Privacy Policy

1. Introduction is provided by WithSplice Limited (“WithSplice”). At WithSplice, we value your privacy, and we are committed to safeguarding your personal information. All personal data that you provide us will be protected and kept confidential among our affiliates, representatives, and privies. Throughout the website, the terms “we”, “us” and “our” refer to WithSplice.

This Privacy Policy explains how we collect, use, share and protect your personal data in connection with your use of our services. This policy also sets out your rights and whom you may contact for further information.You agree to this Privacy Policy by visiting our website and when you use our services.Your use of our services, and any dispute over privacy is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Policy.

Our website is hosted in Nigeria and is subject to the laws of the Federal Republic of Nigeria. If you are accessing our website from other jurisdictions, please be advised that you are transferring your personal information to us in Nigeria, and by using our website, you are agreeing to the transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of the Federal Republic of Nigeria concerning your use of the website and your agreements with us. Our website and services are not directed at you if we are prohibited by any law of any jurisdiction from making the information on our website available to you and is not intended for any use that would be contrary to local law or regulation.

2. Definitions 

“consent” means the consent of the data subject which must be a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they (by a statement or by a clear affirmative action) signify their agreement to the processing of personal data relating to them;

“data subject”means a living, identified, or identifiable individual about whom WithSplice holds personal data;

“Data Protection Legislation”means all applicable data protection and privacy laws including, but not limited to the Nigeria Data Protection Regulation 2019 (NDPR), the General Data Protection Regulation, the Data Protection Implementation Framework 2020 (DPIF), and any successor legislation;

“personal data”means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that data subject;

“personal data breach”means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed;

3. Consent

3.1 Where processing of your personal data is based on consent, we shall obtain the requisite consent at the time of collection of the personal information. In this regard, you consent to the processing of your personal information when you access our website, or use our services, content, features, technologies or functions offered on our website or other digital platforms. You can withdraw your consent at any time, but such withdrawal will not affect the lawfulness of the processing of your data based on consent given before its withdrawal.

3.2 Where your personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to you when you first provided your consent, we will obtain your consent to the new purpose or purposes.

4. Age Restriction 

4.1 You affirm that you are over 18 years old and have the right to contract in your own name, and that you have read the above authorisation and fully understand its contents.

4.2 Individuals under 18 (eighteen) years old are only allowed to sign up for our services or provide us with their information when an adult above the age of 18 (eighteen) is signing contracts in their stead.

5. Data Protection Principles

The Data Protection Legislation sets out the following principles with which anyone handling personal data must comply. We, our employees, agents, contractors and third-party service providers comply with the following principles when collecting or processing your personal data. All personal data must be:

5.1. processed lawfully, fairly, and in a transparent manner in relation to the data subject;

5.2. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

5.3. accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is accurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;

5.4. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Legislation in order to safeguard the rights and freedoms of the data subject;

5.5. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

6. Information We Collect.In providing our services to you, we collect certain non-personal and personal data about you. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as permitted or required by the Data Protection Legislation. There are two categories of information we collect. We collect a variety of information from our users and visitors to our website. As described below, some information is automatically collected when you visit our website, and some you provide to us when filling out a form or communicating with us. 

6.1. Information Collected Automatically: Whenever you visit our website, our web servers automatically collect non-personal information such as the domain name of the internet access provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, and other relevant statistics.

6.2. Information You Provide Us: If you provide us with personal information, by contacting us, or subscribing to our services we collect the following personal information:

6.2.1. Username and password;
6.2.2. Contact information;
6.2.3. Information concerning your identity e.g., a valid government-issued identity card and your nationality;
6.2.4. Business information: e.g. business address, business contact information, information about your services and business such as the nature of services provided, description of services, duration and prices, business hours, payment preferences, cancellation fee, and pictures and videos from your work portfolio or any other pictures you choose to publish through the Service;
6.2.5 Financial information; and
6.2.6 Any other information you provide to us or direct us to collect.

6.3. Other information which may be automatically collected from you when you visit our website include domain name of your internet service provider, the internet protocol address used to connect the computer to the internet, the average time spent on our website, pages viewed, information searched for, access times, your geographical location, operating system, referral source, and other relevant statistics.

