Privacy Policy

_Working draft — under review with counsel. Last updated on publish._

This Privacy Policy explains how Dream Intrepid Ltd. ("UGCOrigin", "we") collects, uses and protects your personal data when you use UGCOrigin. We aim to comply with the Nigeria Data Protection Act (NDPA) 2023 and good international practice.

1. Data we collect

• Account data: name, email, phone number, username, role (brand/creator), password (hashed by our auth provider).
• Profile data: bio, location, niches, rate, photos, logos, social handles, portfolio and showcase media.
• Verification data: identity, bank and business details you submit for verification and payouts.
• Transaction data: offers, gigs, escrow funding, payouts and ledger entries.
• Communications: messages, attachments and support tickets.
• Usage data: device, log, and (only after consent) analytics data.

2. How we use it

To operate the marketplace; verify identity; hold escrow and pay out; match brands and creators; power search and recommendations; prevent fraud and abuse; provide support; send transactional notifications; and, with your consent, analytics and product updates.

3. Legal bases

We process data to perform our contract with you, to comply with legal obligations (e.g. KYC/AML and tax), for our legitimate interests in running a safe marketplace, and on your consent (e.g. analytics cookies and marketing email).

4. Privacy between users

To protect everyone, we show a creator's name as "First L." and hide social handles and phone numbers publicly. Full name and contact details are revealed to the other party only once a deal is funded. Messages are scanned to prevent sharing contact details off-platform before a contract exists.

5. Sharing

We share data with service providers who help us run the Platform — payments (Paystack), media hosting (Cloudinary), database/auth (Supabase), email (our email provider) and, where enabled, identity verification and analytics. They process data on our instructions. We may disclose data where required by law.

6. Payments

Card and bank details are handled by our payment processor (Paystack); we do not store full card numbers. Payout bank details are stored to the extent needed to pay you.

7. Cookies and analytics

Essential cookies keep the Platform working. Analytics and marketing tools load only after you consent via the cookie banner, and only where their IDs are configured. You can change your choice at any time.

8. Retention

We keep personal data for as long as your account is active and as needed for legal, tax, accounting and dispute purposes, then delete or anonymise it.

9. Your rights

Subject to law, you may access, correct, delete, restrict or port your data, and object to certain processing. Contact privacy@ugcorigin.com. You may also complain to the Nigeria Data Protection Commission.

10. Security

We use encryption in transit, access controls, row-level security and audited admin actions. No system is perfectly secure; tell us immediately if you suspect an issue.

11. Children

UGCOrigin is not for anyone under 18.

12. Changes

We will notify material changes in-app or by email.

13. Contact

privacy@ugcorigin.com — Dream Intrepid Ltd.