Disclaimer: This Privacy Policy describes the privacy practices of llocal Limited ("we," "our," or "us") for our website llocal.net and mobile application llocal (collectively, the "Services"). By using our Services, you agree to the terms outlined in this Policy.
1. Definitions
2. Information We Collect
2.1. Data You Provide Voluntarily
- Account Registration: Name, email address, telephone number, username, hashed password
- Profile Information: Photograph, biography, gender, date of birth, physical address
- User-Generated Content: Photos, videos, audio, files, recordings, comments, reviews, forum posts, private messages
- Financial and Transactional Data: Purchase history, subscription records, billing address
- Biometric Data: face scans for authentication]
- Customer Support Communications: Content of support interactions
Payment Processing Note: Payment card details are processed directly by our PCI-DSS compliant third-party payment processors. We only receive tokenized payment confirmations and do not store full card numbers.
2.2. Data Collected Automatically
- Device Information: Device ID, IMEI, MAC address, hardware serial number, IP address, operating system, browser type
- Service Usage Data: Crash logs, performance data, pages viewed, features used, clickstream data
- Location Data: GPS coordinates (with permission), approximate location from IP/Wi-Fi
-
Cookies and Tracking Technologies:
- Strictly Necessary (essential for service)
- Performance/Analytics (e.g., Google Analytics)
- Functional (enhanced functionality)
- Targeting/Advertising (personalized ads)
2.3. Data from Third Parties
- Social Networks (when connecting accounts)
- Single Sign-On (SSO) Providers
- Data Brokers and Marketing Partners
- Publicly Available Sources
3. Legal Bases for Processing (GDPR Compliance)
We process your Personal Data based on one or more of the following legal grounds:
- Performance of a Contract: To provide the Services you requested
- Consent: For specific purposes where we've obtained your clear consent
- Legitimate Interests: For our business interests that don't override your rights
- Legal Obligation: To comply with legal or regulatory requirements
4. Purposes of Processing
| Purpose of Use | Categories of Personal Data | Legal Basis (GDPR) |
|---|---|---|
| Service Provision & Account Management | Account Information, Profile Information, Financial Data | Performance of a Contract |
| Personalization of User Experience | Usage Data, Device Information, Profile Information | Legitimate Interests / Consent |
| Marketing & Advertising | Contact Information, Usage Data, Device Information | Consent / Legitimate Interests |
| Communication & Customer Support | Contact Information, Communications, Account Information | Performance of a Contract / Legitimate Interests |
| Security, Fraud & Abuse Prevention | Device Information, Account Information, Usage Data, IP Address | Legitimate Interests / Legal Obligation |
5. Data Sharing and Disclosure
We disclose Personal Data with the following categories of third parties:
- Service Providers (Data Processors): Cloud hosting, analytics, marketing, customer support under strict contractual terms
- Advertising Partners: For targeted ads and measurement (opt-out available)
- Professional Advisors: Lawyers, auditors, insurers where necessary
- Law Enforcement and Public Authorities: When required by law
- Business Transferees: In connection with mergers, acquisitions, or asset sales
- With Your Consent: For any other purpose disclosed with your permission
CCPA/CPRA Notice: We do not "sell" or "share" Personal Data as defined under CCPA/CPRA.
6. International Data Transfers
Your Personal Data may be processed in countries outside your country of residence, including the United States, the United Kingdom or among many others.
When transferring data from the EEA, UK, or Switzerland to non-adequate countries, we rely on:
- European Commission's Standard Contractual Clauses (SCCs)
- Your explicit consent for specific transfers
- Other legally adequate mechanisms
7. Data Retention
| Data Category | Retention Trigger / Period |
|---|---|
| Account Data | Duration of account life, plus 3 years for legal compliance |
| Financial & Transactional Data | 7 years for tax and financial reporting |
| Marketing Data | Until consent withdrawal or opt-out |
| Technical Log Data | 12 months for security and analytics |
| Inactive Accounts | Deleted after 24 months of inactivity |
8. Data Security
We implement a comprehensive security framework including:
- Technical Measures: Encryption in transit (TLS 1.2+) and at rest, pseudonymization, secure coding practices
- Organizational Measures: Strict access controls, security training, confidentiality agreements
- Physical Measures: Data center access controls
We maintain an incident response plan to handle potential data breaches in compliance with legal notification requirements.
9. Your Rights and Choices
You have the following rights regarding your Personal Data:
- Right of Access & Data Portability: Request a copy of your data in machine-readable format
- Right to Rectification: Correct inaccurate or incomplete data
- Right to Erasure: Request deletion under certain circumstances
- Right to Restriction of Processing: Request we stop processing some data
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent at any time
- Right to Non-Discrimination: Protection against discrimination for exercising rights
Verification Process: We must verify your identity to process requests. We may ask for information to confirm you are the account owner.
Appeal Process: If we decline your request, we will explain why and provide appeal instructions.
10. Children's Privacy
Our Services are not directed to individuals under the age of 16 (GDPR) or 13 (COPPA). We do not knowingly collect Personal Data from children. If we discover such data, we will delete it immediately.
11. Changes to This Policy
We may update this Policy and will notify you of material changes by:
- Posting the new Policy on our Services
- Updating the "Last Updated" date
- Sending email notification for significant changes
- Requiring acknowledgment upon next login
12. Contact Information
Contact Our Privacy Team
Data Protection Officer / Privacy Team: llocal Legal Team
Email: legal@llocal.net
Postal Address: FCT 900107, Nigeria.
You have the right to lodge a complaint with a supervisory authority in your country of residence.