Privacy Policy

Last updated: 26 October 2026

This policy explains what personal data OwoDaily Limited (RC 2009981), Plot A37E, Ikate Ancient City, Lekki, Lagos 106104, Nigeria ("OwoDaily", "we", "us") collects when you visit owodaily.com or use the OwoDaily web application (the "Platform"), why we collect it, who we share it with, how long we keep it, and the rights you have. It is written to meet section 27 of the Nigeria Data Protection Act 2023 ("NDPA") and the Nigeria Data Protection Commission's General Application and Implementation Directive 2025 ("GAID").

OwoDaily Limited is the data controller for the personal data described here.

1. Our Data Protection Officer

Our Data Protection Officer can be reached at [email protected] (subject "Data Protection") or by post at the address above. Contact the DPO for any question about this policy or to exercise your rights.

2. Who this policy covers

Visitors to the website, Customers on the free plan, Members, OwoDaily Plus members, Partners, Campaign Owners, Creators, Affiliates and anyone who contacts our support team. You must be 18 or older to hold an Account. We do not knowingly collect data from anyone under 18; if we learn we have done so, we close the Account and delete the data except where the law requires us to keep it.

3. What we collect

Data you give us

• Account details: full name, email address, phone number, date of birth, sex, country and state, username, profile photo.
• Payout details: bank name, account number and account name (Nigeria) or PayPal email (outside Nigeria). The account name is verified against the bank record.
• Identity documents: a government-issued ID, only when we need to verify your age or identity, restore access to a locked Account, or where a payment partner or the law requires it. We do not collect your BVN or NIN.
• Tax identification number, where you give it so that tax deducted from your payouts can be credited to you.
• Campaign data: proof screenshots, links, videos, social media usernames and other content you submit for Campaigns; the Campaigns you post; your referral links and the sign-ups, sales and claims attributed to them.
• Communications: emails, support tickets, complaints, appeals, Village forum posts and comments.
• Payment data: records of memberships, Credits and Campaigns you paid for. Card details are entered directly with our payment processors and never stored by us.

Data we collect automatically

• Device and connection data: IP address, browser type, operating system, device identifiers, time zone, approximate location derived from IP, referring and exit pages, pages viewed, dates and times, clickstream data.
• Cookies and similar technologies, as described in section 9.
• Tracking data from social platforms where you submit Campaign content (for example public view counts and engagement on a TikTok video you submitted), collected through those platforms' public interfaces.

Data we receive from others

• Confirmation of payments from our payment processors.
• Bank account name verification results from licensed verification providers.
• Reports from Campaign Owners about submissions, and from other users about conduct.

4. Why we use your data and the lawful basis for each purpose

Where we rely on legitimate interest we have carried out a legitimate interest assessment and concluded that the processing is one you would reasonably expect and that does not override your rights. You may ask for a summary of that assessment.

5. Automated decisions

Our systems automatically count views and engagement on Campaign content, flag engagement patterns that look artificial, and flag duplicate or suspicious submissions. A flag does not by itself reject a submission or close an Account; a member of our review team makes that decision. You can ask for a human review of any decision within 7 days under clause 10.5 of the Terms of Use.

6. Who we share your data with

We share personal data only with:

• Payment processors and banks (currently [Paystack / Flutterwave / Korapay] and our settlement banks) to take payments and send payouts, and PayPal for payouts outside Nigeria.
• Bank verification providers to confirm that a payout account is in your name.
• Campaign Owners, who see the username, proof and content you submit to their Campaign so that they can review it. They may use that data only for the Campaign and must not contact you outside the Platform.
• Partners, who see the number of claims and sales attributed to their listings but not Customers' personal details unless the Customer registers with the Partner directly.
• Other users, who see your username, profile photo and any content you post publicly in the Village forum.
• Service providers who host the Platform, send our emails, store files and provide customer support tools, under written contracts that require them to protect your data and use it only on our instructions (NDPA s.29).
• Analytics and advertising platforms (currently Google Analytics, Meta and TikTok measurement tools) to understand how people find and use the Platform and to measure our own advertising. These tools use cookies or pixels; see section 9. We do not sell your personal data.
• Professional advisers, auditors, regulators and law enforcement, where the law requires or permits it.
• A buyer or successor of our business, on notice to you.

7. International transfers

Some of our service providers (for example cloud hosting, email delivery, analytics and PayPal) store or process data outside Nigeria. Where we transfer personal data outside Nigeria we do so only to a country the Nigeria Data Protection Commission recognises as providing adequate protection, or under contractual safeguards that meet sections 41 to 43 of the NDPA, or where you have given informed consent or the transfer is necessary to perform our contract with you (for example a PayPal payout). We keep a record of the basis for each transfer and carry out a transfer impact assessment where the GAID requires it.

8. How long we keep your data

9. Cookies

We use cookies and similar technologies in three groups:

• Necessary cookies, which keep you logged in, remember your settings and protect against fraud. These are always on.
• Analytics cookies, which tell us how the Platform is used (for example Google Analytics).
• Advertising cookies and pixels, which measure our own advertising on Meta, TikTok and Google.

When you first visit, a banner lets you accept or reject analytics and advertising cookies before any non-necessary cookie is set. You can change your choice at any time through the "Cookie settings" link in the footer or your browser settings. Rejecting cookies does not stop you using the Platform.

10. How we protect your data

We use encryption in transit, access controls, logging, regular backups and staff confidentiality obligations. Bank details and identity documents are stored encrypted with restricted access. No system is perfectly secure; if a breach occurs that is likely to put your rights at risk, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of it and will tell you without undue delay where the risk to you is high.

11. Your rights

Under sections 34 to 38 of the NDPA you have the right to:

• ask for a copy of the personal data we hold about you;
• have inaccurate data corrected, which you can mostly do yourself on your dashboard;
• have your data erased, or its processing restricted, where the law allows;
• withdraw consent to marketing at any time, using the unsubscribe link or your Account settings;
• object to processing based on legitimate interest, including profiling for marketing;
• not be subject to a decision based solely on automated processing that has a legal or similarly significant effect on you, and to ask for human review;
• receive your data in a portable format;
• complain to the Nigeria Data Protection Commission (ndpc.gov.ng).

To exercise a right, email [email protected] with the subject "Data request". We will respond within 30 days and may ask you to verify your identity first. Some data cannot be erased while your Account is open or while the law requires us to keep it, for example payout and tax records.

12. Links to other sites

The Platform links to social media platforms, Partner websites and payment processors that we do not control. Their privacy policies, not this one, govern what they collect.

13. Changes to this policy

We will give at least 14 days' written notice of material changes by email and in-app. The version date at the top tells you when it last changed.

14. Contact

OwoDaily Limited, Plot A37E, Ikate Ancient City, Lekki, Lagos 106104, Nigeria Data Protection Officer and general enquiries: [email protected] (use the subject "Data Protection" for data matters)