Moradera Privacy Policy

1. Introduction

This Privacy Policy explains how Moradera ("Moradera", "we", "us" or "our") collects, uses, stores, discloses and otherwise processes personal data when you visit moradera.com, create an account, register or verify a device, use our seller services, submit a report, request an ownership transfer, contact our support team, or otherwise interact with our services.

We aim to comply with the Nigeria Data Protection Act 2023 (NDPA), applicable regulations and guidance, and other relevant laws of the Federal Republic of Nigeria. References to a law include amendments or successor requirements that apply to our processing activities.

This policy applies to personal data processed through our website and related Moradera services. A separate notice may apply where we clearly provide one for a particular service or transaction.

For the purposes of data-protection law, the identity of the person or legal entity operating Moradera and determining the purposes of processing must be stated accurately in the final published version of this policy. Contact us using the details at the end of this policy if you have questions about the operator responsible for your information.

2. Information we collect

The information we collect depends on how you use Moradera. We may collect the following categories where relevant to the service you request.

A. Account and contact information

• Your name, email address, telephone number and other contact details you provide.
• Account credentials and account-related information, such as authentication identifiers and account status.
• Profile information, including a profile photograph if you choose to upload one.
• Messages, enquiries, complaints and communications sent to our support team.

B. Identity, seller and verification information

• Identity information and identification documents submitted for applicable identity, ownership or seller-verification processes.
• Business name, business contact details and seller onboarding information.
• Information provided to establish authority to register, sell or transfer a device.
• Documents or evidence submitted to support a verification request, dispute, recovery report or ownership claim.

C. Device and registry information

• Device identifiers such as IMEI numbers, serial numbers and other identifying details applicable to the device.
• Device make, model, category, registration details and verification status.
• Purchase evidence, receipts, ownership records and relevant transfer history.
• Reports or records relating to lost, stolen, recovered or disputed devices.
• Information about a device's listing, registration or transaction on Moradera.

D. Payment and transaction information

• Transaction references, payment status, amounts, fees and relevant payment timestamps.
• Subscription and billing records for applicable seller services.
• Information needed to reconcile a payment or investigate a payment-related complaint.
• Limited information received from a payment provider to confirm or administer a transaction.

Payment providers may process payment credentials or financial details through their own systems. We do not claim to collect or store full payment-card details unless a particular payment flow expressly requires it.

E. Technical and usage information

• IP address, browser type, operating system and technical request information.
• Pages visited, actions performed, dates and times of access, and error or diagnostic information where recorded.
• Cookie, session and similar technical data used by the website, where applicable.
• Approximate location or location information you choose to provide or permit, where a feature requires it.
• Security logs and information reasonably needed to detect misuse, protect accounts or investigate incidents.

F. Information from other sources

Where lawful and necessary, we may receive relevant information from payment providers, verification partners, sellers, buyers, authorised representatives, or public and official sources. We take reasonable steps to consider the source and reliability of information used for verification or dispute review.

Please do not submit another person's personal information or identity documents unless you are authorised to do so and the submission is appropriate for the service or report.

3. Why we use your information

Depending on the service involved, we may process personal data to:

• Create and administer accounts and provide requested Moradera services.
• Register devices and maintain relevant device, ownership and transaction records.
• Respond to device-verification requests and display the results that the service is designed to provide.
• Review seller applications, identity documents, purchase evidence and verification submissions.
• Process or reconcile subscriptions, transaction fees and other payments through relevant payment arrangements.
• Record and review ownership-transfer requests, disputes, lost or stolen reports and recovery claims.
• Communicate service updates, verification outcomes, security alerts and responses to enquiries.
• Prevent fraud, impersonation, unauthorised access, misuse of the registry and other unlawful activity.
• Maintain system security, troubleshoot errors, improve usability and assess service performance.
• Meet applicable legal, regulatory, accounting and record-keeping obligations.
• Establish, exercise or defend legal claims and respond to valid requests from competent authorities.
• Send promotional communications where permitted by law and, where required, with your consent.

We do not treat the fact that information is available to us as permission to use it for unrelated purposes. Any further use must have an appropriate lawful basis and be consistent with applicable data-protection requirements.

