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Data Protection & Confidentiality Charter

Privacy Policy

At Wasanni, your privacy and data sovereignty are fundamental. This document outlines how Wasanni Limited collects, protects, retains, and processes your personal information in strict adherence to the Nigeria Data Protection Act 2023 (NDPA) and international privacy standards.

Effective Date: October 2026 • Regulatory Jurisdiction: Federal Republic of Nigeria • Data Controller: Wasanni Limited (Abuja, Nigeria)
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Table of Contents

01. Data Controller Information 02. Categories of Data Collected 03. Lawful Bases for Processing 04. Financial Data & Payment Security 05. Third-Party Data Disclosures 06. Technical Security Safeguards 07. Your Statutory Rights 08. Data Retention Schedules 09. Cross-Border Cloud Transfers 10. Automated Pitch Logic 11. Breach Response Protocols 12. Frequently Asked Questions 13. Contact Administration

1. Data Controller Information

Wasanni Limited ("Wasanni", "we", "us", or "our"), incorporated and registered in Abuja, Nigeria, acts as the primary Data Controller responsible for the processing and protection of personal data collected through wasanni.com.ng.

Regulatory compliance and data governance operations are supervised directly by the Wasanni Administrator. For supervisory questions, compliance notices, or statutory rights requests under the Nigeria Data Protection Act, you may reach our administrative desk directly via email at support@wasanni.com.ng or through our dedicated in-app Support Section.

2. Categories of Personal Data Collected

We collect personal data directly from you when you register, communicate, deposit funds, or interact with stadium matches. The categories of information include:

A. Identity & Profile Data

Full name, chosen username, unique Wasanni ID (WSN ID), email address, pledged club loyalty, profile avatar photo, and account status.

B. Financial & Transactional Data

Deposit transaction references, diamond purchase tiers, withdrawal destination bank name, 10-digit NUBAN account number, and resolved beneficiary account name. Note: Wasanni never stores, processes, or captures your debit card numbers, PINs, or CVV codes.

C. Pitch Performance & Gamification Records

Player Power rating, stadium attack strikes, defensive clearance actions, yellow/red card penalty logs, tournament match minutes, and community post contributions.

D. Technical & Device Information

Internet Protocol (IP address), browser type and version, operating system, network latency metrics, and essential session authentication cookies.

3. Legal Bases & Purposes of Processing

Under Section 25 of the Nigeria Data Protection Act 2023, Wasanni processes your personal data on the following lawful bases:

  • Performance of Contract: To operate your account, verify pitch participation, credit vault balances, and deliver tournament prize payouts pursuant to our Terms and Conditions.
  • Legal & Regulatory Obligation: To satisfy anti-money laundering (AML), fraud detection, and tax reporting requirements established by Nigerian financial authorities and the Central Bank of Nigeria (CBN).
  • Legitimate Interests: To secure the platform against bot attacks, enforce fair play algorithms, optimize page rendering speeds, and investigate community misconduct.
  • Explicit Consent: Where you provide consent for optional communications or browser push notifications, which you may withdraw at any time.

4. Financial Data Security & Payment Partners

Financial security on Wasanni is conducted in partnership with licensed payment switches compliant with the Payment Card Industry Data Security Standard (PCI-DSS Level 1).

When you purchase Diamond packs or deposit Naira, transactions are executed seamlessly within our secure in-app modal using bank-grade 256-bit encryption. Wasanni receives only cryptographic reference tokens, transaction amounts, and webhook notifications authenticated via HMAC-SHA256 signatures. At no point do Wasanni servers hold or inspect full card numbers or sensitive authentication PINs.

5. Third-Party Disclosures

Wasanni does not sell, rent, or monetize your personal data to commercial data brokers. We disclose data solely to:

  • Licensed Payment Switches: Korapay and NIBSS to execute automated bank settlements.
  • Hosting Infrastructure Providers: Managed server providers operating secure tier-3 data facilities with strict confidentiality covenants.
  • Law Enforcement & Regulatory Authorities: When compelled by valid legal subpoenas, court orders, or statutory mandates issued by Nigerian judicial bodies.

