HafrikPlay Privacy Policy

Effective Date: March 5, 2025

1. Introduction

This Privacy Policy governs the processing of personal data by HafrikPlay Digital Media Limited ("HDML," "we," "our," or "us") in relation to HafrikPlay, a digital platform providing users with access to curated content, interactive features, and community engagement tools.

We recognize that privacy is a fundamental human right and are committed to ensuring transparency, accountability, and compliance with applicable data protection laws. These include:

• The Nigeria Data Protection Act (NDPA) 2023
• The General Data Protection Regulation (GDPR) (EU & UK)
• The Digital Services Act (DSA) (where applicable)
• Other applicable international privacy and consumer protection laws

This Policy applies to your use of all HarikPlay digital services. This includes streaming and accessing content on any device, as well as personalization features that enhance and tailor your user experience. It also covers the underlying technology and infrastructure that power our platform, along with the ability to connect your HarikPlay account to third-party applications. Whether you use our free or paid service options, collectively referred to as "Service Options," this Policy governs how your data is processed.

Additionally, this Policy extends to other HarikPlay services that reference it, such as our official websites, customer support services, and community and engagement platforms.

This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal data when you use HafrikPlay.

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the practices described herein.

2. Categories of Personal Data Collected

We collect the following categories of personal data based on your interaction with HafrikPlay:

2.1 Data You Provide Directly

We collect information that you voluntarily share with us, such as your public profile details, name, identification number, address, email address, social media login credentials, phone number, device information, browsing history, account and billing details, as well as any comments, lists, photos, videos, and voice recordings you upload. Additionally, if other users share content about you on HafrikPlay, that information will remain publicly accessible as long as the original sharer retains it.

• Identity and Contact Data: Full name, username, email, phone number, country of residence
• Profile Information: Profile photo, bio, user-generated content, preferences
• Financial Data: Payment details (processed via third-party payment gateways; we do not store card details)
• Communications Data: Messages, feedback, or inquiries submitted via customer support

2.2 Data Collected Automatically

We also automatically collect certain data from your device, such as your IP address, device identifiers, mobile carrier, time zone, operating system, and hardware/software versions. This helps us optimize our Services and personalize your experience using automated decision-making tools.

Your engagement with the HafrikPlay platform, including comments, views, interactions, likes, and shares, is also tracked to improve our recommendations and tailor the content you see. Additionally, we may collect and process location-based information from your SIM card, IP address, or mobile settings to enable location-based features.

When you post content on HafrikPlay, metadata-such as details on when, how, and by whom the content was created- is automatically uploaded. This may include your account name and hashtags associated with the post.

• Device and Technical Data: IP address, device identifiers, operating system, browser type
• Usage Data: Pages visited, time spent, features interacted with
• Behavioral Data: Preferences, engagement history, content interactions
• Geolocation Data: If location services are enabled, we may collect location data for content personalization

2.3 Data from Third Parties

If you connect HafrikPlay to a social media platform or public forum, we may receive data from these accounts, depending on your privacy settings with those services. For details on how they process your information, please refer to their respective privacy policies.

We also receive information from third-party sources, including advertising networks, analytics providers, and other HafrikPlay-operated websites. If you create an account through a third-party service, such as a social media platform, we may collect profile-related information, including your username, gender, profile image, birthday, and contact list. Additionally, we may access contact information from your address book or social media connections to help you discover and connect with people you may know.

• Social Media Platforms: If you sign in using third-party services (e.g., Google, Facebook), we receive data such as your name and email
• Advertising & Analytics Providers: Information used to improve recommendations and deliver targeted advertising
• Law Enforcement & Regulatory Requests: Information provided in response to legal obligations

2.4 Cookies and Third-Party Analytic Tools

To enhance your experience, we use cookies and similar technologies. Cookies are small data files stored on your device that help enable essential features, track performance, and personalize content. Different types of cookies serve different functions, including those that are strictly necessary for the platform, analytical tools to monitor performance, functionality-based enhancements, and targeted advertising. While you can disable cookies through your browser settings, doing so may affect certain features of HafrikPlay. Furthermore, we utilize third-party analytics tools to assess traffic patterns and user engagement on HafrikPlay. These tools collect data from your device and platform interactions, helping us refine and improve our Services.

