Privacy Policy

Version 4.0 | Effective: May 2026 | Compliant with NDPA 2023

1. Introduction

SummerIsland Systems ("we", "us", "our") operates What's Up Trivia, a skill-based knowledge competition platform. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023.

2. Data Controller

Company: SummerIsland Systems
Email: hello@whatsuptrivia.com.ng
Location: Abuja, Nigeria

3. Information We Collect

3.1 Information You Provide

Phone number (WhatsApp/Telegram)
Display name/username
State/location (optional)
Bank account details (for reward redemption)
KYC documents (government ID, selfie) when required

3.2 Information Collected Automatically

Device identifiers and fingerprints
Platform information (WhatsApp/Telegram)
Round session data and response times
Transaction and payment records

4. How We Use Your Information

Provide and maintain the competition platform
Process payments and reward redemptions
Verify identity and prevent platform abuse
Enforce our Terms of Service
Send platform-related notifications
Improve our services
Comply with legal obligations

5. Legal Basis for Processing (NDPA 2023)

Contract Performance: To provide the platform service
Consent: For marketing communications
Legitimate Interest: For platform integrity and abuse prevention
Legal Obligation: For tax and regulatory requirements

6. Data Sharing

We may share your information with:

Payment Processors: For secure payment processing
WhatsApp/Telegram: As messaging platforms
Cloud Providers: For data storage
Law Enforcement: When legally required

We do NOT sell your personal data to third parties.

7. Data Retention

Data Type	Retention Period
Account Data	Duration of account + 2 years
Round History	2 years
Transaction Records	7 years (tax compliance)
KYC Documents	5 years after verification
Round Audit Logs	7 days

8. Your Rights (NDPA 2023)

You have the right to:

Access: Request a copy of your personal data
Rectification: Correct inaccurate data
Erasure: Request deletion (subject to legal requirements)
Restriction: Limit how we process your data
Portability: Receive your data in a portable format
Objection: Object to certain processing activities

To exercise these rights, email: hello@whatsuptrivia.com.ng

9. Data Security

We implement appropriate security measures including encryption, secure payment processing, access controls, and regular security assessments.

10. Children's Privacy

What’s Up Trivia is available to users 13 and above. We do not knowingly collect data from children under 13.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify users of significant changes via our messaging platforms.

12. Contact Us

Privacy Inquiries: hello@whatsuptrivia.com.ng
Phone: +2349160975128