Privacy Policy

Last updated: August 29, 2026

1. Overview & Statutory Framework

EASTSTAR SOFTWARE DEVELOPMENT LTD ("Supafluence", "we", "us", or "our") is committed to protecting your personal data in strict compliance with the Nigeria Data Protection Act (NDPA) 2023, Nigeria Data Protection Commission (NDPC) guidelines, and applicable data privacy laws across our operational markets (including the Kenya Data Protection Act 2019, Ghana Data Protection Act 2012, and South Africa POPIA 2013).

2. Data Controller & Data Protection Officer

EASTSTAR SOFTWARE DEVELOPMENT LTD is the Data Controller responsible for your personal data. We have appointed a Data Protection Officer (DPO) who can be contacted at hi@supafluence.africa.

3. Data We Collect

We collect and process the following categories of personal data:

Category	Data Elements	Source
Identity & Profile	Name, avatar, bio, gender, country, city, spoken languages.	Provided by user during registration and profile management.
Contact & Access	Email address, phone number, hashed password, session tokens.	Registration inputs and authentication services.
Commercial Metrics	Social handles, follower counts, views, engagement rates, rate cards.	Configured by creators and cross-referenced via platform audits.
Audience Data	Top countries, top cities, gender split, age ranges.	Provided via creator analytics inputs.
Business Information	Company name, website, business registration, industry.	Provided by business accounts during onboarding.
Billing Records	Transaction references, currency, subscription records. (Card details are processed securely via Paystack).	Payment gateway webhooks.

4. Lawful Bases for Processing

Under Section 25 of the NDPA 2023, we process personal data based on:

Contractual Necessity: To deliver marketplace services, match creators and brands, and process subscriptions.
Consent: Where you have opted in to specific communications or features.
Legitimate Interests: To detect fraud, ensure platform security, and improve performance.
Legal Obligation: To comply with applicable tax, statutory, and regulatory directives under Nigerian law.

5. Data Sharing & Third Parties

We do not sell personal data. We share data only with:

Marketplace Users: Public creator profiles and rate cards are visible in search directories. Deal details are shared between counterparties in the Deal Workspace.
Service Providers: Cloud database infrastructure (Supabase/AWS) and payment processing (Paystack) under data protection agreements.
Regulators & Law Enforcement: When required by valid legal process or Nigerian law.

6. Cross-Border Data Transfers

Personal data may be processed on secure cloud servers outside Nigeria. Cross-border transfers comply with Sections 41–43 of the NDPA through adequacy determinations, standard contractual clauses, or direct contractual necessity.

7. Security & Retention

We enforce TLS 1.3 encryption in transit, AES-256 encryption at rest, role-based access controls, and regular vulnerability audits. Personal data is retained for the duration of active accounts, plus statutory retention periods (e.g. 6 years for financial records under Nigerian tax law).

8. Your Statutory Rights

Under the NDPA 2023, you have the right to access, rectify, erase ("right to be forgotten"), restrict processing of, port, or object to the processing of your personal data.

To exercise your rights, email our Data Protection Officer at hi@supafluence.africa. We respond to verified requests within 30 days without charge.

9. Supervisory Authority

You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng or via email at info@ndpc.gov.ng.

10. Contact Information

EASTSTAR SOFTWARE DEVELOPMENT LTD
Contact: hi@supafluence.africa
Lagos State, Federal Republic of Nigeria

1. Overview & Statutory Framework

3. Data We Collect

We collect and process the following categories of personal data:

Category	Data Elements	Source
Identity & Profile	Name, avatar, bio, gender, country, city, spoken languages.	Provided by user during registration and profile management.
Contact & Access	Email address, phone number, hashed password, session tokens.	Registration inputs and authentication services.
Commercial Metrics	Social handles, follower counts, views, engagement rates, rate cards.	Configured by creators and cross-referenced via platform audits.
Audience Data	Top countries, top cities, gender split, age ranges.	Provided via creator analytics inputs.
Business Information	Company name, website, business registration, industry.	Provided by business accounts during onboarding.
Billing Records	Transaction references, currency, subscription records. (Card details are processed securely via Paystack).	Payment gateway webhooks.

4. Lawful Bases for Processing

Under Section 25 of the NDPA 2023, we process personal data based on:

Contractual Necessity: To deliver marketplace services, match creators and brands, and process subscriptions.

Consent: Where you have opted in to specific communications or features.

Legitimate Interests: To detect fraud, ensure platform security, and improve performance.

Legal Obligation: To comply with applicable tax, statutory, and regulatory directives under Nigerian law.

5. Data Sharing & Third Parties

We do not sell personal data. We share data only with:

Marketplace Users: Public creator profiles and rate cards are visible in search directories. Deal details are shared between counterparties in the Deal Workspace.

Service Providers: Cloud database infrastructure (Supabase/AWS) and payment processing (Paystack) under data protection agreements.

Regulators & Law Enforcement: When required by valid legal process or Nigerian law.

8. Your Statutory Rights

Under the NDPA 2023, you have the right to access, rectify, erase ("right to be forgotten"), restrict processing of, port, or object to the processing of your personal data.

To exercise your rights, email our Data Protection Officer at hi@supafluence.africa. We respond to verified requests within 30 days without charge.