6. Technical Security Safeguards

We deploy defense-in-depth measures to safeguard personal data against unauthorized disclosure, interception, or destruction:

  • Transport Layer Security: All data transmissions are encrypted using modern TLS 1.3 encryption with high-grade cipher suites.
  • Credential Hashing: User passwords are encrypted using one-way cryptographic Bcrypt hashing algorithms with work factor hardening. Passwords are mathematically irrecoverable in plaintext.
  • Strict Access Controls: Administrative database access is restricted through multi-factor authenticated bastions and logged in immutable administrative audit trails.

7. Your Statutory Rights Under the NDPA 2023

As a data subject, you hold statutory rights enforceable under the Nigeria Data Protection Act 2023:

Right of Access:

Request a copy of the personal data held about your account.

Right to Rectification:

Correct inaccurate or incomplete profile and financial data.

Right to Erasure ("To Be Forgotten"):

Request the deletion of your account and personal records where lawful retention obligations allow.

Right to Object:

Object to processing based on legitimate interests or direct marketing.

To exercise any of these rights, submit a written request to the Wasanni Administrator at support@wasanni.com.ng or open a confidential support ticket in our Support Desk. We respond to all verified statutory requests within thirty (30) days.

8. Data Retention Schedules & Storage Boundaries

We retain personal data only for as long as your account remains active or as required to fulfill operational, legal, and regulatory requirements. Our data retention timetable operates under the following criteria:

Account Credentials & Profile Data Duration of active account + 30 days post-deletion
Financial Transactions & Payout Records 5 Years (Mandatory CBN & Tax AML Statutes)
Stadium Match Strikes & Tournament History Indefinite seasonal archives (anonymized upon user departure)
Support Desk Tickets & Resolutions 24 Months post ticket resolution

9. Cross-Border Data Transfers & Cloud Facilities

Wasanni hosts primary databases and real-time gaming services within secure cloud data centers. In instances where technical processing or payment verification necessitates data transmission across international borders, we ensure compliance with Section 41 of the Nigeria Data Protection Act (NDPA 2023).

Such transfers are governed by international adequacy decisions, Binding Corporate Rules (BCRs), or Standard Contractual Clauses (SCCs) that guarantee recipients enforce protections comparable to Nigerian data protection legislation and the General Data Protection Regulation (GDPR).

10. Automated Match Simulation & Decision Logic

During live fixtures on the Stadium Pitch, match outcomes are simulated using algorithmic mathematical models. These models evaluate aggregate player ratings, team formations, and live participant actions. This computational logic is strictly confined to in-game sports mechanics and carries no legal or discriminatory impact on your person outside the virtual sports arena.

11. Incident Response & Breach Notification

In the improbable event of a security incident that compromises the confidentiality, integrity, or availability of personal data, Wasanni maintains a certified Incident Response Protocol. In accordance with statutory directives, we implement immediate containment and notify affected users directly via registered email with clear mitigation recommendations.

12. Frequently Asked Questions

Can Other Users See My Private Bank Account Information?

No. Your bank account details, 10-digit NUBAN numbers, and withdrawal ledgers are completely confidential and accessible only to you and authorized financial compliance controllers. Other club members, captains, and visitors can never see your private banking information.

Is My Email Address Visible To Other Players On The Platform?

No. Your email address is kept strictly private and used exclusively for account authentication, password recovery, and security alerts. Only your chosen username, display name, and club badge are displayed publicly on community posts and match lineups.

How Can I Submit A Request For Complete Account Erasure?

You may submit an account erasure request by emailing the Wasanni Administrator at support@wasanni.com.ng or creating a ticket in our Support Desk. Your profile, feed posts, and personal details will be expunged from production systems within thirty (30) days.

How Long Does Wasanni Retain Transaction And Audit Logs?

Pursuant to Nigerian anti-money laundering (AML) and financial record-keeping regulations overseen by the Central Bank of Nigeria, transactional and payout logs are retained in encrypted, immutable archives for five (5) years before automated archival purges occur.

How Are Financial Payments Protected During In-App Checkout?

All deposits and diamond vault purchases take place within a secure in-app modal powered by licensed PCI-DSS Level 1 compliant switches. Your payment credentials never touch or reside on our servers; transactions are verified via end-to-end cryptographic tokens and signed webhooks.

13. Data Protection Administration & Inquiries

If you have questions regarding this Privacy Policy, wish to exercise statutory data rights, or need assistance regarding your personal records, please reach our administrative office:

Data Protection Officer: Wasanni Administrator
Email: support@wasanni.com.ng
Headquarters: Abuja, Nigeria
In-App Support: Open Support Ticket