Effective Date: June 3, 2025

FirstBy Retail Limited (“we,” “us,” or “our”) operates Classiry Nigeria at https://classiry.ng. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our classified advertising platform.

1. Information We Collect

1.1 Personal Information You Provide

When you create an account or use our services, we collect:

  • Full name and username
  • Email address and phone number
  • Physical location (city, state)
  • Account password (encrypted)
  • Profile information and photos
  • Payment information for premium services
  • Communication preferences

1.2 Listing Information

When you post classified ads, we collect:

  • Product or service descriptions
  • Images and videos
  • Pricing information
  • Contact details for inquiries
  • Location information for listings
  • Category and subcategory selections

1.3 Communication Data

We collect information when you:

1.4 Automatically Collected Information

We automatically collect:

  • IP address and device information
  • Browser type and version
  • Operating system details
  • Pages visited and time spent on site
  • Search queries and browsing patterns
  • Referral sources and exit pages
  • Date and time of visits

1.5 Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Remember your login status
  • Store your preferences
  • Analyze site traffic and usage patterns
  • Improve our services
  • Provide personalized content
  • Enable security features

2. How We Use Your Information

2.1 Primary Purposes

We use your information to:

  • Create and manage your account
  • Display your classified listings
  • Facilitate communication between users
  • Process payments for premium services
  • Provide customer support
  • Send service-related notifications

2.2 Secondary Purposes

We may also use your information to:

  • Improve our platform and services
  • Analyze user behavior and preferences
  • Prevent fraud and abuse
  • Comply with legal obligations
  • Send marketing communications (with consent)
  • Conduct research and analytics

2.3 Legal Basis for Processing

We process your personal information based on:

  • Your consent for marketing communications
  • Contract performance for service delivery
  • Legitimate business interests for platform improvement
  • Legal compliance requirements

3. Information Sharing and Disclosure

3.1 Public Information

The following information is publicly visible:

  • Your listings and descriptions
  • Username and profile information
  • Reviews and ratings you receive
  • Public messages and comments

3.2 With Other Users

We share information to facilitate transactions:

  • Contact information when users express interest in your listings
  • Communication history for customer support purposes
  • Transaction details for dispute resolution

3.3 Service Providers

We share information with trusted third parties who:

  • Process payments on our behalf
  • Provide hosting and technical services
  • Assist with customer support
  • Help with marketing and analytics
  • Support security and fraud prevention

3.4 Legal Requirements

We may disclose information when required to:

  • Comply with Nigerian laws and regulations
  • Respond to legal processes and court orders
  • Protect our rights and property
  • Ensure user safety and platform security
  • Investigate fraud or abuse

3.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, user information may be transferred to the new entity with appropriate notice.

4. Data Security

4.1 Security Measures

We implement appropriate security measures including:

  • Encryption of sensitive data in transit and at rest
  • Secure server infrastructure and regular security updates
  • Access controls and authentication systems
  • Regular security audits and monitoring
  • Employee training on data protection

4.2 Data Breaches

In the event of a data breach, we will:

  • Notify affected users within 72 hours
  • Report to relevant Nigerian authorities as required
  • Take immediate steps to secure the breach
  • Provide guidance on protective measures

4.3 User Responsibilities

You are responsible for:

  • Keeping your login credentials secure
  • Using strong, unique passwords
  • Logging out of shared devices
  • Reporting suspicious activity immediately

5. Data Retention

5.1 Active Accounts

We retain your personal information while your account remains active and for legitimate business purposes.

5.2 Inactive Accounts

Accounts inactive for more than 24 months may be deleted, with 30 days advance notice sent to your registered email.

5.3 Legal Requirements

Some information may be retained longer to comply with:

  • Nigerian legal and regulatory requirements
  • Tax and accounting obligations
  • Fraud prevention and security purposes
  • Ongoing legal proceedings

5.4 Deletion Requests

Upon account deletion, we will:

  • Remove your personal information from active systems
  • Retain minimal data required for legal compliance
  • Anonymize data used for analytics purposes

6. Your Rights and Choices

6.1 Access and Correction

You have the right to:

  • Access your personal information
  • Correct inaccurate or incomplete data
  • Update your account information at any time
  • Request a copy of your data

6.2 Communication Preferences

You can control:

  • Marketing email subscriptions
  • Push notification settings
  • SMS communication preferences
  • Newsletter subscriptions

6.3 Account Management

You may:

  • Deactivate your account temporarily
  • Delete your account permanently
  • Modify privacy settings
  • Control listing visibility

6.4 Data Portability

You can request a copy of your data in a structured, machine-readable format for transfer to another service.

7. Children’s Privacy

7.1 Age Restrictions

Classiry Nigeria is not intended for users under 18 years of age. We do not knowingly collect personal information from children under 18.

7.2 Parental Notification

If we become aware that we have collected information from a child under 18, we will delete such information immediately and notify the parents if possible.

8. International Data Transfers

8.1 Data Location

Your personal information is primarily stored and processed in Nigeria. Some service providers may process data outside Nigeria with appropriate safeguards.

8.2 Adequate Protection

When transferring data internationally, we ensure adequate protection through:

  • Contractual safeguards with service providers
  • Compliance with international data protection standards
  • Regular monitoring of data handling practices

9. Third-Party Services

9.1 External Links

Our platform may contain links to third-party websites. We are not responsible for the privacy practices of these external sites.

9.2 Social Media Integration

If you connect social media accounts, we may access limited information as permitted by your privacy settings on those platforms.

9.3 Payment Processors

Payment information is processed by third-party payment providers who maintain their own privacy policies and security standards.

10. Updates to This Policy

10.1 Policy Changes

We may update this Privacy Policy to reflect:

  • Changes in our data practices
  • New legal requirements
  • Platform improvements and new features
  • User feedback and industry best practices

10.2 Notification of Changes

We will notify you of material changes by:

  • Posting updates on our website
  • Sending email notifications to registered users
  • Providing in-app notifications
  • Updating the effective date at the top of this policy

10.3 Continued Use

Continued use of our services after policy updates constitutes acceptance of the revised terms.

11. Regional Compliance

11.1 Nigerian Laws

This Privacy Policy complies with applicable Nigerian data protection laws and regulations, including the Nigeria Data Protection Regulation (NDPR).

11.2 Data Protection Officer

For data protection inquiries, contact our Data Protection Officer at [email protected].

12. Contact Information

12.1 Privacy Questions

For questions about this Privacy Policy or our data practices:

12.2 Data Requests

To exercise your privacy rights or make data requests:

12.3 Complaints

If you have concerns about our data handling:

  • Contact us first at [email protected]
  • You may also contact the National Information Technology Development Agency (NITDA) if issues remain unresolved

13. Definitions

  • Personal Information: Any information that can identify you as an individual
  • Processing: Any operation performed on personal data, including collection, storage, use, and disclosure
  • Data Controller: FirstBy Retail Limited, as the entity determining how personal data is processed
  • Data Processor: Third parties who process data on our behalf under our instructions

Last Updated: June 3, 2025 FirstBy Retail Limited – Classiry Nigeria Website: https://classiry.ng