7. Using Your Personal Data

7.1 We primarily collect your personal data to ensure that we provide the most efficient service to you, monitor the use and improve our website and other legitimate interests. Your information will solely be used and disclosed for the following purposes:
7.1.1. To help us verify your identity,
7.1.2. To carry out our obligations ensuing from any contracts entered into between you and us,
7.1.3. To provide you with the products, services and information you request from us, including sharing your information with third parties where we have legal basis to do so,
7.1.4. To assist you with enquiries and improve our customer service,
7.1.5. To assist us in carrying out marketing analysis and customer profiling (including transactional information), conduct research, including creating statistical and testing information,
7.1.6. To allow us to communicate with you in any way (including e-mail, telephone, and text or multimedia messages),
7.1.7. For our billing and account purposes,
7.1.8 To help prevent and detect fraud or loss,
7.1.9. To update our records,
7.1.10. To make recommendations and suggestions to you about services offered by us unless you have previously asked us not to do so,
7.1.11. To send you service or support messages, such as updates, security alerts, email notifications and /or newsletters,
7.1.12. To conduct investigations and risk assessments, and
7.1.13. For compliance with legal and regulatory obligations.

7.2 Employees, agents, contractors, or other parties working on behalf of WithSplice shall collect your personal data only to the extent required for the performance of their job duties and only in accordance with this policy. Excessive personal data must not be collected.

7.3. Employees, agents, contractors, or other parties working on behalf of WithSplice shall process your personal data only when the performance of their job duties requires it. Your personal data held by WithSplice cannot be processed for any unrelated reasons.

8. Data AccuracyYour personal data must be accurate and kept up to date. In this regard, WithSplice shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to you; make efforts to keep your personal data updated where reasonable and applicable; and make timely efforts to correct or erase your personal data when inaccuracies are discovered.

9. Data RetentionWithSplice shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.  In the case of your financial data, the purpose for which the data was collected is to provide you with our services. Unless WithSplice receives a valid request to erase your data, the data is retained for ten years after you actively stop using our services or products. This allows your record to be maintained. 

10. Other Information We CollectWe may also collect information from you using cookies and other analytical tools especially when you use our products and services. More details are provided below in our section on Cookies.We may collect information about you or others from our affiliates or from third-party sources. For example, we may, in our sole discretion, ask for and collect supplemental information from non-affiliated parties, such as information to verify your identity or information for other fraud or safety protection purposes, to the extent permitted by law. We may combine information collected from you through the Services with information obtained from third parties and information derived from other products or services we offer.We may collect information provided by you through survey participation or form submission. e.g. surveys about the nature of the services you receive from a business owner, for example. We will collect the information you provide in response to the survey, which may include your name, contact information, demographic data, and concerns or interests about services (for example, hair or skin concerns).We may also collect information about you from social media networks e.g. Facebook, Instagram, Twitter, or other social media sites. We may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We may also collect your information if you interact with social media features that may be made available on the Services, such as like and share buttons, or if you tag us or identify us in your social media posts. If you access the Services through a third-party account, such as Facebook or Google, (each a “Third-Party Service”), you may allow us to have access to certain information from the Third-Party Service. Depending on the Third-Party Service, the information disclosed to us may include your name, profile picture, gender, email address, photos, videos, people you follow and/or who follow you, and/or your posts or “likes.”Third-Party Services have their own policies for handling your information, and we encourage you to consult their privacy policies before accessing the Services with a Third-Party Service.

11. Data Confidentiality Your information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request copies of any and all information we keep on you, if such requests are made in compliance with applicable laws and other relevant enactments. While we are responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorised officers of WithSplice. 

12. Disclosures

12.1. We will not sell, publish, or disclose to third parties your personal data collected on our website, through our servers or otherwise obtained by us, other than to provide our services and as set forth in this policy. We may share generic aggregated demographic information not linked to any Personal Data regarding visitors and users with our business partners, trusted affiliates, professional advisers and advertisers for the purposes outlined above. We may share your information with these third parties for those limited purposes if you have given us your permission and in compliance with the Data Protection Legislation.

12.2. We may request and provide Personal Data about you from and to third parties to provide our services. We may share Personal Data with service providers, affiliates, partners, and other third parties where it is necessary to provide the products and services, or for any other purposes described in this Privacy Policy.

12.3. Your Personal Data may be provided as necessary to the following categories of recipients: security, insurance, professional advisory (including legal, accounting and auditing advice), banking, payment processing, facilitating credit arrangements, credit reporting, fraud checks, data storage, information processing, order tracking, marketing, online communications technology services, and other trusted third parties with whom we have an agreement for the protection of your information, or government/regulatory/law enforcement agencies pursuant to legally binding order. 

12.4. We will notify you as soon as we become aware of a harmful data breach which may result in a risk of your rights and freedom.

12.5. You have the right to request an erasure of your data at any time.

12.6. We will notify you if we are transferring your data.

12.7. You may request at any time that we halt further dissemination of your data or cease to use your data. 

12.8. If you submit content in a public forum or a social media post, or use a similar feature on our website, that content is publicly visible. 

