Privacy Policy

1. Introduction and NDPR Compliance

Fray Spot ("we," "our," or "us") is committed to protecting your privacy and personal data in accordance with the Nigeria Data Protection Regulation (NDPR) 2019. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our gaming tournament platform.

As a data controller under NDPR, we ensure that all personal data processing activities comply with Nigerian data protection laws and international best practices.

2. Data Controller Information

Data Controller:

Fray Spot Limited
Address: [Your Business Address], Nigeria
Email: privacy@frayspot.com

Data Protection Officer (DPO):

Email: dpo@frayspot.com

You may contact our DPO for any data protection concerns or to exercise your rights under NDPR.

3. Personal Data We Collect

Account Information

• Full name and username
• Email address
• Phone number
• Date of birth (for age verification)
• Profile picture (optional)

Financial Information

• Bank account details for withdrawals
• Transaction history
• Payment method information (processed securely through Paystack)

Gaming Data

• Tournament participation records
• Game performance statistics
• Match results and rankings
• Gaming platform usernames

Technical Data

• IP address and device information
• Browser type and version
• Usage analytics and platform interactions
• Cookies and similar technologies

4. Legal Basis for Processing (NDPR Compliance)

We process your personal data based on:

• Consent: When you voluntarily provide information and agree to our terms
• Contract Performance: To provide tournament services and process payments
• Legal Obligation: To comply with Nigerian laws and regulations
• Legitimate Interest: To improve our services and prevent fraud

5. How We Use Your Data

• Create and manage your gaming account
• Process tournament registrations and payments
• Facilitate prize distributions and withdrawals
• Provide customer support and resolve disputes
• Send important notifications about tournaments and account activity
• Improve our platform and develop new features
• Ensure platform security and prevent fraud
• Comply with legal and regulatory requirements

6. Data Sharing and Third Parties

We may share your data with:

• Payment Processors: Paystack (for secure payment processing)
• Cloud Services: Supabase (for secure data storage)
• Legal Authorities: When required by Nigerian law or court orders
• Service Providers: Third-party vendors who assist in platform operations

All third-party processors are required to maintain NDPR-compliant data protection standards.

7. Your Rights Under NDPR

You have the right to:

• Access: Request copies of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your personal data
• Portability: Receive your data in a structured format
• Restriction: Limit how we process your data
• Objection: Object to certain types of data processing
• Withdraw Consent: Withdraw consent for data processing
• Complaint: Lodge complaints with the Nigerian Data Protection Commission (NDPC)

To exercise these rights, contact us at privacy@frayspot.com or our DPO at dpo@frayspot.com. We will respond within 30 days as required by NDPR.

8. Data Security and Storage

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• Staff training on data protection practices
• Incident response procedures

Your data is stored securely in Nigeria-compliant cloud infrastructure with appropriate backup and recovery measures.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy:

• Account Data: Until account deletion or 3 years of inactivity
• Transaction Records: 7 years (as required by Nigerian financial regulations)
• Gaming Records: 2 years for tournament history and statistics
• Marketing Data: Until consent is withdrawn

10. International Data Transfers

Your personal data is primarily processed within Nigeria. If we need to transfer data internationally, we ensure adequate protection through:

• NDPR-approved adequacy decisions
• Standard contractual clauses
• Binding corporate rules
• Your explicit consent

11. Cookies and Tracking

We use cookies and similar technologies to enhance your experience. For detailed information about our cookie usage, please see our Cookie Policy.

12. Children's Privacy

Our platform is not intended for children under 18 years. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a child, we will take steps to delete such information promptly.

13. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant changes through email or platform notifications at least 30 days before they take effect.

14. Contact Information

For privacy-related inquiries:

Email: privacy@frayspot.com
DPO: dpo@frayspot.com
Address: [Your Business Address], Nigeria

Nigerian Data Protection Commission:

If you have concerns about our data practices, you may contact the NDPC:

Website: ndpc.gov.ng
Email: info@ndpc.gov.ng