Privacy Policy

Effective date: 12th December 2025

Welcome to Creatify (collectively referred to as "Creatify", "we", "us", or "our").

PRIVACY POLICY

We are Creatify, a Private Limited Company, respect your privacy and are committed to protecting your Personal Data. This Privacy Policy explains how we manage your Personal Data when you visit the Creatify App, your privacy rights, and how the law protects you.

We maintain this application as a service to our staff and customers. By using our application, you are agreeing to comply with and be bound by the following Privacy Policy. Please review the following carefully. If you do not agree to this policy, you should not use this application.

Introduction

Creatify is a marketplace application that connects Creators (e.g., photographers, stylists, editors) with Recruiters (brands, agencies, individuals). This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, how long we keep it, and your rights under applicable law including the Nigerian Data Protection Act (NDPA).

Controller and contact

Creatify is the data controller of personal data processed through the app and related services. For privacy enquiries or to exercise your data rights, contact:

  • Email: [email protected]

Scope

This Policy applies to all users of Creatify (Creators, Recruiters and visitors) and to personal data processed through our mobile and web applications, APIs, emails, payment processors and related services.

Key definitions

  • Personal data – information that identifies or can identify a living person
  • Sensitive data – special categories such as biometric data
  • Aggregated data – anonymised data used for analytics. Aggregated data alone is not personal data

Personal data we collect and sources

We collect personal data you provide directly, data collected automatically when you use our platforms, and data from third parties. Categories include:

  • Identity: name, title, date of birth, BVN and similar identifiers
  • Contact: email, telephone, billing and service addresses
  • Profile and portfolio: skills, experience, availability, profile photos, portfolio media
  • Financial and transaction: bank account details, transaction metadata from payment processors (we do not store CVV)
  • KYC and verification: identity documents, selfie/liveness checks and verification outcomes supplied by verification vendors
  • Technical and usage: IP address, device type, OS, browser, app version, crash logs, pages visited, search and booking behaviour, timestamps, referral data
  • Location: approximate by IP; precise only if you enable location services
  • Communications: messages, support tickets, and marketing preferences

Third-party sources

We receive data from payment processors, verification vendors, and email/SMS delivery providers, and from any external services you connect to Creatify.

Aggregated data

We may aggregate and anonymise data for product improvement and analytics. If aggregated data is re-linked to identify an individual, we treat it as personal data.

Purposes and lawful bases for processing

We process personal data for the following purposes, with the listed lawful bases where applicable:

  • Provide and administer the service: account management, bookings, payments (contract performance).
  • KYC, fraud prevention and safety: identity verification, platform security and legal compliance (legal obligation and legitimate interests).
  • Payments and billing: process fees, subscriptions, refunds (contract performance).
  • Product improvement and personalisation: search ranking, recommendations and analytics (legitimate interests).
  • Communications: transactional messages and marketing where you consent (consent / legitimate interests).
  • Legal and compliance: respond to lawful requests, enforce Terms and defend rights (legal obligation / legitimate interests).

When processing sensitive data such as biometrics we obtain explicit consent or rely on permitted legal grounds and safeguards.

Sharing and disclosure

We disclose personal data only as necessary for the above purposes and only to:

  • Other users: public profile items (name, portfolio, rates, availability, ratings) and booking-relevant information visible to Recruiters; sensitive data (full bank details) are not shown to other users.
  • Service providers and processors: hosting, storage, analytics, payment processors, verification providers, communications providers and support vendors acting under contract and only on our instructions.
  • Legal or safety purposes: law enforcement, regulators, or to prevent fraud or imminent harm.
  • Business transactions: in connection with corporate restructuring, merger or sale — we will notify affected users where required.
  • With your consent: where you authorise sharing or integrate third-party services.

We require vendors to implement appropriate security measures and contractual safeguards.

International transfers

Your data may be stored or processed outside Nigeria. We ensure transfers comply with NDPA requirements and use appropriate safeguards such as standard contractual clauses, binding corporate rules, or other NDPC-approved mechanisms as applicable.

Retention

We retain personal data only as long as necessary to provide services, comply with legal and regulatory obligations (including AML/tax), resolve disputes and enforce agreements. Account data is retained while your account is active. KYC and transaction records are retained in line with regulatory retention requirements. When you delete your account we will remove or anonymise personal data except where retention is required by law or necessary for fraud prevention and legitimate business purposes.

Security

We apply administrative, technical and physical safeguards such as encryption in transit, access controls, secure hosting and monitoring to protect data. No system is completely secure; you share responsibility for securing your credentials and devices.

Cookies and similar technologies

We use cookies, SDKs and similar technologies for authentication, security, performance, analytics and personalisation. You can manage cookie preferences via your browser or device settings; disabling some cookies may limit functionality.

Biometric processing and verification

We may use third-party providers for biometric verification. We obtain explicit consent prior to biometric processing. Creatify receives only verification results and limited metadata; we do not retain raw biometric templates. Verification may be required to access certain features such as payouts or certain bookings.

Children

Our services are not directed at persons under 18. We do not knowingly collect personal data from children under 18. If we learn we have collected such data we will delete it and take other steps required by applicable law.

Automated decision-making and profiling

We may use automated systems for search ranking, recommendations, fraud detection and verification scoring. If an automated decision has a legal or similarly significant effect on you, you may request human review and information about the decision.

Your rights

Subject to applicable law you may have rights to: be informed, access, rectify, erase, restrict processing, object to processing, data portability, and withdraw consent. To exercise rights contact [email protected]. We will verify identity and respond in line with NDPA timelines. If dissatisfied you may lodge a complaint with the Nigeria Data Protection Commission.

Consequences of not providing data

If you refuse or withdraw personal data required for core functions (e.g., identity verification or payment details), we may be unable to create your account, process payments or enable certain features.

Third-party links and embedded content

Our services may link to third-party sites or embed third-party content. We are not responsible for their privacy practices. Review their privacy policies before using those services.

Changes to this Policy

We may update this Policy to reflect changes in law, features or operations. Material changes will be communicated via in-app notice or email where feasible. Continued use after changes indicates acceptance.

Contact and supervisory authority

For privacy enquiries or to exercise your rights contact [email protected]. If unsatisfied with our response you may complain to the Nigeria Data Protection Commission.

© 2025 Creatify. All rights reserved.