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Privacy policy

What we collect when you use Hoolam, why we need it, who sees it, how long we keep it, and the rights you have under the Nigeria Data Protection Act 2023.

Contents
  1. 01Who is responsible for your data
  2. 02What we collect
  3. 03Why we use it, and on what legal basis
  4. 04Who sees your data
  5. 05Data stored outside Nigeria
  6. 06How long we keep it
  7. 07Your rights
  8. 08How we protect it
  9. 09Under 18s
  10. 10This website
  11. 11Changes to this policy

In short

  • We collect only what a safe deal needs: your WhatsApp number and name, your deals, and the bank account you get paid or refunded into.
  • We never sell your details, and we don’t use them for advertising.
  • The other person in a deal sees what they need to trust you. Your public page is shown only if you turn it on.
  • We keep deal and payment records for 5 years because Nigerian law requires it. Everything else you can ask us to delete.
  • You can ask to see, correct or delete your data at any time: hello@hoolam.com.

Who is responsible for your data

HOOLAM DIGITAL PLATFORM LTD (RC 9919417), of 8, Delta Bakery Road, Woji, Rivers State, Nigeria, decides how your personal data is used for Hoolam. In data protection law we are the “data controller”. For anything about your data, including your rights below, write to hello@hoolam.com with “Privacy” in the subject, or message us on WhatsApp on +234 703 679 9976.

What we collect

WhatWhere it comes fromExamples
Your WhatsApp detailsWhatsApp, when you message usYour phone number and WhatsApp profile name
Your profileYouBusiness name, city
Your dealsYou and the other person in the dealItem description, price, photos of the item, delivery date, proof of sending, every step of the deal and when it happened
Bank detailsYou, checked with your bankBank name, account number and account name, so we can pay or refund you
PaymentsOur payment partnerAmounts, payment references, times, whether a transfer succeeded
Messages with usYouYour messages and choices in the chat, problem reports, ratings and comments, messages to our team
Your public page (if you turn it on)YouYour photo and links to your Instagram, TikTok, Facebook or website
Technical recordsOur systemsWhether our messages were delivered, and server logs (which include IP addresses) when you open a Hoolam link or page

If someone types your number to start a deal with you, we receive your number from them and send you a single message about that deal. If it wasn’t meant for you, tap “Not me” and we won’t message you about deals from others again.

We don’t collect your BVN, NIN or card details. If we ever need to check your identity, for example before larger deals, we will tell you first what we need and why.

Why we use it, and on what legal basis

WhyLegal basis (NDPA 2023, section 25)
To run your deals: show summaries, take payment, hold money, pay sellers, refund buyers, and message you about each stepPerforming our contract with you
To decide problems between a buyer and a sellerPerforming our contract with you
To keep records of deals and payments, and to answer lawful requests from authoritiesComplying with the law, including the Money Laundering (Prevention and Prohibition) Act 2022 and tax law
To show your trust record to people about to deal with you, and to spot and stop fraud and misuseOur legitimate interest, and yours, in safe trading
To show your public seller page, photo and linksYour consent: you turn it on, and you can turn it off at any time
To fix problems and improve HoolamOur legitimate interest in a working service

We don’t send marketing messages, we don’t use your data for advertising, and we don’t make decisions about you by automated means alone. Where our system flags something unusual, such as a payment that doesn’t match a deal, a person on our team looks at it.

Who sees your data

The other person in your deal

They see your name as it appears on WhatsApp (or your business name), the deal details, and your trust record on Hoolam. If you get paid, the transfer narration shows the deal code.

People who check you

Anyone can ask our chat about a seller by their number and see that seller’s trust record: the number of deals completed, how many buyers were happy, and how long they’ve been on Hoolam. Sellers can see a short record of a buyer before accepting their deal. We don’t show your phone number, bank details or deal contents to people checking you.

The public, only if you choose

If a seller turns on their public page, anyone with the link can see their business name, city, trust record, and any photo and links they added.

Companies that help us run Hoolam

We share data only as needed, under contracts that require them to protect it:

  • Meta Platforms, for WhatsApp messaging (the WhatsApp Business Platform);
  • Moniepoint Microfinance Bank, through Monnify, for receiving payments, holding money, checking account names and sending payouts and refunds;
  • Render, which hosts our servers and website; and
  • Supabase, which hosts our database.

The authorities

We share data with the police, courts, regulators or other public bodies only when the law requires us to, or when it’s needed to prevent fraud or protect someone from harm.

We never sell your data. We don’t rent it, trade it, or share it with advertisers.

Data stored outside Nigeria

Some of the companies above store or process data outside Nigeria. Our servers are run by Render in Germany, our database by Supabase, and WhatsApp messages by Meta, in the countries where those companies operate. When data leaves Nigeria, we rely on the safeguards the Nigeria Data Protection Act allows, such as the providers’ data protection terms, and we only use providers with strong security.

How long we keep it

WhatHow long
Deal and payment records, including the bank accounts used5 years after the deal ends, as Nigerian law requires
Problem reports and how they were decided5 years after the deal ends
Your profile, photo, links and public pageUntil you remove them or ask us to delete your data
Your place in a chat conversationOnly until the conversation moves on
Server logsA short time, for security and fixing faults

Your rights

Under the Nigeria Data Protection Act 2023 you have the right to:

  • see the data we hold about you and get a copy;
  • correct data that is wrong or incomplete;
  • delete your data, where we don’t have to keep it by law (see Delete your data);
  • restrict or object to how we use it, including use based on our legitimate interests;
  • take your data with you in a common format;
  • withdraw your consent, for example by turning off your public page; and
  • complain to the Nigeria Data Protection Commission (ndpc.gov.ng) if you think we have handled your data wrongly. We’d like the chance to fix it first, so please tell us too.

To use any of these rights, write to hello@hoolam.com or message us on WhatsApp on +234 703 679 9976. We will reply within 30 days. To protect you, we confirm requests by messaging the WhatsApp number on your Hoolam account.

How we protect it

  • Everything moves over encrypted connections. Messages and payment updates we receive are checked to be really from WhatsApp and our payment partner.
  • Only Hoolam team members who need it can see personal data. They sign in with a password and a second step on their phone, and each sees only what their role allows.
  • Every action our team takes on a deal or account is recorded with their name, and that record can’t be edited.
  • Money can only move to the seller of a deal or back to its buyer.

No system is perfectly secure. If a breach puts your data at risk, we will tell you and the Nigeria Data Protection Commission as the law requires.

Under 18s

Hoolam is only for people aged 18 and over. If we learn that someone under 18 is using it, we will stop their deals safely and delete what we don’t have to keep.

This website

Our website doesn’t use cookies, ads or tracking. Details are on our Cookies page.

Changes to this policy

We will update this policy when what we do with data changes, and show the date it took effect at the top. For important changes, we will also tell you in WhatsApp.