## 1. Introduction Welcome to Zimozi Swift ("we," "our," or "us"). Zimozi Swift is a multi-vendor e-commerce marketplace operating in Nigeria that connects vendors with customers, and offers additional services including Family Pack subscriptions, Shop4me personal shopping, LiveFirst buy-now-pay-later credit, and a state representative distribution network. This Privacy Policy explains how we collect, use, disclose, and protect the personal information of users who access or use our platform at **zimoziswift.com** and related mobile or web applications (collectively, the "Platform"). By creating an account or using the Platform, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the Platform. --- ## 2. Who This Policy Applies To This policy applies to all users of the Platform, including: - **Customers** — individuals who browse, purchase, or subscribe to products and services. - **Vendors** — businesses or individuals who register to sell products on the Platform. - **Agents / Affiliates** — commission-based partners who refer customers to the Platform. - **State Representatives / Volunteers** — regional distribution partners operating on behalf of Zimozi Swift. - **Visitors** — individuals who browse the Platform without registering. --- ## 3. Information We Collect ### 3.1 Information You Provide Directly **All Users:** - Full name, email address, phone number, and password - Profile photo (where applicable) - Correspondence, support queries, and feedback **Customers:** - Delivery addresses (country, state, city, street address, apartment, ZIP code) - Order history and preferences - Family Pack subscription details - Shop4me request details and budget information - LiveFirst credit application information **Vendors:** - Business name, legal name, and business address - Date of birth and identification document(s) - Bank account details (bank name, account number, account name) for payout processing - KYC documentation including: National ID Number (NIN), International Passport, payslip, appointment letter, bank authorization letter, selfie, or live video verification **Agents / Affiliates:** - Business name, biography, social media handles, and follower count - Niche/category information and agent referral codes - Bank account details for commission payouts **State Representatives / Volunteers:** - Home address, business name, and business address (including state, LGA, and city) - Photos of storefront, storage space, and delivery vehicle - Delivery coverage area and capacity information - Application status and supporting documentation ### 3.2 Information Collected Automatically When you use the Platform, we automatically collect: - **Device information:** device type, browser type, browser version, operating system - **Network information:** IP address, internet service provider - **Usage data:** pages visited, links clicked, search queries, session duration - **Authentication data:** login timestamps, last active time, session tokens ### 3.3 Information from Third Parties - **Payment providers (Paystack):** transaction status, payment reference codes. We do not store full card numbers. - **SMS provider (Termii):** delivery status of OTP messages sent to your phone number. - **Push notification service (Firebase / FCM):** device push tokens for notification delivery. - **Logistics API:** delivery tracking updates and route assignment data. --- ## 4. How We Use Your Information We use collected information to: | Purpose | Legal Basis | |---|---| | Create and manage your account | Contract performance | | Process orders, payments, and refunds | Contract performance | | Deliver products and provide order tracking | Contract performance | | Process vendor payouts and agent commissions | Contract performance | | Verify identity through KYC processes | Legal obligation / Contract performance | | Send transactional emails and SMS (order confirmations, OTPs, reminders) | Contract performance | | Send promotional communications (with your consent) | Consent | | Detect and prevent fraud, abuse, and security incidents | Legitimate interest | | Improve platform performance and user experience | Legitimate interest | | Comply with applicable Nigerian laws and regulations | Legal obligation | | Resolve disputes and enforce our Terms and Conditions | Legitimate interest | --- ## 5. Sharing Your Information We do not sell your personal data. We may share it in the following limited circumstances: ### 5.1 With Vendors When you place an order, your name, delivery address, and order details are shared with the relevant vendor to fulfill your purchase. ### 5.2 With Service Providers We engage trusted third-party service providers who process data on our behalf under confidentiality obligations: - **Paystack** — payment processing - **Termii** — SMS OTP delivery - **Resend / Postmark** — transactional email delivery - **Firebase (Google)** — push notifications - **Zimozi Swift Logistics API** — order delivery and tracking ### 5.3 With State Representatives and Agents Delivery and contact details necessary to fulfill orders or referral commissions may be shared with your assigned state representative or referring agent. ### 5.4 Legal Requirements We may disclose your information when required by Nigerian law, court order, or governmental authority, or when disclosure is necessary to protect the rights, property, or safety of Zimozi Swift, our users, or the public. ### 5.5 Business Transfers In the event of a merger, acquisition, or sale of all or part of our business, your information may be transferred as part of that transaction. We will notify you in advance where required by law. --- ## 6. KYC and Identity Verification Certain features — including vendor onboarding, the LiveFirst buy-now-pay-later program, and state representative roles — require identity verification (KYC). KYC data including identity documents, selfies, and supporting financial documents: - Are stored securely with access limited to authorised reviewers. - Are used solely for identity verification and fraud prevention. - Are not sold or shared with third parties except as required by law. - Are retained for the period required under applicable Nigerian financial regulations. --- ## 7. Cookies and Tracking Technologies We use session cookies and similar technologies to: - Maintain your login session - Remember items in your cart - Analyse Platform usage through server-side logging You can disable cookies through your browser settings; however, some Platform features may not function correctly without them. We do not currently use third-party advertising or tracking cookies. --- ## 8. Data Retention We retain your personal data for as long as your account is active or as necessary to provide services to you. Specifically: - **Account data:** retained while your account is open and for up to **3 years** after closure. - **Transaction records:** retained for **7 years** in accordance with Nigerian financial record-keeping obligations. - **KYC documents:** retained for the period required by applicable law, typically **5–7 years**. - **Server logs (IP, device data):** retained for up to **12 months**. You may request deletion of your account and associated data at any time (see Section 11), subject to legal retention obligations. --- ## 9. Data Security We implement appropriate technical and organisational measures to protect your personal data, including: - Encrypted storage of passwords (bcrypt hashing) - HTTPS/TLS encryption for all data in transit - Role-based access controls for administrative systems - Hashed storage of sensitive tokens (e.g., invite tokens) - Regular security reviews However, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials and notifying us immediately at **support@zimoziswift.com** of any unauthorised access. --- ## 10. Children's Privacy The Platform is not intended for individuals under the age of **18**. We do not knowingly collect personal data from minors. If we become aware that a minor has provided personal data, we will delete it promptly. If you believe a minor has registered, please contact us at **support@zimoziswift.com**. --- ## 11. Your Rights As a user of the Platform, you have the following rights regarding your personal data: - **Access:** Request a copy of the personal data we hold about you. - **Correction:** Request correction of inaccurate or incomplete data. - **Deletion:** Request deletion of your account and personal data, subject to legal retention obligations. - **Restriction:** Request that we limit processing of your data in certain circumstances. - **Data Portability:** Request your data in a structured, machine-readable format where technically feasible. - **Withdraw Consent:** Withdraw consent for marketing communications at any time by using the unsubscribe link in our emails or contacting us directly. To exercise any of these rights, contact us at **support@zimoziswift.com**. We will respond within **30 days**. --- ## 12. Third-Party Links The Platform may contain links to third-party websites or services (e.g., vendor social media pages). This Privacy Policy does not apply to those third-party sites. We encourage you to review their privacy policies independently. --- ## 13. Changes to This Policy We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email or by posting a notice on the Platform. Continued use of the Platform after changes take effect constitutes acceptance of the updated policy. The current version is always available at **zimoziswift.com/privacy**. --- ## 14. Contact Us If you have any questions, concerns, or complaints about this Privacy Policy or how we handle your data, please contact us: **Zimozi Swift** Email: **support@zimoziswift.com** Website: **zimoziswift.com** --- *© 2026 Zimozi Swift. All rights reserved.*