as a technology infrastructure provider. We are not liable for the legitimacy of the election, the eligibility of the voters provided by the Organizer, or the ultimate disputes arising from election results.
9. Contact Us
If you have questions regarding this Privacy Policy or wish to exercise your data rights, please contact our Data Protection Officer (DPO):
- Email: privacy@votesphere.com
- Address: Votesphere HQ, Imo State, Nigeria.
