Sabi9ja Privacy Policy

Our commitment to you

Sabi9ja does not sell your personal data to third parties. We collect only what we need to provide and improve our services, and we give you clear controls over your information.

1. Introduction

Sabi9ja Markets ("Sabi9ja", "we", "us", or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your data when you visit our website, use our mobile application, or interact with our services (collectively, the "Platform").

This policy applies to all users of the Sabi9ja Platform, including registered account holders, visitors, and any person whose personal data we process in connection with our services. It applies regardless of whether you are located in Nigeria or accessing the Platform from another jurisdiction.

Please read this policy carefully. By using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, you should not use the Platform.

2. Data Controller

For the purposes of applicable data protection laws, the data controller responsible for your personal information is:

EntitySabi9ja Markets

RegistrationRC-XXXXXXX (CAC Nigeria)

AddressAdepate House, 44 Montgomery Rd, Yaba 101245, Lagos, Federal Republic of Nigeria

Data Protection Officerhello@sabi9ja.markets

3. Information We Collect

We collect personal data in several ways: information you give us directly, information we collect automatically as you use the Platform, and information we receive from trusted third parties.

Information you provide directly

Data Category	Examples	Source
Identity	Full name, date of birth, username, profile photo	Account registration
Contact	Email address, phone number	Account registration
Financial	Bank account details (for withdrawals), BVN (Bank Verification Number)	Withdrawal setup / KYC
Identity verification	Government-issued ID (NIN, International Passport, Driver's Licence), selfie/liveness check	KYC verification
Communications	Messages to support, feedback forms, survey responses	Your interactions with us

Information collected automatically

Data Category	Examples	Source
Usage data	Pages visited, features used, search queries, clicks, time spent	Platform activity
Transaction data	Trade history, wallet deposits/withdrawals, win/loss records	Trading activity
Device & technical	IP address, browser type & version, OS, device identifiers, screen resolution	Automatic collection
Location	Country/city-level location derived from IP address	Automatic (IP geolocation)
Cookies & trackers	Session data, preferences, analytics identifiers	See Cookie Policy

Information from third parties

We may receive information about you from third parties, including:

·Payment processors and Nigerian banks (to verify deposits and process withdrawals)
·Identity verification partners (to comply with our KYC obligations)
·Fraud detection services (to protect our Platform and users)
·Analytics providers (aggregated and anonymised usage insights)

4. How We Use Your Data

We use your personal data for the following purposes:

Providing our services

Creating and managing your account, processing trades, facilitating deposits and withdrawals, and delivering the core prediction market platform.

Safety and compliance

Verifying your identity (KYC), detecting and preventing fraud, money laundering, and market manipulation, and complying with our legal obligations under Nigerian law.

Improving the Platform

Analysing usage patterns to improve features, fix bugs, test new functionality, and personalise your experience.

Marketing communications

Sending you updates about new markets, platform features, and promotional offers — only where you have opted in. You can opt out at any time.

Customer support

Responding to your questions, resolving disputes, and providing technical assistance.

5. Legal Basis for Processing

We process your personal data on the following legal grounds under the Nigeria Data Protection Act (NDPA) 2023 and other applicable law:

Contract performance

Processing necessary to provide you with the Platform and fulfil our contractual obligations to you (e.g. executing trades, processing withdrawals).

Legal obligation

Processing required to comply with our legal and regulatory obligations (e.g. AML/CFT, KYC, tax reporting).

Legitimate interests

Processing necessary for our legitimate business interests, such as fraud prevention, security, and improving our services — where these interests are not overridden by your rights.

Consent

Where we rely on your consent (e.g. for marketing communications or non-essential cookies), you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

We do not sell your personal data. We may share your information with:

Service providers

Trusted third-party companies that help us operate the Platform, including cloud hosting providers, payment processors, identity verification services, fraud detection tools, analytics providers, and customer support platforms. These providers are contractually obligated to use your data only as directed by us and to maintain appropriate security measures.

Named processors

·Microsoft Clarity — session replay and usage analytics on public pages. We do not load Clarity on KYC, payout methods, deposit, wallet, or two-factor setup pages, and we request strict content masking. Clarity may still process page URLs and interaction data on other routes.
·OpenAI — powers the in-app support and account assistants. Account chat does not send wallet balances or open positions unless you ask about them. Conversations are not stored with OpenAI (store is disabled) and the assistant has no tools that can move funds.

