You choose what the hall sees.

1

Who is responsible for your data

We are. This page tells you what we keep, why, and what you can do about it.

Version [to be confirmed: version date] · In force from [to be confirmed: date in force]

1. SprayLive is run by Limestone Technology Services Limited (RC 1928165), of Road 7A, Dr Shaffideen Amuwo Street, Lekki Scheme 2, Ajah, Lagos 10024, Nigeria. We decide how your data is used, so the law calls us the data controller.
2. Our Data Protection Officer is [to be confirmed: data protection officer’s name or role]. Write to support@limestone.ng or call +234 704 253 3409.
3. We follow the Nigeria Data Protection Act 2023 and the directives of the Nigeria Data Protection Commission. [to be confirmed: NDPC registration number, if registered]

2

What we keep

We keep what puts your name on the big screen and what moves your money safely.

We do not sell your data.

1. Most of this comes from you. Some comes from our payment partner (whether a payment worked), from the bank (the name on an account), and from the identity check (whether your number matches your name).
2. We do not ask for sensitive details such as your health, religion or politics. Please do not put them in your name or photo.

3

Why we keep it, and what lets us

So the hall can see you, the host can thank you, and your money is safe.

1. Where we rely on your consent, you can withdraw it at any time. That does not undo what was done before.
2. We do not make decisions about you by computer alone that have a legal or similarly serious effect. A fraud check may pause a payment; a person reviews it if you ask.

4

Who sees your name and face

The hall does. That is the point.

1. When you spray, your name, your photo and the amount go up on the big screen. Anyone in the hall can see it, and someone may film or photograph the screen. We cannot control that.
2. The MC sees your name and can call it. You may appear on the list of top sprayers.
3. Other guests at the same event can see your name and photo so they can spray you. You can turn that off.
4. The host sees who sprayed and how much, on the gift list.
5. If you spray without your name, the hall and the MC see “A well-wisher” and no photo. The host still sees your name on the gift list, so they can thank you.

5

Who we share it with

Only the companies that help us run SprayLive, and the authorities when the law says so.

1. Each company may use your data only to do that job for us, under a written agreement, and must keep it safe.
2. If SprayLive is sold or merged, your data may pass to the new owner, who must keep to this page. We will tell you first.

6

Data kept outside Nigeria

Some of the companies above keep data on computers outside Nigeria.

1. Your data may be stored or handled in [to be confirmed: countries]. We only send it where the law allows: to a country or under a contract that protects it to the standard of the Nigeria Data Protection Act 2023. [to be confirmed: Legal to state the transfer basis under ss. 41–43]
2. [to be confirmed: where BVN details are kept, once hosting is chosen]
3. You can ask us for details of the protection in place.

7

Your choices and rights

You decide how you are seen, and you can ask for your data at any time.

• Spray without your nameThe big screen will not show it.
• Remove your photoYou added it. You can take it off.
• Download your dataYour profile, sprays and payments, from your profile.
• Delete your accountFrom your profile.

1. The law also gives you the right to:

   • know what we keep about you and get a copy;
   • have wrong details corrected;
   • have your data deleted, where we no longer have a reason to keep it;
   • ask us to stop or limit a use of your data, and object to a use based on our legitimate interest;
   • take your data to another service in a form a computer can read;
   • withdraw consent you gave;
   • not be subject to a decision made by computer alone.
2. To use a right, use your profile or write to support@limestone.ng. It is free. We answer within [to be confirmed: 30] days. We may ask you to confirm it is you. The file from your profile holds your profile, your sprays and your payments. For identity-check records and payout account details, write to us.
3. If you are not satisfied, you can complain to the Nigeria Data Protection Commission (ndpc.gov.ng).

8

How long we keep it

As long as you have an account, and after that only what the law makes us keep.

1. You cannot delete your account while you still hold mint or a payment is on its way. Get your mint back first.
2. When a period ends we delete the data or make it anonymous.

9

How we keep it safe

We protect your data and tell you if something goes wrong.

1. Data travels encrypted between your phone and us. Sign-in codes and identity numbers are stored scrambled, the bank account you pay from is stored encrypted, and staff access is limited, protected by two-step sign-in and logged. [to be confirmed: payout account numbers of hosts, crew and partners are encrypted]
2. Card details are handled by our payment partner, which meets the card industry’s security standard (PCI DSS). They never reach our systems.
3. If a breach is likely to put your rights at risk, we tell the Nigeria Data Protection Commission within 72 hours of knowing, and we tell you immediately, in plain words, what happened and what to do.
4. No system is perfect. Help us by never sharing your sign-in code.

10

Children

SprayLive is for adults.

1. You must be 18 or older to have an account. We do not knowingly keep data about anyone under 18. If you think a child has joined, tell us and we will remove the account.
2. A host who shows a child’s name or photo at an event, for example at a naming or birthday, must be the child’s parent or guardian or have their consent.

11

Cookies and your browser

We use what keeps you signed in and remembers your look. No advertising trackers.

1. We set two cookies. One keeps you signed in for up to 90 days; SprayLive cannot work without it. The other remembers the look you chose in the app, Crisp or Gold Room, for one year; you can clear it at any time. If you are signed in, the look is also saved with your profile and comes back from there.
2. Your browser also stores a random number that identifies your device, a note of the look you chose, and short-lived notes that expire when you close the page.
3. We do not use advertising cookies or sell data to advertisers. [to be confirmed: update if analytics is added]

12

Changes and how to reach us

If this page changes in a way that matters, we tell you before it applies.

1. The date at the top shows the current version. For an important change we tell you by SMS or in the app, and ask for your consent again where the law requires it.
2. Privacy questions: support@limestone.ng · +234 704 253 3409 · Limestone Technology Services Limited, Road 7A, Dr Shaffideen Amuwo Street, Lekki Scheme 2, Ajah, Lagos 10024, Nigeria