Privacy Policy

1. Who We Are and How to Contact Us

Data controller: Vind Limited, incorporated in the Federal Republic of Nigeria.

Registered office: 8 Ajibode Street, Yaba, Lagos, Nigeria.

For privacy questions, data subject requests, or complaints, contact support@sloud.app. You may also contact us at hello@sloud.app or +234 706 964 6891.

If you are a customer purchasing from a merchant using Sloud, that merchant is typically the data controller for your personal information as a buyer. We process certain transaction data on the merchant's instructions as a data processor.

2. Scope of This Policy

This policy applies to personal information processed through Sloudfront, our marketing website, hosted online stores, Sloud Checkout, and consumer-facing products such as Sloud Go where applicable.

This policy does not apply to third-party websites, apps, or services that we do not control, including the privacy practices of licensed financial partners that provide wallets, virtual accounts, and settlement services. Those partners are governed by their own privacy notices.

3. Information We Collect

We collect information you provide directly, information generated through your use of the Services, and information from third parties where permitted by law.

• Account and identity information: name, email address, phone number, account credentials (passwords are stored in hashed form), and business name.
• Business and KYC information: business address, registration details, owner identification documents, and other verification data required for compliance.
• Financial and transaction information: payment amounts, transaction references, Sloud Checkout activity, wallet activity, payout details, and fee records. Wallet and settlement services are provided through licensed financial partners.
• Catalog and commerce data: products, dishes, services, prices, inventory, orders, customer records you upload, and store configuration.
• Communications: support requests, feedback, and correspondence with our team.
• Technical and usage data: IP address, browser type, device identifiers, pages visited, session data, and analytics events.
• Cookies and similar technologies: as described in Section 9 below.

4. How We Use Your Information

We use personal information to operate, secure, and improve the Services, including:

• Creating and managing your Sloudfront account and hosted storefront.
• Processing payments, orders, and wallet transactions through our platform and licensed partners.
• Conducting identity verification (KYC), sanctions screening, and fraud prevention.
• Providing customer support and responding to inquiries.
• Sending service-related communications, including security alerts and account notices.
• Sending marketing communications where you have opted in. You may withdraw consent or unsubscribe at any time.
• Analysing usage to improve performance, features, and user experience.
• Complying with legal obligations and enforcing our Terms.

5. Legal Bases for Processing

Under the Nigeria Data Protection Act 2023 (NDPA) and other applicable laws, we process personal information where one or more of the following applies:

Consent: where you have given clear consent for a specific purpose, such as marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

Contract: where processing is necessary to provide the Services you request or to take steps at your request before entering a contract.

Legal obligation: where processing is required to comply with law, regulation, court order, or requests from competent authorities, including KYC and anti-money laundering requirements.

Legitimate interests: where necessary for purposes such as fraud prevention, network security, service improvement, and business administration, balanced against your rights.

6. How We Share Information

We do not sell your personal information. We may share information in the following circumstances:

• Licensed financial partners: to provide wallets, virtual accounts, payment collection, and payouts. Their use of information is governed by their privacy policies and regulatory obligations.
• Service providers and data processors: cloud hosting, analytics, email delivery, customer support tools, and security vendors bound by confidentiality and data processing obligations.
• Merchants and customers: where necessary to complete a transaction you initiate (for example, order fulfilment or payment confirmation).
• Legal and regulatory authorities: when required by law, court order, or to protect rights, safety, and integrity of the Services.
• Business transfers: in connection with a merger, acquisition, or sale of assets, with notice where required by law.

7. Financial Services and Partner Disclosure

Business wallets, virtual accounts, payouts, and certain payment services available through Sloud are provided by licensed financial partners. Vind Limited provides the technology platform and does not directly hold customer funds in connection with those regulated services.

When you use wallet or payment features, your information may be shared with our partners to the extent necessary to provide those services and meet regulatory requirements. You may also be required to accept those partners' terms and privacy notices.

8. Data Retention

We retain personal information only for as long as necessary for the purposes described in this policy, including:

• Active account data: for as long as your account remains open and as needed to provide the Services.
• KYC and financial records: for periods required by applicable financial, tax, and anti-money laundering laws, which may extend beyond account closure.
• Support and communications: for as long as needed to resolve enquiries and maintain appropriate business records.
• Marketing preferences: until you opt out or withdraw consent, and for a reasonable period thereafter to honour your request.
• Technical logs and analytics: for limited periods appropriate to security monitoring and service improvement, unless a longer period is required by law.

When data is no longer required, we delete or anonymise it in accordance with our retention policies and applicable law.

9. Cookies and Analytics

We use cookies and similar technologies to maintain sessions, remember preferences, measure traffic, and improve the Services. Essential cookies are used to operate the Services. Non-essential analytics cookies are used only where permitted by applicable law and, where required, your consent.

You can control cookies through your browser settings. Disabling cookies may limit certain features.

We use Google Analytics and similar tools to understand how visitors interact with our website. These providers may process data outside Nigeria under their own privacy policies.

10. Security

We implement administrative, technical, and organisational measures designed to protect personal information, including encryption in transit, access controls, and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials and transaction PIN.

If we become aware of a personal data breach likely to affect your rights, we will notify you and the Nigeria Data Protection Commission (NDPC) where required by the NDPA and applicable guidance.

11. Your Rights

Under the NDPA and other applicable law, you may have the right to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of personal information, subject to legal retention requirements;
• request restriction of processing in certain circumstances;
• object to processing based on legitimate interests, where applicable;
• request data portability where technically feasible;
• withdraw consent at any time where processing is based on consent.

To exercise these rights, contact us at support@sloud.app with sufficient information to verify your identity. We will respond within the timeframe required by applicable law, typically within one month unless an extension is permitted.

You may lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe our processing violates applicable law.

12. Automated Decision-Making

We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on you without appropriate safeguards. We may use automated tools for fraud detection and risk scoring, but meaningful decisions involving your account are subject to human review where required by law.

13. International Transfers

Your information may be processed in Nigeria and other countries where we or our service providers operate, including countries that may not provide the same level of data protection as Nigeria.

Where we transfer personal information internationally, we implement appropriate safeguards as required by the NDPA, which may include contractual protections, adequacy assessments, or other mechanisms recognised by applicable law.

14. Children's Privacy

The Services are not directed to individuals under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will take steps to delete it.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the revised policy on this page and update the "Last updated" date. Material changes may be communicated by email or in-app notice where appropriate. Continued use of the Services after changes take effect constitutes acceptance of the updated policy where permitted by law.

16. Contact Us

Vind Limited

Registered office: 8 Ajibode Street, Yaba, Lagos, Nigeria

Support: support@sloud.app · +234 706 964 6891

General enquiries: hello@sloud.app · +234 706 964 6891