Privacy Policy

1. Who We Are

Flandle Technologies Ltd is the data controller for Chetly. Registered address: CafeOne, Unilag, Lagos. CAC registration number: RC 6966858.

Data Protection Officer: Chizom Echehieuka, chizom@flandle.io

2. What We Collect

If you're an individual receiving tips (creator, professional, or otherwise):

• Full name, email address, phone number
• BVN, used solely to verify your identity
• Bank account name and number, used to send you your tips
• Your tip page content (page name, photo, description)
• Transaction history: amounts received, dates, and payer information available to us

If you're sending a tip:

• Name or handle you choose to enter at the time of tipping
• The name, bank and account number of the bank account you pay from, as reported to us by Nomba. We record this for every tip, including anonymous ones, for fraud prevention and our transaction records, and it is never shown to the creator for an anonymous tip. If you don't tip anonymously and leave the name field blank, the creator sees the name on that bank account
• Your email address, only if you choose "Get a receipt with Google", used to send you your receipt. We receive only your verified email from Google and do not create an account for you
• Payment details, processed directly by Nomba, our payment partner; Chetly does not see or store your card or account credentials
• Transaction amount and timestamp

For everyone:

• Basic device and usage data (browser type, general analytics) to keep the site working and secure

3. Why We Collect It

• To create and run your tip page or process your tip
• To verify a creator's identity before releasing any payout, which we're legally required to do
• To detect and prevent fraud or abuse
• To meet our AML/CFT and NDPA obligations
• To contact you about your account or a transaction

4. Who We Share Data With

• Nomba: our licensed payment processing partner, who actually moves the funds. We share the transaction and recipient bank details needed to complete a transfer.
• Supabase: our backend infrastructure provider, which stores account and transaction data on our behalf.
• BVN verification providers: used to confirm a creator's identity at signup.

We do not sell your data to anyone, and we don't share it beyond what's needed to run Chetly and meet our legal obligations.

5. How Long We Keep It

Account data is kept for as long as your account is active. Identity verification and transaction records are kept for a minimum of five years after the transaction, as required for AML/CFT compliance, even if you close your account.

6. Your Rights

Under the NDPA, you can ask us to:

• Show you the personal data we hold about you
• Correct anything inaccurate
• Delete your data, where we're not legally required to keep it (e.g. verification records within the five-year window)
• Explain how a particular decision about your account was made

To exercise any of these, email chizom@flandle.io.

7. Security

We use reasonable technical safeguards, including encryption of sensitive data in transit and access controls on our systems. No platform is 100% secure. If you ever suspect your account has been compromised, tell us immediately.

8. If Something Goes Wrong

If we ever have a data breach that puts your information at risk, we'll notify the Nigeria Data Protection Commission and affected users without undue delay, as required by law.

9. Changes to This Policy

We may update this policy as Chetly grows. We'll update the date at the top when we do, and let you know if a change materially affects how your data is used.

10. Contact

Questions or complaints: chizom@flandle.io. You can also complain directly to the Nigeria Data Protection Commission (NDPC).