Legal
Privacy Policy
Effective Date: May 2025
1. Overview
Wonr Technologies Limited ("Wonr", "we", "our", "us") is committed to protecting the privacy of every person who uses our platform. This Privacy Policy explains what personal data we collect, why we collect it, how it is used and stored, and what rights you have over your data.
This policy is written in compliance with the Nigeria Data Protection Regulation (NDPR) 2019 and its implementing guidelines. By using the Wonr app, you consent to the practices described in this policy.
2. Data We Collect
Account & Identity Data
- Full name, username, email address, and date of birth provided at registration.
- Bank Verification Number (BVN) or National Identification Number (NIN) for identity verification. These are processed by a licensed KYC provider and are never stored in raw form on Wonr servers.
Financial Data
- Nigerian bank account number, account name, and bank name for payout processing. We do not store card numbers or payment credentials.
Gameplay Data
- Game scores, response times, pool participation history, and leaderboard positions.
Device & Usage Data
- Device type, operating system version, app version, and anonymised usage analytics. We do not track precise location.
Communications
- Messages sent to our support team and any dispute submissions.
3. How We Use Your Data
We use your personal data for the following purposes:
- Account management: to register, verify, and maintain your account.
- Identity verification (KYC): to comply with our legal obligations and prevent fraud and underage access.
- Prize payouts: to process instant bank transfers to your linked account when you win a pool.
- Platform security: to detect and prevent fraudulent activity, cheating, and account abuse.
- Game integrity: to maintain accurate leaderboards and resolve disputes fairly.
- Product improvement: to analyse aggregated, anonymised usage data to improve the platform.
- Legal compliance: to meet our obligations under Nigerian law, including tax and financial reporting requirements.
- Communications: to send important account notifications, prize confirmations, and service updates. We do not send unsolicited marketing without your explicit consent.
4. Data Sharing & Third Parties
We do not sell your personal data. We share data only with trusted third parties strictly necessary for platform operations:
- KYC provider: processes BVN/NIN verification. Subject to their own data protection agreements.
- Payment processor: facilitates bank transfers for prize payouts. Holds a current licence from the Central Bank of Nigeria (CBN).
- Cloud infrastructure: our platform is hosted on secure, encrypted cloud servers in jurisdictions with equivalent data protection standards.
- Push notification service: delivers app notifications using anonymised device tokens.
All third-party partners are contractually obligated to process your data only for the purposes we specify. We will never share your data with advertisers or data brokers.
5. Data Retention
We retain your personal data for as long as your account is active and for a period thereafter as required by law:
- Account and transaction data: minimum 5 years after account closure to comply with Nigerian financial regulations.
- KYC records: 5 years from the date of verification.
- Gameplay data: lifetime of your account and up to 2 years thereafter.
- Support communications: 2 years.
When data is no longer needed, it is securely deleted or irreversibly anonymised.
6. Security
We implement industry-standard technical and organisational measures to protect your personal data, including:
- End-to-end encryption for all data transmitted between the app and our servers.
- AES-256 encryption for data stored at rest.
- A 4-digit withdrawal PIN required to authorise all prize payouts, separate from your login credentials.
- Optional biometric authentication and app lock for device-level security.
- Regular security audits and vulnerability assessments.
In the event of a data breach that affects your rights, we will notify you and the National Information Technology Development Agency (NITDA) within 72 hours as required by law.
7. Your Rights Under NDPR
As a data subject under the NDPR, you have the following rights:
- Right of Access: request a copy of the personal data we hold about you.
- Right to Rectification: correct inaccurate or incomplete data via your profile settings.
- Right to Erasure: request deletion of your account and associated data using the "Delete Account" option in Settings. Note that some data must be retained to fulfil legal obligations (see Section 5).
- Right to Data Portability: request your gameplay and account data in a machine-readable format.
- Right to Object: object to processing of your data for analytics purposes by contacting privacy@wonr.app.
- Right to Withdraw Consent: where processing is based on consent, you may withdraw it at any time.
To exercise any of these rights, contact privacy@wonr.app. We will respond within 30 days.
8. Push Notifications & Local Storage
The Wonr app uses push notifications to alert you to game invitations, pool results, and prize payouts. You can manage notification preferences in your device settings at any time.
We use local device storage to cache session data, security preferences (e.g. app lock status, biometric preference), and your bank list for faster access. This data does not leave your device and is cleared when you delete the app.
We do not use tracking cookies. The app does not use browser cookies as it is a native mobile application.
9. Children's Privacy
Wonr is strictly for users aged 18 and above. We do not knowingly collect personal data from individuals under 18. If we become aware that a user is under the minimum age, we will immediately terminate their account and delete all associated data.
If you believe a minor has created an account on our platform, please contact support@wonr.app immediately.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes via in-app notification at least 14 days before they take effect.
Your continued use of the platform after the effective date of any changes constitutes acceptance of the updated policy.
11. Contact & Data Controller
Wonr Technologies Limited is the data controller responsible for your personal data.
For privacy-related enquiries, data subject requests, or to report a concern:
- Privacy: privacy@wonr.app
- Support: support@wonr.app
You also have the right to lodge a complaint with NITDA (the Nigerian data protection authority) if you are not satisfied with our response.