Privacy Policy

Last updated: May 28, 2025

Alafialink places the highest importance on protecting your privacy and securing your personal information. This privacy policy outlines how we collect, use, share, and protect your data when you use our e-commerce platform, Alafialink (hereinafter referred to as the “Platform”). By accessing or using the Platform, you agree to the practices described in this policy, in accordance with applicable laws and regulations in Nigeria and other African economic zones where we operate.

Information We Collect

We collect different types of information when you use Alafialink:

1. Personally Identifiable Information (PII):
2. This includes the information you provide directly when creating your account, placing orders, posting ads, or communicating with us. This information may include your name, email address, phone number, mailing address, date of birth, payment information (in compliance with PCI DSS security standards), national identification number (NIN) or any other identification required by Nigerian regulations, and any other information you choose to share.
3. Demographic and Profile Information:
4. We may collect information about your geographic location (country, city), your buying and selling preferences, your interests, and other information you provide in your user profile.
5. Transaction Information:
6. We record details of your transactions on the Platform, including products purchased or sold, prices, shipping and payment information, as well as your order and ad history.
7. Technical and Usage Information:
8. We automatically collect certain information when you interact with the Platform, such as your IP address, device type, operating system, web browser, pages you view, actions you take, and log data. We may use cookies, web beacons, and other tracking technologies to collect this information.
9. Communication Information:
10. We retain records of your communications with other users via the Platform and with our customer service.
11. Public information:
12. Information you choose to make public on the Platform, such as ratings and comments, will be visible to other users.

How we use your information

We use the collected information for the following purposes:

1. Providing and improving the Platform:
2. Managing your account, facilitating transactions between buyers and sellers, personalizing your user experience, providing customer support, and enhancing the functionality and user-friendliness of the Platform.
3. Processing transactions:
4. Verifying your identity (including concerning Nigerian regulatory requirements), processing payments, shipping products, and managing returns and refunds.
5. Communicating with you:
6. Sending you notifications related to your account, transactions, Platform updates, promotional offers (with your consent, in accordance with Nigerian regulations), and responding to your support requests.
7. Ensuring security and preventing fraud:
8. Monitoring suspicious activities, verifying identities, preventing fraud and money laundering, and enforcing our terms of use in compliance with Nigerian laws and international standards.
9. Personalizing content and advertising:
10. Presenting you with products, services, and advertisements that may interest you based on your purchase and browsing history, subject to your consent where required by Nigerian law.
11. Analyzing and understanding the use of the Platform:
12. Conducting data analyses to improve our services, develop new features, and understand trends in the African market.
13. Complying with legal and regulatory obligations:
14. Responding to requests from competent authorities and adhering to applicable laws in Nigeria and the various African economic zones where we operate, including the Nigeria Data Protection Regulation (NDPR) and regulations related to anti-money laundering.

Sharing Your Information

We may share your information with the following categories of recipients:

1. Other users of the Platform:
2. Your contact information and transaction details are shared with buyers and sellers involved in your transactions. Public information such as ratings and comments is visible to all users.
3. Third-party service providers:
4. We engage third-party companies to provide services on our behalf, such as payment processing, web hosting, data analysis, marketing (subject to your consent in accordance with the NDPR), logistics, and customer support. These providers have access to your information only to the extent necessary to perform their services and are contractually obligated to protect it in accordance with this policy and applicable laws, including the NDPR. We will ensure that these transfers are carried out in accordance with NDPR requirements regarding data transfers outside Nigeria.
5. Legal and regulatory authorities:
6. We may disclose your information to competent authorities in Nigeria and other jurisdictions if required by law, in connection with legal proceedings, to prevent fraud or illegal activities, or to protect our rights and the safety of our users. This includes reporting obligations under anti-money laundering laws.
7. Business partners:
8. With your explicit consent (in accordance with the NDPR), we may share your information with business partners to offer you special deals or complementary services.
9. Business transfers:
10. In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity. We will notify you of any changes in ownership or control of your information in accordance with the NDPR.

Cross-border data transfers and African economic zones

Since Alafialink operates in Africa and aims to connect buyers and sellers from different countries and African economic zones (e.g., ECOWAS, SADC, COMESA, etc.), your information may be transferred and processed in countries other than your country of residence, potentially including outside Nigeria. These countries may have data protection laws different from those in Nigeria.

In accordance with the Nigeria Data Protection Regulation (NDPR), we are committed to implementing adequate protective measures to ensure the security of your information during these transfers. These measures may include standard contractual clauses approved by the competent authorities, binding corporate rules, or other legally recognized transfer mechanisms by the NDPR. We will carefully assess the risks associated with each transfer and take necessary steps to ensure an appropriate level of protection.

Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Measures

Alafialink is committed to complying with the anti-money laundering and counter-terrorism financing regulations in effect in Nigeria (Money Laundering (Prohibition) Act) and in other African economic zones where we operate. To this end, we implement the following measures:

1. Customer Identity Verification (KYC):
2. We require both buyers and sellers to provide valid information and documents to verify their identity when creating their account and/or during significant transactions. This includes submitting official identification (such as NIN, passport, driver's license), proof of address, and other relevant information in accordance with Nigerian regulatory requirements.
3. If you are a representative or employee of a buyer or seller, or an independent buyer or seller, depending on your use of the applicable functions and/or services on the platform, we will ask you to provide:
4. Contact details, such as the name of the contact/legal representative, address, business/contact phone number, business and contact/legal representative email address, job title and department, credentials, and phone bills of the contact/legal representative.
5. Account information, such as your username and password, gender, and account settings.
6. Business information, such as identity information, tax registration, and/or related information about your business, including your business name, registration number and date, official company website, type of business and industry, business registration details, and information about your business license, proof of business operation, including lease agreement, title deed, utility bills, etc.
7. Transaction information, such as transaction statements, billing/delivery address for your order recipient, past payments and orders, as well as other details about products you provided or purchased via the Platform.
8. Payment information, such as bank account numbers, credit/debit card numbers, credit/debit card holders, expiration dates and security codes, and tracking information for checks or money orders, bank statements, and account opening pages.
9. In order to facilitate your use of the services available on the Platform (including on optimized websites and/or mobile applications), we may request access to content stored on your devices, including, but not limited to, photos, videos, calendars, and/or other files, which you can provide to us. If you use the communication tools available on the Platform (notably in the case of voice communication), we may need access to your camera and/or microphone.
10. From time to time, we may also collect information about existing and potential users during or in connection with trade shows, industry events, and/or other functions, including names, addresses, phone numbers, fax numbers, and email addresses of representatives.
11. Customer Due Diligence (CDD):
12. We implement due diligence procedures to assess and monitor the risk of money laundering and terrorist financing associated with our clients. This may include enhanced due diligence for higher-risk clients.
13. Transaction Monitoring:
14. We implement both automated and manual systems to monitor transactions and identify suspicious activities or those potentially linked to money laundering or terrorist financing. This includes reviewing transaction volumes, unusual activity patterns, transactions involving high-risk jurisdictions identified by Nigerian and international authorities, and transactions involving politically exposed persons (PEPs). We also require buyers and sellers, under our general terms and conditions, to cooperate with any investigation into suspicious or fraudulent transactions.
15. Business partners:
16. With your explicit consent (in accordance with the NDPR), we may share your information with business partners to offer you special deals or complementary services.
17. Record Keeping:
18. We maintain detailed records of all transactions and customer identification information for the periods required under the Money Laundering (Prohibition) Act and other relevant regulations in Nigeria.
19. Staff Training:
20. We regularly train our staff on AML/CFT policies and procedures to ensure they can identify and report suspicious activities.
21. Cooperation with Authorities:
22. We fully cooperate with the NFIU, law enforcement agencies, and other Nigerian and international regulatory bodies in their efforts to prevent and combat money laundering and terrorist financing.
23. Internal Policies and Procedures:
24. We have established clear internal policies and procedures to prevent and detect money laundering and terrorist financing, in line with international best practices and Nigerian regulations, including the implementation of transaction limits and reporting thresholds.
25. By using Alafialink, you agree to provide accurate and truthful information and to cooperate with us in the context of our AML/CFT procedures. We may request additional information or documents to comply with these regulations.