4. Our lawful basis for processing

We process personal data only where an appropriate legal basis applies. Depending on the circumstances, this may include:

• Contract: processing needed to provide a service you request or take steps at your request before entering into a contract.
• Legal obligation: processing needed to comply with applicable laws, lawful orders or regulatory requirements.
• Consent: processing for which we request your freely given, specific, informed and unambiguous consent where consent is the appropriate legal basis.
• Legitimate interests: processing needed for a legitimate interest, where applicable law permits it and the relevant interests and rights have been considered.
• Vital interests or public interest: processing where the relevant legal conditions for these bases are met.

The lawful basis depends on the particular purpose and information involved. We will not rely on consent as the basis for every activity where another lawful basis is more appropriate.

Where information is required to fulfil a contract, comply with a legal obligation or complete a requested verification, refusing to provide it may mean that we cannot provide the relevant feature or complete the requested process.

5. Device registry, verification and public information

Moradera helps users check device records and supports device registration, seller verification, ownership records, transfer processes and reports relating to lost, stolen or recovered devices.

Information that may be visible to the public

Depending on the feature and its configuration, a public device check may show selected device identifiers, device details, a verification result, a registry status or other information specifically intended for public checking.

Information intended to remain private

Public verification results are not intended to expose private identity documents, private contact details, residential addresses, authentication credentials, private account records or internal file-storage locations. Access to these records should be restricted according to the user's role, the purpose of processing and applicable law.

Limits of a verification result

A Moradera result reflects the records and checks available to the service at the time of the request. A result that shows no adverse record does not, by itself, guarantee that a device is genuine, has never been stolen, is free from all claims or restrictions, or is legally owned by the person presenting it. Registry information may be incomplete, delayed, disputed or inaccurate.

Users should independently assess a device and the seller, and report suspected errors or unauthorised disclosures to Moradera. We may review submitted evidence and correct or update records where appropriate.

6. Cookies, sessions and technical information

Moradera may use browser sessions, cookies and similar technologies where needed to operate the website, maintain authentication, protect accounts, remember preferences or support functionality.

If analytics, performance monitoring or other non-essential tracking technologies are used, the relevant information and choices should be disclosed through an appropriate notice or preference mechanism where required by law.

You can manage or delete cookies through your browser settings. Blocking certain cookies or session technologies may affect login, security or other website features.

The exact cookies and third-party technologies used may change as the website evolves. We should keep this section aligned with the technologies actually deployed on Moradera.

7. When we may share your information

We do not treat personal information as information that can be disclosed freely. We may share relevant information in the following circumstances, subject to applicable law and appropriate safeguards.

Service providers

We may use hosting, infrastructure, authentication, communication, payment, security or other service providers to operate Moradera. They may process information on our behalf or independently for their own services, depending on their role and the applicable arrangement.

Buyers, sellers and registry users

We may display information intended for a particular public verification feature or share relevant transaction or transfer information with the parties involved where needed to operate the service. We should limit such disclosures to information that is appropriate for the feature and transaction.

Law enforcement and public authorities

We may disclose relevant information to the Nigeria Police Force or another competent authority where required by law, in response to a valid lawful request, or where another lawful basis permits disclosure for fraud prevention, investigation, protection of rights or public interest.

Where legally permitted and appropriate, we will consider the scope and validity of a request and disclose only information reasonably relevant to it. We do not state that every user record is routinely sent to the police.

Business changes and legal claims

Information may be disclosed as part of a proposed or completed business transfer, restructuring or similar transaction, subject to applicable legal requirements and safeguards. We may also share information where reasonably necessary to establish, exercise or defend legal claims.

When information is shared with an independent organisation, that organisation may have its own legal responsibilities. This does not remove any responsibilities that Moradera has under applicable law for its own processing, selection of service providers or disclosures.

8. International transfers of personal data

Some service providers or technical infrastructure used to deliver online services may be located outside Nigeria. Where personal data is transferred internationally, Moradera will take the steps required by applicable data-protection law, which may include assessing the transfer and implementing an appropriate legal safeguard.

The countries and providers involved depend on the services actually used. Contact us if you need further information about an applicable transfer of your personal data.

