Registry privacy notice

Effective date: [[EFFECTIVE DATE]] · Version: [[VERSION]]

This notice is for people who register belongings, check an item before buying, report a theft or loss, transfer an item, act as someone's witness, report a found item, or question a report on CredChek. It also covers shops that register stock and the buyers they pass records to. It follows the Nigeria Data Protection Act 2023. For our product authentication checks, see the consumer privacy policy.

Who we are

CredChek is run by [[LEGAL ENTITY NAME]] ("we"), [[REGISTERED ADDRESS]], Lagos, Nigeria, registration number [[RC NUMBER]]. We are the data controller. Our data protection officer is [[DPO NAME]], [[DPO EMAIL]], [[DPO POSTAL ADDRESS]].

The short version

Buyers see a qualified status and the item's category, brand and model. They never see who owns it.
We store phone numbers and the numbers of your belongings (IMEI, VIN, serial) as keyed fingerprints and as encrypted values.
If you verify your name, we keep a keyed fingerprint of your NIN, never the number itself.
Your theft story and police reference are encrypted. Only our review staff can read them, and we record every time they open a case.
Checks are free, and you do not need an account to check.
We do not sell your information.

What we collect and why

What	Why	Basis ([[COUNSEL]] to confirm)
Your account. Your phone number (a keyed fingerprint to find you, the encrypted number to send you codes, and the last 4 digits), your first and last name (encrypted), your email if you add and confirm one, your postal address if you add one (encrypted), your language, and the version of the terms you accepted	To let you sign in, keep a private record of your belongings, and send your certificate	Contract (the registry service you ask for) and legitimate interests (settling claims, preventing misuse)
Your witnesses. The name you give for each witness (encrypted), how you know them, a keyed fingerprint and the last 4 digits of their phone number, and whether they accepted	To protect your items: a witness must approve a transfer out of your account	Contract with you, and legitimate interests for the witness [[COUNSEL]]
Name check. Your NIN and name are sent to our identity provider to check against the national record. We keep a keyed fingerprint of your NIN, the name the check confirmed (encrypted), the result, the provider's reference, the number of attempts, and the version and time of your consent. The payment record holds the amount, status and the payment provider's reference	To give you a verified badge and a certificate, and to make sure one NIN verifies only one account	Your consent for the check [[COUNSEL]], and contract for the payment
Belongings. Category, brand, model, nickname, details you add (year, colour, purchase date, plate number), photos, and each number stored as a keyed fingerprint, an encrypted value and its last 4 characters. A history of changes (field names and last 4 characters only), and any private ownership claim	To run your record, answer checks, and settle two people registering the same number	Contract and legitimate interests
Certificates and record cards. The certificate number, the item, the registration date and, on your own copy, the name confirmed by your name check	To give verified owners a document that anyone can check	Contract
Transfers. Who asked and who owns the item, the reason, a sale price if given, approvals by you and your witness, risk signals (such as a very new account or many recent requests), the fee payment, the receipt, and any challenge	To move a record safely from one owner to the next, and to stop a stolen phone from being used to give items away	Contract and legitimate interests (preventing fraud)
Theft or loss reports. Kind and date of incident, general area, your description (encrypted), police reference (encrypted), safety flags, review state and notes, case reference	To warn buyers with a qualified status and let our staff check the report	Legitimate interests (protecting buyers and owners)
Found-item reports. The finder's phone number (encrypted, confirmed with a code), a keyed fingerprint of it, and their note (encrypted)	To let a finder reach an owner without either seeing the other's details first	Legitimate interests
Proof files. Receipts, photos and police papers you upload, saved as cleaned images in private storage	To support ownership, reports, transfers and disputes	Legitimate interests
Disputes. The statement you write (encrypted), your proof, the item, and our decision	To let a buyer or owner question a report, and for us to decide	Legitimate interests
Check receipts. The type and last 4 characters of the number checked, a keyed fingerprint of the number, the answer we gave, the matched item (if any), a keyed fingerprint of your network or phone number, the time, and the receipt reference	To give you a receipt, stop harvesting, and count checks	Legitimate interests (preventing misuse)
Shops and their buyers. For a shop: the business name, email, phone number and address (address encrypted), a password stored only as a one-way hash, its plan and payments, and its stock records. For a buyer a shop names: their name, phone number and optional email (all encrypted) and a keyed fingerprint of the phone number	To let shops register stock and pass each record to the buyer, who accepts with their own phone	Contract with the shop; legitimate interests for the buyer [[COUNSEL]]
Messages. Short texts and emails with codes, the item name and a reference. We never put a full number, a place or another person's details in a text	To send codes and tell you about decisions, transfers and witness requests, and, if you opt in, when someone checks your reported item	Legitimate interests; your consent for the check alert
Donations. Amount, currency, status and the payment provider's reference. If we hold your confirmed email, we pass it to the provider for your receipt	To record and reconcile your gift	Contract, and legal obligation for financial records [[COUNSEL]]

We also keep a log of sensitive actions, such as signing in, reporting, transferring and staff decisions.