Financial and regulatory authorities

We may be required to share data with the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), the Securities and Exchange Commission (SEC), or other competent authorities in compliance with applicable law.

Business transfers

In the event of a merger, acquisition, financing, or sale of all or part of Sabi9ja's business, your information may be transferred to the successor entity. We will notify you of any such change and your rights in connection with it.

With your consent

We will share your information with other third parties only with your explicit, informed consent.

Law enforcement

We may disclose your personal data if required to do so by law, court order, or legal process, or if we believe in good faith that disclosure is necessary to protect our rights, prevent fraud, or protect the safety of our users.

7. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes described in this policy, unless a longer retention period is required or permitted by law. Our standard retention periods are:

Active account dataFor the duration of your account relationship with Sabi9ja

Transaction records7 years after the transaction date (AML/CFT legal requirement)

Identity verification documents5 years after account closure (regulatory requirement)

Customer support communications3 years after the last interaction

Marketing dataUntil you unsubscribe or 2 years of inactivity, whichever is sooner

System logs and technical data90 days from collection

When we no longer need your data, we will securely delete or anonymise it in accordance with our data retention schedule.

8. Your Rights

Under the Nigeria Data Protection Act 2023 and other applicable law, you have the following rights regarding your personal data:

Right to access

You have the right to obtain a copy of the personal data we hold about you and information about how we use it.

Right to rectification

You can ask us to correct any inaccurate or incomplete personal data we hold about you.

Right to erasure

In certain circumstances, you can ask us to delete your personal data ('right to be forgotten').

Right to restriction

You can ask us to restrict how we use your data in certain situations, such as while we investigate a dispute.

Right to portability

You can request a copy of your data in a structured, machine-readable format to transfer to another service.

Right to object

You can object to processing based on legitimate interests or for direct marketing purposes at any time.

To exercise any of these rights, please contact our Data Protection Officer at hello@sabi9ja.markets with your full name, registered email address, and a clear description of your request. We will respond within 30 days. We may need to verify your identity before processing your request.

If you are dissatisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

9. International Data Transfers

Sabi9ja is based in Nigeria and primarily processes your data within Nigeria. However, some of our third-party service providers are located outside Nigeria, which may require us to transfer your data internationally.

Where we transfer personal data outside of Nigeria, we ensure that appropriate safeguards are in place, including standard contractual clauses approved by the NDPC or equivalent protections. We only transfer data to countries or organisations that provide an adequate level of data protection.

10. Children's Privacy

The Sabi9ja Platform is intended exclusively for adults aged 18 and over. We do not knowingly collect or solicit personal information from anyone under the age of 18. If we learn that we have inadvertently collected personal data from a child under 18, we will promptly delete that data.

If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately at hello@sabi9ja.markets.

11. Security

We implement industry-standard technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

·Encryption for stored personal and financial data
·Encrypted connections (HTTPS) for data sent between your device and our servers
·Optional two-factor authentication for account sign-in
·Access controls so staff only handle data needed for their role
·Monitoring for suspicious account and trading activity
·Incident response procedures, including notification where the law requires it

No data transmission over the internet is completely secure. While we take all reasonable steps to protect your information, we cannot guarantee absolute security. You are responsible for keeping your account credentials secure.

12. Cookies

Sabi9ja uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage. For full details of what cookies we use, why we use them, and how to control them, please read our Cookie Policy.

13. Third-Party Links

The Platform may contain links to third-party websites, applications, or services. Once you leave our Platform, this Privacy Policy no longer applies. We are not responsible for the privacy practices of third-party sites. We encourage you to read the privacy policy of every website you visit.

14. Policy Changes

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email and by posting a prominent notice on the Platform before the changes take effect. The "Last updated" date at the top of this policy reflects the most recent revision.

Your continued use of the Platform after any changes to this policy constitutes your acceptance of the revised policy.

15. Contact & DPO

For all privacy-related queries, rights requests, or complaints, please contact our Data Protection Officer:

AddressAdepate House, 44 Montgomery Rd, Yaba 101245, Lagos

Phone+234 906 556 6388

HoursMon–Fri, 9:00 AM – 5:00 PM WAT

DPO Emailhello@sabi9ja.markets

Privacy Emailhello@sabi9ja.markets

Response timeWithin 30 days

RegulatorNigeria Data Protection Commission (NDPC)

NDPC websitendpc.gov.ng

Privacy Policy