9. How long we retain personal data

We keep personal data only for as long as reasonably necessary for the purposes described in this policy, taking account of the nature of the information, the service provided, security needs and applicable legal obligations.

Retention periods may differ for:

• Account and profile information.
• Device registration, ownership and transfer records.
• Identity documents and verification evidence.
• Payment, subscription, accounting and audit records.
• Lost, stolen, recovery and dispute reports.
• Security logs, support messages and legal records.

When personal data is no longer needed, we will take appropriate steps to delete it, anonymise it or otherwise dispose of it securely, subject to applicable legal requirements and legitimate record-keeping needs.

We do not promise that every record can be erased immediately on request. For example, some records may need to be retained to comply with the law, resolve a dispute, maintain the integrity of ownership history or protect against fraud.

10. Data security

Moradera takes reasonable technical and organisational steps designed to protect personal data against unauthorised access, disclosure, alteration, loss or destruction. Appropriate measures depend on the sensitivity of the information and the risks associated with its processing.

Measures may include, where implemented and appropriate:

• Access restrictions and role-based permissions.
• Secure authentication and account-protection controls.
• Secure transmission and storage practices.
• System monitoring, updates and security reviews.
• Procedures for handling suspected security incidents.

No internet-based service or storage system can be guaranteed to be completely secure. We cannot promise that a security incident will never occur, but we will respond to incidents in accordance with applicable legal requirements.

You should protect your login details, use a secure device and notify us promptly if you suspect that your account has been accessed without permission.

11. Your privacy rights

Subject to applicable law and any lawful limitations, you may have the right to:

• Be informed: receive clear information about how your personal data is processed.
• Access: ask whether we process your personal data and request access to it.
• Rectification: request correction of inaccurate or incomplete information.
• Deletion: request erasure of personal data where the applicable legal conditions are met.
• Restriction: request that certain processing be restricted in circumstances recognised by law.
• Object: object to certain processing where the law gives you that right, including relevant direct marketing.
• Data portability: request a copy in a portable format where the right applies.
• Withdraw consent: withdraw consent where consent is the lawful basis for the relevant processing.
• Challenge certain decisions: exercise rights relating to qualifying automated decisions, where applicable.
• Complain: lodge a complaint with the Nigeria Data Protection Commission or another competent authority, as appropriate.

How to exercise your rights

Send a request to support@moradera.com with the subject "Privacy Rights Request". Explain what you would like us to do and, where possible, identify the account or record involved.

We may ask for reasonable information to verify your identity or authority to make the request. Please do not send passwords or unnecessary sensitive information in an email.

We will handle requests within the period required by applicable law. Some requests may be refused, limited or partially fulfilled where a lawful exception applies. Where required, we will explain the outcome and any available complaint options.

A request to delete an account does not automatically require deletion of every record where retention is lawfully necessary. We will assess the information concerned and the legal basis for any continued retention.

12. Consent, withdrawal and marketing

Where we rely on consent, we will request it in a manner appropriate to the processing involved. Merely visiting the website does not automatically mean that you have consented to every possible use of your personal data.

If you withdraw consent, this will not make processing that lawfully took place before withdrawal unlawful. We may continue to process relevant information where another lawful basis applies, subject to your rights under applicable law.

If we send promotional emails, you may opt out using the unsubscribe option provided in the message, where available, or by contacting support@moradera.com. We may still send non-promotional messages needed to administer your account, provide a service, address security concerns or meet legal obligations.

13. Third-party websites and services

Moradera may link to third-party websites or use third-party services. Those organisations may collect and process information under their own privacy policies and terms.

We encourage you to read the privacy information provided by a third party before submitting personal information directly to it. This policy does not replace a third party's privacy policy, and we are not responsible for processing that falls solely under another organisation's control.

14. Changes to this Privacy Policy

We may update this policy to reflect changes in our services, data practices, technology or legal obligations.

When changes are made, we will update the date shown at the top of this page. Where a change materially affects your rights or where applicable law requires it, we will provide an appropriate notice or seek consent where necessary.

We encourage you to review this page periodically. A change to this policy does not remove rights that you have under applicable law.

15. Contact Moradera about privacy

If you have questions about this policy, want to exercise your data-protection rights, or wish to report a concern about the handling of your personal data, contact us using the details below.