3. Legal Basis for Processing

Legal Basis for Processing

At HarikPlay, we process your personal data based on specific legal grounds to ensure that our services function smoothly while complying with applicable laws. One key basis for processing your data is contractual necessity. This means we use your information to provide and maintain our services, allowing you to stream content, personalize your experience, and interact with our platform as intended.

In some cases, we process your data based on our legitimate interests. This includes using your information to enhance security, prevent fraud, and analyze how our platform is used. These measures help us improve your experience while keeping HarikPlay safe and efficient.

There are instances where we rely on your consent to process certain types of data. For example, we will ask for your permission before using your data for marketing purposes, location tracking, or AI-driven personalization features. You always have the right to withdraw your consent if you no longer wish for your data to be used in these ways.

Additionally, we may process your data to comply with legal obligations. This applies when we need to meet regulatory requirements or fulfill requests from authorities.

If at any point you have given consent for data processing, you can withdraw it whenever you choose.

4. How We Use Your Data

We use your personal data to ensure a seamless, engaging, and secure experience on HafrikPlay. This includes providing access to our platform and tailoring content to your preferences through AI-driven recommendations, helping you discover music, videos, and other content that match your interests.

Additionally, we use your data to maintain and enhance the security of our platform by monitoring for fraudulent activity, unauthorized access, and potential threats. Compliance with legal and regulatory obligations is also a key aspect of our data processing, ensuring that we meet all applicable laws and industry standards.

Your data helps us conduct analytics and market research, allowing us to improve our services, understand user behavior, and develop new features that enhance your experience. We may also use your data to deliver relevant advertisements, with the option to opt out if you prefer not to receive personalized ads.

Importantly, we do not sell your personal data to third parties. Your privacy is a priority, and we are committed to handling your information responsibly.

5. Data Sharing & Third-Party Disclosures

We share personal data only in the following scenarios:

5.1 Service Providers & Partners

We engage vetted third parties for:

• Cloud storage (AWS, Google Cloud, etc.)
• Payment processing (Stripe, Paystack)
• Security monitoring (firewall providers, fraud detection)

5.2 Compliance with Law Enforcement & Regulators

We may disclose your data if required to:

• Comply with legal obligations or regulatory inquiries
• Enforce our terms of service
• Prevent fraud, abuse, or security threats

5.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your data may be transferred under strict confidentiality obligations.

We do not engage in unauthorized data sharing or profiling.

6. Data Retention & Deletion

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by applicable laws.

• Account Data: We keep your account-related information for as long as your HafrikPlay account remains active. If you choose to delete your account, we will remove or anonymize your data unless retention is required for legal or operational purposes.
• Transaction Records: Financial records, including payment history and transactions, are retained for five years to comply with financial regulations and auditing requirements.
• Legal & Compliance Data: Any data related to legal obligations, disputes, or regulatory compliance is retained in accordance with statutory requirements, ensuring we meet our legal responsibilities.

Once the applicable retention period expires, we securely delete or anonymize your data to protect your privacy.

Deletion Requests:
You may request account deletion via privacy@hafrikplay.com. Your data will be permanently deleted within 30 days, except where legal obligations require retention.

To process requests related to accessing, deleting, or correcting your data, we may ask you to provide specific details associated with your HafrikPlay account. This helps us confirm your identity and ensure the security of your information.

If you do not have a HafrikPlay account, we may not have enough data to verify your identity or fulfill your request. This is because we do not store sufficient information to re-identify and link you to previous interactions with the HafrikPlay platform where data may have been collected. As a result, we may be unable to process your request.

If your request is denied, you may have the right to appeal the decision by following the instructions provided at the time of the denial.

7. Your Rights Under Data Protection Laws

Your Data Rights

As a HafrikPlay user, you have several rights regarding your personal data. You have the right to access your personal information and request a copy of the data we hold about you. For example, if you want to review your listening history or see what preferences HafrikPlay has recorded about your music taste, you can request this information from us.

If you find that any of your personal details are incorrect or incomplete, you have the right to rectification. This means that if your email address or username is outdated or incorrect, you can ask us to update it so that your account details remain accurate.

You also have the right to request the deletion of your personal data, commonly referred to as the “right to be forgotten.” For instance, if you decide to stop using HafrikPlay and want your account and all related data permanently removed, you can submit a deletion request. In some cases, instead of deletion, you may prefer to restrict the processing of your data. This could apply if you are disputing the accuracy of certain details in your profile, and you want us to temporarily stop using that data while the issue is being resolved. Additionally, you have the right to object to certain types of data processing, including targeted advertising and profiling.

