THEBLOW360ENTERPRISE
Making Life Easy — With a Click of Your Phone
PRIVACY POLICY
Data Protection Notice in Compliance with the Nigeria Data Protection Act, 2023
Warri, Delta State, Nigeria
Effective Date: 26 February 2026
Last Updated: 26 February 2026
PRIVACY POLICY
This Privacy Policy describes how Theblow360enterprise ("We", "Us", or "Our") collects, processes, uses, stores, and protects personal data belonging to Users of the Theblow360 Application, in compliance with the Nigeria Data Protection Act, 2023 (NDPA), its General Application and Implementation Directive (GAID) 2025, and all applicable data protection laws of the Federal Republic of Nigeria.
By using the Theblow360 App, you consent to the collection and use of your personal data as described in this Privacy Policy.
1. WHO WE ARE (DATA CONTROLLER)
Theblow360enterprise is the Data Controller responsible for your personal data. Our contact details are:
Name: Theblow360enterprise
Address: Warri, Delta State, Nigeria
Data Protection Contact: support@theblow360.com
We are registered with the Nigeria Data Protection Commission (NDPC) as a Data Controller in accordance with the provisions of the NDPA, 2023.
2. PERSONAL DATA WE COLLECT
We collect the following categories of personal data when you use our App:
2.1 Registration and Identity Data
• Full name, date of birth, gender
• Email address, phone number
• Government-issued identification (where required for verification)
2.2 Transaction and Financial Data
• Payment card details (processed through encrypted third-party payment processors)
• Bank account details (where applicable)
• Transaction history, order records, and billing information
2.3 Location Data
• Real-time GPS location (for delivery and logistics services)
• Pickup and drop-off addresses
2.4 Device and Technical Data
• IP address, device identifier, browser type, operating system
• App usage data, crash reports, and diagnostic information
2.5 Communications Data
• Messages exchanged between Users and Vendors via the in-App messaging feature
• Customer support communications
3. LEGAL BASIS FOR PROCESSING
We process your personal data on the following legal bases as provided under Section 25 of the NDPA, 2023:
6. Contractual Necessity: Processing is necessary for the performance of our contract with you (i.e., providing you access to the App and facilitating service transactions).
7. Consent: Where you have freely, specifically, and unambiguously consented to processing — for example, consenting to receive marketing communications.
8. Legal Obligation: Where processing is necessary to comply with applicable Nigerian laws and regulations, including tax and anti-money laundering obligations.
9. Legitimate Interests: For purposes of fraud prevention, App security, and service improvement, where such interests are not overridden by your fundamental rights and freedoms.
4. HOW WE USE YOUR PERSONAL DATA
We use your personal data for the following purposes:
• To create and manage your account on the App;
• To facilitate and process service requests between you and Vendors;
• To process payments and maintain financial records;
• To provide customer support and resolve disputes;
• To verify your identity and prevent fraud;
• To send transactional notifications, updates, and service-related communications;
• To comply with applicable laws, court orders, or regulatory requirements;
• To improve the App's features, performance, and user experience;
• To send promotional or marketing communications (where you have consented).
5. DATA SHARING AND DISCLOSURE
5.1 We do not sell, rent, or trade your personal data to third parties for their marketing purposes.
5.2 We may share your personal data with:
• Vendors: To fulfill your service requests (e.g., sharing your delivery address with a logistics Vendor).
• Payment Processors: Third-party payment service providers operating under their own privacy policies and applicable CBN regulations, for the purpose of processing your payments.
• Technology and Hosting Partners: Service providers who assist in operating the App, subject to binding confidentiality and data processing agreements.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or valid governmental authority under Nigerian law.
• Professional Advisors: Legal, accounting, or other professional advisors under strict confidentiality obligations.
5.3 Any third party with whom we share your data is contractually required to protect your data and use it only for the specified purpose.
6. CROSS-BORDER DATA TRANSFERS
Where your personal data is transferred outside Nigeria, we shall ensure that such transfers are made only to countries that provide an adequate level of data protection, or subject to appropriate safeguards such as standard contractual clauses, as permitted under Section 41 of the NDPA, 2023. You will be informed of such transfers where required by law.
7. DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes set out in this Privacy Policy, and in accordance with our legal and regulatory obligations under Nigerian law. Upon expiry of the applicable retention period, we shall securely delete or anonymize your personal data. Account data is generally retained for a period of six (6) years following account closure, to comply with applicable financial and tax record-keeping requirements.
8. COOKIES AND TRACKING TECHNOLOGIES
The Theblow360 App uses cookies and similar tracking technologies in accordance with Article 19 of the NDPC's General Application and Implementation Directive (GAID), 2025. You will be presented with a cookie consent interface when you first access the App. You may withdraw your consent to non-essential cookies at any time through your account settings. Essential cookies required for the core functioning of the App shall operate without requiring consent.
9. YOUR DATA SUBJECT RIGHTS
In accordance with Section 34 of the NDPA, 2023, you have the following rights with respect to your personal data:
10. Right to Information: To be informed about how your personal data is processed.
11. Right of Access: To obtain a copy of the personal data we hold about you.
12. Right to Rectification: To request correction of inaccurate or incomplete data.
13. Right to Erasure: To request deletion of your personal data where no longer necessary or where consent is withdrawn.
14. Right to Data Portability: To receive your personal data in a structured, commonly used electronic format.
15. Right to Object: To object to the processing of your data for direct marketing or legitimate interest purposes.
16. Right to Restrict Processing: To request restriction of processing in certain circumstances.
To exercise any of these rights, please submit a written request to privacy@theblow360.com. We shall respond within thirty (30) days of receipt of your request. We shall not charge a fee for handling your request unless it is manifestly unfounded or excessive.
10. DATA SECURITY
We implement appropriate technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, in accordance with Section 39 of the NDPA, 2023. These measures include end-to-end encryption of sensitive data, secure server hosting, role-based access controls, and regular security audits. In the event of a data breach, we shall notify the NDPC within seventy-two (72) hours and affected Users without undue delay, where required by law.
11. CHILDREN'S PRIVACY
The Theblow360 App is not intended for use by children under the age of eighteen (18). We do not knowingly collect personal data from minors. If we become aware that personal data of a minor has been collected without verifiable parental consent, we shall take steps to delete such data promptly, in compliance with the Child Rights Act, 2003 and the NDPA, 2023.
12. COMPLAINTS TO THE REGULATOR
If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at:
Nigeria Data Protection Commission
Website: www.ndpc.gov.ng
Email: info@ndpc.gov.ng
13. UPDATES TO THIS POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or the App's features. We will notify you of material changes via email or in-App notification. The effective date at the top of this Policy indicates when it was last revised.