IP Access Restrictions and Sanctions Compliance

1. Purpose
2. In accordance with applicable international sanctions regimes, including those established by the OFAC (U.S. Office of Foreign Assets Control), the UN, and the EU, as well as Nigerian laws and regulations on Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT), AlafiaLink is committed to preventing access to its e-commerce platform for users located in or operating from sanctioned jurisdictions.
3. Policy Statement
4. AlafiaLink prohibits access to its services for individuals, businesses, or other entities located in jurisdictions subject to economic or trade sanctions. This restriction includes, but is not limited to, countries and territories designated by OFAC sanctions programs, the United Nations Security Council, the European Union, and those identified by the Nigerian Financial Intelligence Unit (NFIU) in the context of anti-money laundering and terrorist financing.
5. Implementation Measures
6. IP Geolocation Blocking
7. The AlafiaLink platform uses geolocation services such as Cloudflare and AWS WAF to automatically detect and block IP addresses originating from sanctioned countries or territories. This restriction is enforced at the network firewall level and/or through application layer logic.
8. Payment Gateway Controls
9. Our payment gateway partners must implement geolocation and sanctions verification controls for all processed transactions. These controls include IP address filtering, BIN (Bank Identification Number) matching, and origin country validation. They must also comply with AML requirements from the Central Bank of Nigeria (CBN).
10. Restricted Account Registration
11. During user onboarding on AlafiaLink, we collect and validate information regarding the country of origin and contact details of new users. Any registration attempt from sanctioned territories will be automatically rejected and access to the platform will be denied.
12. Ongoing Monitoring and Revisions
13. Regular audits are conducted to detect and investigate any access anomalies, such as login attempts from restricted IP addresses or geographic inconsistencies. Any suspicious behavior will be flagged for compliance assessment, and necessary corrective measures will be taken.
14. Policy Disclosure and Enforcement
15. Our Terms of Service and Privacy Policy clearly state that access to our platform is strictly prohibited from regions under sanctions. Accounts found to be in violation of this policy will be immediately suspended or terminated.
16. Roles and Responsibilities
17. The Compliance Officer at AlafiaLink is responsible for ensuring that these measures are effectively implemented, maintained, and updated in response to changes in the global sanctions landscape and Nigerian regulations. The technical team supports this process by managing IP blocking systems and triggering alerts in case of anomalies.
18. Reviews and Updates
19. This section will be regularly reviewed and updated to ensure compliance with applicable laws, including those specific to Nigeria, and to adapt our practices to global regulatory requirements while maintaining the integrity of our e-commerce platform.

Security of Your Information

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction, in accordance with the requirements of Article 13 of the NDPR. These measures include encryption of sensitive data (at rest and in transit), the use of robust firewalls, implementation of strict physical and logical access controls, regular security audits, and staff training on best data security practices.

While we strive to protect your information, no method of transmission over the Internet or electronic storage is completely secure. Therefore, in accordance with Article 14 of the NDPR, in the event of a data breach likely to result in a high risk to your rights and freedoms, we will notify you as soon as possible, as well as the competent authority (Nigeria Data Protection Bureau - NDPB).

Your Data Protection Rights (In Accordance with the NDPR)

As a data subject in Nigeria, you have the following rights regarding your personal information:

1. Right of Access:
2. You have the right to request access to your personal information that we hold, as well as information about how it is processed.
3. Right to Rectification:
4. You have the right to request the correction of any inaccurate or incomplete personal data we hold about you.
5. Right to Erasure (Right to be Forgotten):
6. You have the right to request the deletion of your personal data in certain circumstances, particularly when the data is no longer necessary for the purposes for which it was collected or processed, or if you withdraw your consent (where processing is based on consent).
7. Right to Restrict Processing:
8. You have the right to request the restriction of processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.
9. Right to Data Portability:
10. You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller without hindrance from us.
11. Right to Object:
12. You have the right to object to the processing of your personal data in certain situations, particularly for direct marketing purposes.
13. Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
14. The right to lodge a complaint with the Nigeria Data Protection Bureau (NDPB) if you believe your data protection rights have been violated.
15. To exercise these rights, please contact us using the details provided in the "Contact Us" section below. We will respond to your request in accordance with the NDPR and other applicable Nigerian laws. We may ask you to verify your identity before responding to your request.

Service providers

We may employ third-party companies and individuals for the following reasons => To facilitate our Service; To provide the Service on our behalf; To perform Service-related services; or To assist us in analyzing how our Service is used. We want to inform users of this Service that these third parties have access to their personal information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Security

We value your trust in providing us your personal information, thus we strive to use commercially acceptable means of protecting it. But remember that no method of transmission over the Internet or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Links to other sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our data practices, legal and regulatory developments in Nigeria and other jurisdictions, or changes to our services. We will inform you of any material changes by posting the new policy on the Platform and updating the "last updated" date. In some cases, we may also notify you directly by email or through a notice on the Platform. We encourage you to regularly review this policy to stay informed about our privacy practices. By continuing to use the Platform after changes are posted, you accept the revised privacy policy.

Contact Us

If you have any questions, concerns, or requests regarding this privacy policy or the processing of your personal information, please contact us at:

Data Protection Officer (DPO)

Alafialink

contact@sudequilibre.com

12 Rev Ogunbiyi Street, Arizona Court, Ikeja GRA, Lagos, Nigeria.

+234099065954155

You also have the right to directly contact the Nigeria Data Protection Bureau (NDPB) for any questions or complaints regarding the protection of your personal data.

We are committed to responding to your requests promptly and in accordance with the Nigeria Data Protection Regulation (NDPR) and other applicable laws.