If you prefer that HafrikPlay does not track your listening habits to show you personalized ads, you can opt out of such data processing. Similarly, if HafrikPlay’s AI-powered recommendations are influencing your content suggestions in a way you do not want, you can request that we stop using your data for this purpose. If you wish to transfer your data to another service, you can exercise your right to data portability. For example, if you are switching to another streaming platform and want to keep your playlists, you can request a copy of your playlist data in a format that allows you to transfer it easily.

If you ever believe that HafrikPlay has mishandled your personal data, you also have the right to lodge a complaint with a data protection authority. If, for instance, you feel your privacy rights have been violated or your requests regarding your data have not been properly addressed, you can report it to the relevant regulatory body for further investigation.

To exercise any of these rights, you can submit your request to privacy@hafrikplay.com. We are committed to responding within 30 days, in accordance with applicable data protection laws.

How to Exercise Your Rights

To make a request, contact us at privacy@hafrikplay.com. We will review and respond within 30 days, following applicable data protection laws.

8. AI, Automated Decision-Making & Profiling

HafrikPlay utilizes AI-powered analytics to enhance your experience on the platform. Our AI systems analyze your listening habits and preferences to improve content recommendations, ensuring that you discover music, podcasts, and other content tailored to your tastes. For example, if you frequently listen to Afrobeats, our AI may suggest emerging artists in that genre or create custom playlists that align with your listening history.

In addition to enhancing content discovery, AI helps us detect and prevent fraudulent activities. This includes identifying unusual login attempts, spotting fake engagement patterns, and protecting your account from unauthorized access. If, for instance, our system detects multiple failed login attempts from an unfamiliar location, we may temporarily restrict access to safeguard your account.

AI is also used to personalize advertisements, making them more relevant to you. Instead of seeing random ads, you might receive promotions for music events, exclusive merchandise, or streaming offers based on your listening habits. However, we respect your control over your data and preferences. If you prefer not to have AI-driven personalization influence your experience, you can disable this feature in your account settings at any time.

9. Security Measures

HafrikPlay is committed to ensuring the security of your personal data through a combination of advanced technical measures and strict organizational protocols. We use end-to-end encryption to safeguard sensitive transactions, ensuring that your payment details and account information remain secure. Additionally, we offer two-factor authentication (2FA) to provide an extra layer of protection for your account, preventing unauthorized access even if your password is compromised.

To further reinforce security, we conduct regular security audits and penetration testing to identify and address potential vulnerabilities before they can be exploited. Our access control and monitoring systems track and restrict unauthorized attempts to access sensitive data, ensuring that only authorized personnel can interact with critical information.

While we take extensive precautions, no system is entirely immune to security threats. Therefore, we strongly encourage users to take additional steps to protect their accounts. Using a strong, unique password, enabling 2FA, and staying vigilant against phishing scams—such as emails or messages that attempt to steal your login credentials—are essential practices to enhance your security.

10. Children's Privacy

HafrikPlay has a minimum age requirement, known as the Age Limit, which varies by country or region. The platform is not intended for children who are under the age of 13, are legally restricted from having their personal data processed, or require parental consent for data processing under local laws.

HafrikPlay does not knowingly collect or process personal data from children below the applicable Age Limit. If you are under this age, you should not use HafrikPlay or share any personal information with us. Instead, we encourage younger users to explore child-friendly alternatives.

For parents or guardians who become aware that their child under the Age Limit has provided personal data to HafrikPlay, we urge you to contact us immediately. Once verified, we will take appropriate steps to delete the child’s information. In some cases, this may require deleting the child’s HafrikPlay account entirely to comply with data protection regulations.

If you are using HafrikPlay on a shared device, we advise exercising caution when selecting content. Be mindful of what is played or recommended, ensuring that it remains appropriate for individuals under 18 years old.

Parents may contact us at privacy@hafrikplay.com for account review or deletion.

11. Changes to This Privacy Policy

We may update this policy to reflect legal or operational changes. If significant modifications occur, we will notify you via:

1. Email (if applicable)
2. In-app notification
3. Updated date at the top of this policy

Continued use of HafrikPlay constitutes acceptance of the revised policy.

12. Contact Information

For privacy inquiries, data requests, or complaints, contact:

Email: privacy@hafrikplay.com
Legal Office: 58 Olokonla Road Off Lekki Epe Expressway, Lagos State