1. Who is responsible
VISMARKS NIGERIA LIMITED, a company in formation in the Federal Republic of Nigeria (name reserved with the Corporate Affairs Commission, approval code 178096328517, 9 September 2026; incorporation pending), represented pending incorporation by its founder Ayanfe Mary-Grace Adesipe, with a planned affiliate in the United Arab Emirates, is the data controller for the Platform. Privacy requests: privacy@vismarks.com. Our Data Protection Officer can be reached at the same address.
2. What we collect and why
- Account data — email, name, password (hashed), role, company, phone, profile and Stage details. Basis: contract.
- Identity verification (sellers) — government ID, selfie, BVN/NIN or business registration, proof of address, processed with our verification and payment partners. Basis: legal obligation (KYC/AML) and contract.
- Order, enquiry and dispute data — products bought/sold, amounts, delivery addresses, messages between buyer and seller (including replies sent by email), dispute evidence. Basis: contract and legal obligations.
- Payout data (sellers) — bank/mobile-money details passed to payment partners. We never store full card numbers. Basis: contract.
- Content you publish — listings, photos, videos, music, live streams, replays, games, comments, chat. Basis: contract and legitimate interest in running and promoting the Platform.
- Usage and device data — pages viewed, features used, approximate location from IP, device/browser, crash and performance logs, views and impressions on listings and Stages. Basis: legitimate interest (security, improvement) and consent for analytics/marketing cookies.
- Communications — support emails, reports, appeals, legal acceptances (version, time, IP, device). Basis: contract, legal obligation and legitimate interest.
3. Stage, live shows and recordings
When you host or join a live show we process your camera/microphone streams, chat and participation in real time through our live-video provider. Shows may be recorded; hosts choose whether replays are public or private. If you appear on camera or in chat you may be visible in replays and highlights. Audience presence counts and reactions are shown to hosts. Tips, tickets and memberships are processed as order data.
4. AI processing
We use AI models (via trusted providers) to write listing text from your photos, recommend content, translate, caption, detect policy violations and generate Official Stage content. Your photos and text are sent to the provider for processing and are not used by them to train public models under our agreements. You can always edit or reject AI output. Decisions with legal or similarly significant effects (e.g. account closure) are reviewed by a human on request.
6. Sellers as independent controllers
Sellers receive your name, delivery address, phone number and messages to fulfil your order. They act as independent controllers for that data and are bound by the Seller Agreement to use it only for the order, protect it and not market to you without consent. Report misuse to privacy@vismarks.com.
7. International transfers
Our providers may process data outside Nigeria and outside the EU/UK (for example in the EU, US or UAE). We rely on adequacy decisions, standard contractual clauses or equivalent safeguards under the NDPA and GDPR, and on providers' certifications. A copy of safeguards is available on request.
8. How long we keep it
- Account data: while your account is active and up to 90 days after deletion for recovery and fraud checks.
- Order, payment, KYC and tax records: 6 years (accounting, AML and tax law), with personal identifiers minimised where possible.
- Content: until you delete it, plus backups for up to 30 days; promotional clips and other users' shares as described in the Stage & Creator Terms.
- Live replays marked private: until you delete them. Chat logs: 12 months.
- Legal acceptance records, dispute files and enforcement history: 6 years.
- Analytics: aggregated after 13 months.
9. Your rights (NDPA/NDPR & GDPR)
- Access & portability — download your data in one click from Account → Privacy & data.
- Erasure — delete your account from the same page. Some records are kept where the law requires (section 8).
- Rectification, restriction and objection — update details in your account or email us; object to processing based on legitimate interest, including profiling for recommendations.
- Withdraw consent — anytime, for marketing emails, push notifications, analytics or marketing cookies, without affecting earlier processing.
- Automated decisions — request human review of significant automated decisions.
- Complain — to the Nigeria Data Protection Commission (ndpc.gov.ng) or, for EU/UK residents, your local supervisory authority. We would appreciate the chance to help first.
We answer requests within 30 days (extendable where the law allows) and may ask you to verify your identity.
10. Security
Encryption in transit, hashed passwords, two-factor authentication, role-based access, audit logs, encrypted backups and vetted providers. No system is perfectly secure; if a breach affects you we will notify you and the regulator as the law requires (72 hours under the NDPA/GDPR).
11. Children
The Platform is for users aged 13+; under-18s need guardian consent and cannot sell, host or receive money. We do not knowingly collect data from children under 13; if you believe we have, email privacy@vismarks.com and we will delete it.
12. Marketing and notifications
Transactional emails (orders, enquiries, security, legal updates, weekly seller proof summaries) are part of the service. Marketing emails and push notifications are sent only with your consent and always include one-click unsubscribe or an off switch in your account. Replies to our emails go to info@vismarks.com or, for enquiries, straight into your VISMARKS conversation.
14. Changes
We will notify you of material changes by email or in-app at least 30 days before they take effect. The version and effective date are shown at the top.
