Privacy Policy

1. Introduction

Welcome to ThinkRich. ThinkRich Naija (“we”, “us” or “our”) operates the ThinkRich Naija mobile application and the website at www.thinkrichnaija.com (collectively, the “Service”), an educational entertainment platform offering quizzes, competitions, leaderboards and cash prizes in Nigerian naira.

This Privacy Policy explains how we collect, use, disclose and safeguard information that results from your use of the Service. By creating an account, entering a quiz, joining a live show or otherwise using ThinkRich Naija, you agree to the collection and use of information in accordance with this policy.

Our Terms of Service govern all use of the Service and, together with this Privacy Policy, constitute your agreement with us.

2. Definitions

SERVICE: means the ThinkRich Naija quiz platform — including the mobile application and the website www.thinkrichnaija.com — operated by ThinkRich Naija.
PERSONAL DATA: means data about a living individual who can be identified from those data (or from those and other information in our possession).
USAGE DATA: is data collected automatically, generated by use of the Service or from the Service infrastructure itself (for example, session duration or pages visited).
NIN VERIFICATION DATA: means the National Identification Number you submit and the name, gender, date of birth and state of origin returned against it, used to verify that one person holds one account.
COOKIES: are small files stored on your device (computer or mobile device).
DATA CONTROLLER: means a person who determines the purposes and manner of processing personal data. For this Privacy Policy, ThinkRich Naija is the Data Controller.
DATA PROCESSORS: means any person who processes data on behalf of the Data Controller, such as payment processors, identity verification providers and cloud hosting providers.
THE USER: is any individual using our Service — including players, influencers and competition participants.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service — to verify your identity, run fair competitions, award prizes, process wallet payments and keep our community safe.

4. Types of Data Collected

Personal Data. While using the Service we may ask you to provide personally identifiable information, which may include:

First and last name
Email address and phone number
Date of birth (for age verification)
Your National Identification Number (NIN) and the identity details attached to it
Profile photo, if you choose to add one
Bank account details for prize payouts (paid to accounts verified under your profile name)
Referral and influencer channel information you submit when upgrading to a partner account

Usage Data. We collect information your device sends when you use the Service, such as IP address, device type and model, operating system, app version, unique device identifiers, crash reports, pages or screens visited, time spent, quiz answers and scores, and other diagnostic data.

Wallet & Transaction Data. When you fund your wallet, pay a quiz stake or live-show entry fee, or receive a prize, we record the transaction amount, method, status and timestamps. Card details are tokenised and handled by our payment processor; we never store full card numbers.

Tracking Cookies Data. We use cookies and similar tracking technologies to track activity on the Service and remember preferences (including your selected language). Examples:

Session Cookies to operate the Service.
Preference Cookies to remember your settings, such as language.
Security Cookies for fraud and abuse prevention.
Analytics Cookies to understand how the Service is used and improve it.

5. Use of Data

ThinkRich Naija uses the collected data for the following purposes:

To provide, maintain and operate the quiz and competition Service;
To verify your identity through NIN verification and enforce one-person-one-account rules;
To calculate scores, rankings and prize entitlements;
To process wallet deposits, entry fees and prize payouts;
To verify influencer accounts and calculate partner commissions;
To provide customer support and resolve disputes;
To send service notifications (game reminders, results, wallet receipts, account updates);
To monitor usage and detect, prevent and address cheating, fraud and technical issues;
To send you news, promotions, offers and information about upcoming live shows (you can opt out at any time);
To carry out our obligations and enforce our rights under contracts with you;
To comply with legal obligations, court orders and lawful requests from authorities.

6. Retention of Data

We retain your Personal Data only as long as necessary for the purposes set out in this Privacy Policy, to comply with our legal obligations, resolve disputes and enforce our agreements. Wallet, stake and prize-payout records are retained for the period required by applicable tax, accounting and financial regulations.

Usage Data is generally retained for a shorter period, except when used to strengthen security, detect fraud or improve functionality, or when we are legally required to retain it longer.

7. Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — servers located outside your state, province or country where data protection laws may differ from yours.

If you are located outside Nigeria and choose to provide information to us, please note that we transfer and process the data in Nigeria and other jurisdictions where our service providers operate. Your submission of information represents your agreement to that transfer. ThinkRich Naija takes all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

8. Disclosure of Data

We may disclose Personal Data:

Between players where competition integrity requires it — for example, displaying display names and rankings on leaderboards.
Business transactions — in a merger, acquisition or asset sale your Personal Data may be transferred.
Service providers — payment processors, identity verification providers, cloud hosting, SMS and email providers, analytics and crash reporting tools.
Affiliates and subsidiaries.
Law enforcement and authorities when required by law, or to protect the rights, property or safety of ThinkRich Naija, our users or the public, including suspected fraud or prize-money laundering.
With your consent in any other case.

9. Security of Data

The security of your data is important to us. We use industry-standard encryption in transit (TLS) and at rest, tokenise card data through PCI-compliant payment processors and apply strict access controls. Biometric login details, where enabled, remain on your device. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

11. Your Rights under the California Privacy Protection Act (CalOPPA)

According to CalOPPA we agree to the following:

Users can visit our site anonymously;
Our Privacy Policy link includes the word “Privacy” and can easily be found on the home page of our website and inside the app;
Users will be notified of any privacy policy changes on this Privacy Policy page;
Users can change their personal information from inside the app or by emailing privacy@thinkrichnaija.com.

Do Not Track Signals: We honour Do Not Track signals and do not track, plant cookies or use advertising when a Do Not Track browser mechanism is in place.

12. Children's Privacy

ThinkRich Naija is not intended for anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18. If you become aware that a child has provided us with Personal Data, please contact us and we will take steps to remove that information and terminate the account.

13. NIN Verification & Identity

To play quizzes and enter live shows, we verify your identity against your National Identification Number (NIN). You submit your 11-digit NIN once; we display the name, gender, date of birth and state attached to it as read-only confirmation. We use this to ensure one person holds one account and that prizes are paid to the right person.

Your NIN is stored securely and is never displayed in full inside the app or shared with other users. Only accounts verified under the same identity can receive payouts, and a NIN already tied to another account cannot be used to create a duplicate account.

14. Permissions on Mobile Devices

The ThinkRich Naija app requests the following device permissions. You can grant or revoke them at any time in your device settings:

Notifications — game reminders, live-show start alerts and account updates.
Camera and Photos — to upload a profile photo or verification documents (optional).
Biometrics (Face ID / fingerprint) — for biometric login on your device, where you enable it.
Storage — to save receipts, asset kits and exported data.

15. Third-Party Services

We rely on trusted third parties to run the Service, including payment processors, identity verification providers, SMS and email gateways, cloud hosting, analytics and crash reporting. Each provider is bound by contractual obligations to handle your data securely and only for the purposes we specify.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date. For material changes we will also notify you by email or in-app notification. You are advised to review this Privacy Policy periodically.

17. Contact Us

If you have any questions about this Privacy Policy, please contact us:

privacy@thinkrichnaija.com

Website

www.thinkrichnaija.com

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