You can check an item without an account. We then see only your network address or phone number, and we keep it as a keyed fingerprint.

Who sees what

Buyers see the qualified status, how far the report was checked, the category, brand and model, the report month, a case reference and the last update date. The number they typed is shown masked. They never see owner details, your story, your area or your files.
Anyone checking a certificate sees that it is genuine and the item it covers. They never see the owner's name or contact details.
Your witnesses see your name, the last 4 digits of your phone number and, when they are asked to approve a transfer, the item, the reason, any sale price, and the recipient's name and last 4 digits.
The person you transfer to sees the item and the transfer's progress, not your phone number.
A finder never sees who you are. You see the finder's number only if you choose to contact them.
A shop sees the buyer details it entered. The buyer sees the shop's name and the items.
The registered owner is never told who checked or who questioned a report.
The person who questions a report never learns who the owner is.
Our review staff see the report, story, police reference, transfer details and proof files for cases they handle. They see only the last 4 digits of an owner's phone number. Opening a case is recorded in our audit log. Only staff with the review permission can open cases.
Other staff see counts, not who made them.

We do not sell your information. We use providers who work for us under contract:

hosting and storage: Hetzner (Germany) and Cloudflare, including file storage;
codes and texts: WhatsApp (Meta) and our SMS provider [[SMS PROVIDER, CONFIRM]];
email: [[EMAIL PROVIDER, CONFIRM]];
name checks: our identity provider [[IDENTITY PROVIDER, CONFIRM]], which checks against the national identity record;
payments for name checks, transfer fees, shop plans and donations: our payment provider [[PAYMENT PROVIDER, CONFIRM]].

The current list is at [[SUBPROCESSORS URL]]. We may also share information with the police or a court when the law requires it, or to protect someone from harm, after checking the request is lawful [[COUNSEL]].

Transfers outside Nigeria

Our servers are in Germany. Some providers work in the United States or elsewhere. We use safeguards the law recognises, such as contract terms [[COUNSEL TO CONFIRM mechanism for each provider]].

How long we keep information

Information	How long
Check receipts	Until the receipt expires, then deleted. The expiry is a setting we control
Found-item reports	Deleted after a set time [[COUNSEL: confirm the period]]
Unpaid name-check payments	Deleted after a set time. Paid ones stay as accounting records, without your NIN or name
Transfer payment references and receipt files	Deleted a set time after the transfer closes
Registrations, reports, transfers, disputes and the history of changes	We keep the history so people cannot wipe a record to make an item look clean. [[COUNSEL: period]]
Proof files	You can remove a file until it is used in a report, transfer or dispute. After that it stays with that record [[COUNSEL: period]]
Account details	While your account is open. When you close it we erase the full item numbers and keep only keyed fingerprints. [[COUNSEL: period for the rest]]
Name-check records	[[COUNSEL: period]]
Donation and payment records	[[COUNSEL: financial record period]]

Your rights

Under the Nigeria Data Protection Act 2023 you can ask us for a copy of your information, to correct it, to delete it, to restrict or object to how we use it, and to withdraw consent. You can complain to the Nigeria Data Protection Commission ([[NDPC CONTACT]]) [[COUNSEL: confirm the full list of rights and how each applies here]].

How to ask: download a copy of your data or close your account from your account page. For anything else, write to [[DPO EMAIL]]. We reply within [[COUNSEL: statutory period]].

Some requests have limits. We cannot delete the history of a report, transfer or decision that other people may rely on, or records the law makes us keep [[COUNSEL]]. A published theft report stays visible for a set time after you close your account, without any link to you. We can still correct mistakes and hide personal details where we can.

Safety flags and your safety

When you report a theft, you can tell us you fear retaliation or do not want to be contacted. Our review staff see these flags. We never show buyers your story, area or number. Texts we send never name a place or another person. Do not approach anyone yourself. If you are in danger, call the police.

Children

CredChek is for people aged [[MINIMUM AGE, COUNSEL TO CONFIRM]] and over. If you think a child gave us personal information, contact us and we will deal with it.

How we protect information

Phone numbers, belongings' numbers, names, addresses, stories, police references and statements are encrypted. We also keep keyed fingerprints so we can match numbers without storing them in the clear.
We never store your NIN, only a keyed fingerprint of it.
Each owner's records are kept apart in the database, so one owner cannot read another's. Shops can read only their own records.
Sensitive actions, such as reporting a theft, approving a transfer or changing your witnesses, need a fresh code sent to your phone.
Photos and proof files are re-saved without hidden metadata, kept private and opened only through short-lived links.
Staff access depends on role, and case views are recorded.
Checks are limited per person and per network, and we watch for mass harvesting of numbers.
All traffic is encrypted in transit.

No system is perfectly secure. If a breach puts you at risk, we will tell you and the regulator as the law requires [[COUNSEL]].

Changes

We will post changes here with a new date. If a change is significant, we will tell you in the app or on the website first.

Contact

[[LEGAL ENTITY NAME]] · [[DPO EMAIL]] · [[POSTAL ADDRESS]]

CredChek registry privacy notice