Privacy Policy

1. Legal Framework

Our processing of personal data is governed by the following principal Nigerian legislation:

• Nigeria Data Protection Act (NDPA) 2023: The primary data protection law establishing the Nigeria Data Protection Commission (NDPC) and governing the processing of personal data.
• NDPA General Application and Implementation Directive (GAID) 2025: Provides specific guidelines for implementing the NDPA, effective from 19 September 2025.
• Cybercrimes (Prohibition, Prevention, etc.) Act 2015: Provides safeguards against unauthorized interception of electronic communications.
• Child Rights Act 2003: Guarantees privacy protections for children (persons under 18).

2. Information We Collect

Personal Data: We collect information that identifies you, such as your name, identification number, location data, online identifier, or factors specific to your physical, physiological, genetic, psychological, cultural, social, or economic identity.

Sensitive Personal Data: We may process more sensitive categories of data, such as your racial or ethnic origin, religious beliefs, health status, sex life, or political affiliations, only with your explicit consent or as otherwise permitted by law.

3. How We Use Your Information (Legal Basis for Processing)

We process your personal data lawfully and fairly based on one or more of the following legal grounds:

• Your explicit and informed consent
• Performance of a contract to which you are a party
• Compliance with a legal obligation to which we are subject
• Protection of your vital interests or those of another person
• For the performance of a task carried out in the public interest
• For our legitimate interests, provided your fundamental rights do not override those interests

4. Your Rights Under Nigerian Law

As a data subject, you have the following rights under the NDPA 2023:

• Right to Access: You can request copies of your personal data.
• Right to Rectification: You can request correction of inaccurate or incomplete data.
• Right to Erasure (Right to be Forgotten): You can request deletion of your personal data under specific conditions.
• Right to Restrict Processing: You can request limitation of how we use your data.
• Right to Data Portability: You can receive your data in a structured, machine-readable format.
• Right to Object: You can object to the processing of your personal data.
• Right to Object to Automated Decision-Making: You have protections against decisions based solely on automated processing.

To exercise any of these rights, please contact us using the details in Section 9.

5. Data Security and Breach Notification

We implement appropriate technical and organizational security measures to prevent unauthorized access, alteration, disclosure, or destruction of your personal data, in accordance with the NDPA.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify both the Nigeria Data Protection Commission (NDPC) and you, the affected data subject, promptly as required by law.

6. Data Retention and International Transfer

Retention: We will not keep your personal data for longer than necessary for the purposes for which it was collected.

International Transfer: If we transfer your personal data outside Nigeria, we will ensure appropriate safeguards are in place as required by the NDPA and GAID, such as standard contractual clauses, binding corporate rules, or an adequacy decision by the NDPC.

7. Other Key Provisions

• We never sell or rent user data.
• All transactions are encrypted and secured with TLS 1.3.
• Cookies are used only for essential session functionality and to enhance your experience. You can control cookie settings through your browser.
• Children's Privacy: We do not knowingly collect data from children under 18 without verifiable parental consent, in compliance with the Child Rights Act.

8. Copyright and Intellectual Property

Nigeria does not have DMCA legislation. Intellectual property rights, including copyright, are protected under the Nigerian Copyright Act 2022. This Act grants creators automatic copyright protection for original literary, musical, and artistic works, including digital content, without requiring formal registration.

If you believe your copyright has been infringed upon, please contact us with details of the alleged infringement. We will address claims in accordance with the Nigerian Copyright Act.

9. Contact Information

For any questions, to exercise your data subject rights, or to report a data breach, please contact our Data Protection Officer at:

Email: privacy@flyhi.com

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), the national data protection authority.