Privacy Policy
Privacy Policy
Last updated: 10 October 2026
Draft — pending legal review
This policy describes how EPWT handles your information and is being finalised with our legal advisers. Until then it is provided for information and may change.
This policy explains what personal information EPWT Marketplace ("EPWT", "we") collects, why, and what choices you have. It should be read with our Terms & Conditions. We aim to handle your data in line with the Nigeria Data Protection Act / NDPR.
1. Who this covers
This policy covers anyone who uses EPWT — buyers, guests, and paid members — and the shop owners we buy stock from (see section 10). EPWT is the data controller for the information described here.
2. What we collect
We collect only what we need to run the marketplace:
- Account & sign-in: your phone number, or the email/name from Google or Apple sign-in, depending on how you sign in. We use these to identify your account.
- Profile: your name and a contact email if you provide one, and an optional profile photo.
- Delivery: the addresses you save — recipient name, phone, street, and state — used to deliver your orders and to calculate delivery fees.
- Orders: the items you buy, order amounts, delivery and status history, and any disputes or cancellations.
- Membership & earnings (members): your membership status, referral code, referral relationships, earnings ledger, and — for withdrawals — your bank details (bank, account number, resolved account name).
- Preferences & notifications: your privacy toggles and the in-app notifications generated by your activity.
- Technical: basic device/app information needed to deliver the service securely (for example, to keep you signed in).
We do not collect or store your full card details — card payments are handled by Paystack (see section 4). We do not ask buyers or members for NIN or BVN; that is part of vendor verification, which is not yet live (see section 9).
3. How we use it
- To create and secure your account and keep you signed in.
- To take payment, fulfil and deliver your orders, and provide support.
- To calculate pricing and delivery fees, and to show member pricing to active members.
- To operate membership, referrals, earnings and withdrawals for members.
- To send you order, payment, and account notifications, and — only where you allow it — promotional messages.
- To detect and prevent fraud and abuse, and to meet legal and regulatory obligations.
We rely on the lawful bases of performing our contract with you (fulfilling your orders), your consent (for optional marketing and push notifications), our legitimate interests (security and fraud-prevention), and legal obligation, as applicable.
4. Payments
Payments and refunds are processed by Paystack. When you pay, you interact with Paystack directly, and Paystack processes your card or bank details under its own privacy terms — EPWT does not receive or store your full card number. For member withdrawals, we share your bank account number and name with Paystack to verify the account and to send the transfer. Refunds are always returned to your original payment channel through Paystack, never to an in-app balance.
6. Where it's stored
Your data is stored using Google Firebase (authentication, database, file storage and messaging), which processes data on our instructions as our processor. Some of this processing may occur on servers outside Nigeria; where it does, we rely on the provider's safeguards for such transfers. We apply access controls so that only authorised EPWT systems and staff can reach your data.
7. How long we keep it
We keep your information for as long as your account is active and as long as we need it to provide the service. We keep order, payment and payout records for longer where we are required to for legal, tax, accounting or fraud-prevention reasons. When data is no longer needed, we delete or anonymise it.
8. Your rights
Subject to Nigerian data-protection law, you may ask us to access, correct, or delete your personal information, object to certain uses, or withdraw a consent you gave (for example, turning off marketing messages in your privacy settings). You can update your profile, addresses and preferences in the app, or contact us using the details in section 13. Deleting your account may be limited where we must keep certain records by law.
9. Vendor verification (not yet live)
Third-party vendors are not live on EPWT today, and no buyer or member is asked for NIN or BVN. This section describes how we will handle vendor identity data if and when vendor onboarding is introduced, and takes effect only then.
When vendor onboarding goes live, a prospective vendor will be verified through a licensed identity provider. This will involve a live NIN and BVN check and a liveness/selfie match, and resolving their payout bank account name against their verified identity.
We will not store a vendor's full NIN or BVN. We will retain only the identity provider's verification reference, the last few digits, the legal name returned by the check, and the timestamps — the minimum needed to prove a vendor was verified. The full identifiers pass through to the licensed provider and are not kept by EPWT. Full details will be set out here before vendor onboarding is enabled.
10. Suppliers and business contacts
This section is about people who are not users of the app: the owners and contact people of the shops EPWT buys stock from. Our coordinators record their details so we can run our supply chain.
- What we hold: the shop's name, the owner's name, a phone number, the shop's address, the product categories the shop supplies, internal notes our coordinators add, and which EPWT products we source from that shop.
- Why: to source stock, to reorder, and to trace a product back to where it came from — for example, to deal with a quality problem, a recall, or a buyer's dispute.
- Lawful basis: our legitimate interests in running and managing our supply chain.
- Who can see it: the EPWT coordinators for the state the shop is in, and our national coordinator. It is never shown to buyers or members and never published in the app. Like the rest of our data, it is stored with Google Firebase as our processor (see section 6); we do not share it with anyone else, except where the law requires (see section 5).
- How long we keep it: while we work with the shop. When we stop, the record is archived — no longer used for new orders — and kept only as long as we keep the order and product records linked to it (see section 7). After that, we delete or anonymise it.
We ask our coordinators to tell suppliers that their details are recorded, and not to note ID numbers, bank details or other sensitive information about them.
If we hold your details as a supplier, you can ask to see them, have them corrected, or have them deleted, using the contact details in section 13. We may need to keep a limited record where it is linked to orders we must retain by law.
11. Children
EPWT is intended for adults who can enter a binding contract under Nigerian law. We do not knowingly collect data from children. If you believe a child has provided us information, contact us and we will remove it.
12. Changes
We may update this policy from time to time. When we do, we will update the "last updated" date above and, for significant changes, notify you in-app.
13. Contact
For any question about your data, or to exercise a right above, contact us at support@epwt.org or through the Support section in the app.
EPWT Marketplace — Energy · Protection · Wellness · Transformation.