12.9. We may disclose Personally Identifiable Information if required to do so by law or in the good faith belief that such action is necessary to (a) conform with the requirements of the law or comply with legal process served on us, or (b) act in urgent circumstances to protect the personal safety of users of our service or members of the public. 

12.10. To the extent practicable and legally permitted, we will attempt to advise you prior to any such disclosure, so that you may seek a protective order or other relief limiting such disclosure.

13. Transfer of Personal Data

13.1 Third Party Processor 
We may engage the services of third parties in order to process your personal data. The processing by such third parties shall be governed by a written contract with WithSplice to ensure adequate protection and security measures are put in place by the third party for the protection of your personal data in accordance with the terms of this policy and the Data Protection Legislation.

13.2 International Transfers

13.2.1 Your information may be transferred to a foreign country or international organisation for the purpose of providing our service to you. We will ensure that there are adequate data protection laws in the recipient country or organisation before transferring your information. In particular, we shall, among other things, conduct a detailed assessment of whether the said country is on the Nigeria Data Protection Bureau (NDPB) Whitelist of Countries with adequate data protection laws or any other relevant authorities that exist and may come into existence in the jurisdictions where WithSplice has offices.
13.2.2. Transfer of your personal data out of Nigeria would be in accordance with the provisions of the NDPR. We will therefore only transfer your personal data out of Nigeria on one of the following conditions: 
a. Your explicit consent has been obtained;
b. The transfer is necessary for the performance of a contract between you and WithSplice;
c. The transfer is necessary to conclude a contract between WithSplice and a third party in your interest;
d. The transfer is necessary for reason of public interest;
e. The transfer is for the establishment, exercise or defense of legal claims; and 
f. The transfer is necessary in order to protect your vital interests or the interests of other persons, where you are physically or legally incapable of giving consent.
13.2.3. Provided, in all circumstances, that you have been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where you are answerable in duly established legal action for any civil or criminal claim in another country.
13.2.4. We will take all necessary steps to ensure that your personal data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Nigeria shall be provided to you upon request.
13.2.5. Where the recipient country is not on the White List and none of the conditions stipulated in clause 13.2.2 of this policy is met, WithSplice will engage with NDPB and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer.

14. Your Rights Subject to certain limitations and exceptions, you are entitled to the following principal rights under the Data Protection Legislation:
14.1. You have the right to be notified if we are transferring your personal information.
14.2. You have the right to request an erasure of your personal data at any time.
14.3. You have the right to request that we rectify inaccurate personal information.
14.4. You may request at any time that we halt further dissemination of your data or cease to use your personal information.
14.5. You have the right to request for copies of your personal information.

15. Website Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as secure sockets layer (SSL) to safeguard and secure the information we collect online. We use encryption tools when accepting and transmitting delicate visitor information through our website. Some of the other safeguards we use are firewalls and physical access controls to our data centres, and information access authorisation controls.

16. Training
We shall ensure that employees who collect, access and process your personal data receive adequate data privacy and protection training in order to develop the necessary knowledge, skills and competence required to effectively manage the compliance framework under this policy and the Data Protection Legislation with regard to the protection of personal data. On an annual basis, we shall develop a capacity building plan for our employees on data privacy and protection in accordance with the Data Protection Legislation.

17. Use of Cookies
We use cookies to identify you as a user and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember your account log-in information when you visit our website, IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities. If your browser or browser add-on permits, you have the choice to disable cookies on our website; however, this may limit your ability to use our website.

18. The Data We Retain
We will retain your information for as long as needed to provide you with our services, comply with our legal and statutory obligations or verify your information with a financial institution. We are statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us.

19. Data Breach Management Procedure 

19.1. In the event where there is any accidental or unlawful destruction, processing, loss, alteration, unauthorised disclosure of, or access to your personal data, we shall: 
19.1.1. notify you within 24 (twenty-four) hours of the occurrence of the data breach;
19.1.2. properly investigate the breach and take the necessary steps to mitigate such breach;
19.1.3. identify remediation requirements and track the resolution of such breach; and
19.1.4. notify the Information Commissioner’s Office or any other regulatory authority, where necessary. 

20. Links to Third Party Websites

20.1. Our website may contain links to third-party websites or services that are not owned or controlled by us.
20.2. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services.
20.3. We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

21. Limitation of Liability We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorised disclosure of personal data that occurs through no fault of ours.

22. Changes to this Privacy PolicyChanges may be made to this Privacy Policy from time. Whenever such changes are made, we will notify you. These changes will take effect immediately after you have been notified.

23. Contact Us
If you would like more information or you have any comments or questions on our Privacy Policy, please contact us at

This policy is effective as of May 2023  
Last updated: May,14 2023