Privacy Policy

PAYFLUENCE PRIVACY POLICY

Effective date: 1 August 2026 Last updated: 1 August 2026

PayFluence is operated by Fluence Social Network Ltd, a Nigerian private company limited by shares with registration number RC 9620018. The company was incorporated on 17 June 2026.

Company details

Legal name: Fluence Social Network Ltd Trading name: PayFluence RC number: 9620018 Registered address: No. 2, Aanuoluwapo Street, Ogo-Oluwa, Osogbo, Osun State, Nigeria Email: temitopejoshua@payfluence.com.ng Website: www.payfluence.com.ng

The registered address, official email and principal digital-marketing business activity are taken from the company’s CAC status report.

This Privacy Policy has been prepared with reference to the Nigeria Data Protection Act 2023 and applicable guidance from the Nigeria Data Protection Commission. The NDPC identifies rights including access, rectification, objection, restriction, portability, erasure and protection from solely automated decision-making.

1. Introduction

Fluence Social Network Ltd, trading as PayFluence, respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how PayFluence collects, uses, stores, shares, transfers, protects and deletes personal data when you access or use:

• The PayFluence website;
• The PayFluence mobile or progressive web application;
• Tasker dashboards;
• Customer and business dashboards;
• Celebrity, creator and influencer profiles;
• Campaign, booking and payment services;
• Referral and community programmes;
• Support channels;
• WhatsApp groups or other authorised PayFluence communication channels; and
• Any other product or service operated under the PayFluence name.

This Privacy Policy applies to:

• Taskers;
• Product testers;
• Business customers;
• Campaign owners;
• Celebrities;
• Creators;
• Influencers;
• Public personalities;
• Referral partners;
• Community leaders;
• Website visitors;
• Prospective users;
• Contractors and service providers; and
• Any person who interacts with PayFluence.

By creating an account or using PayFluence, you acknowledge that you have read this Privacy Policy.

2. Who controls your personal data

For the purposes of the Nigeria Data Protection Act 2023, the controller responsible for your personal data is:

Fluence Social Network Ltd Trading as PayFluence RC number: 9620018 Registered address: No. 2, Aanuoluwapo Street, Ogo-Oluwa, Osogbo, Osun State, Nigeria Privacy email: temitopejoshua@payfluence.com.ng

PayFluence may also act as a data processor where a customer determines the purpose of a campaign and PayFluence processes personal data on the customer’s instructions.

In some circumstances, PayFluence and a customer may each act as independent data controllers for the information they separately collect and use.

3. Meaning of important terms

For this Privacy Policy:

“PayFluence,” “we,” “us” or “our” means Fluence Social Network Ltd and the PayFluence platform.

“User” or “you” means any person who visits, registers for or uses PayFluence.

“Tasker” means a user who accepts and completes paid or unpaid tasks through PayFluence.

“Customer” means a person, business, organisation, founder, brand or agency that creates or funds a task, campaign, test or booking.

“Celebrity User” means an approved celebrity, creator, influencer, public personality, athlete, entertainer or other person who offers services through PayFluence.

“Campaign” means a task, test, promotional engagement, survey, content assignment, creator booking or other service arranged through PayFluence.

“Personal data” means information relating to an identified or identifiable person.

“Sensitive personal data” includes information that receives enhanced legal protection, such as health, biometric, genetic, religious, political or sexual-life information.

“Processing” includes collecting, recording, organising, storing, using, sharing, altering, retrieving, restricting, deleting or destroying personal data.

4. Eligibility and age restrictions

PayFluence is intended for users who are at least 18 years old and legally capable of entering into a binding agreement.

By registering, you confirm that:

• You are at least 18 years old;
• The information you provide is accurate;
• You are legally permitted to use the service; and
• You are not creating an account for another person without authority.

PayFluence does not knowingly permit children under 18 to:

• Complete paid tasks;
• Create customer campaigns;
• Receive task earnings;
• Request withdrawals;
• Offer celebrity or creator services;
• Enter paid bookings; or
• Conduct payment transactions.

Where we reasonably believe that a user is under 18, we may request age verification, restrict the account, suspend transactions or close the account.

A parent or guardian who believes that a child has provided personal data to PayFluence may contact us at temitopejoshua@payfluence.com.ng.

5. Personal data we collect

The information we collect depends on your role and how you use PayFluence.

5.1 Account information

We may collect:

• Full name;
• Username;
• Email address;
• Telephone number;
• WhatsApp number;
• Password or encrypted authentication details;
• Profile photograph;
• Date of birth or age confirmation;
• Gender, where relevant and voluntarily provided;
• Country, state, city or general location;
• Occupation;
• School or educational category;
• Interests and skills;
• Account type;
• Referral code;
• Referrer information;
• Communication preferences;
• Verification status;
• Account status;
• Warnings, restrictions and suspension records; and
• PayFluence user identification number.

Passwords should be stored in encrypted or hashed form. PayFluence does not need to know or display your plain-text password.

5.2 Identity-verification information

We may collect or review:

• Government-issued identification;
• Voter’s card, national identity information, driver’s licence, passport or other accepted identification;
• Selfies;
• Verification photographs;
• Video-verification records;
• Live-call or Google Meet verification information;
• Name-matching information;
• Proof of business registration;
• Social-media account ownership evidence;
• Bank-account ownership information;
• Address confirmation, where reasonably necessary;
• Information used to detect duplicate accounts;
• Information used to detect impersonation; and
• Information required to recover a compromised account.

We may require enhanced verification before:

• Processing a withdrawal;
• Approving a celebrity profile;
• Approving a business customer;
• Allowing a high-value campaign;
• Restoring a restricted account;
• Changing sensitive account information;
• Resolving an identity dispute; or
• Releasing funds connected to suspected fraud.

PayFluence does not intend to create facial-recognition templates unless this is clearly disclosed, legally justified and supported by appropriate consent or another lawful basis.

5.3 Tasker and testing information

When you apply for or complete tasks, we may collect:

• Task applications;
• Task eligibility information;
• Device type;
• Device model;
• Operating system;
• Browser;
• Application version;
• Internet or network information;
• Task start and completion time;
• Slot reservation information;
• Task status;
• Screenshots;
• Screen recordings;
• Photographs;
• Videos;
• Audio recordings;
• Written answers;
• Survey responses;
• Ratings;
• Product feedback;
• Bug reports;
• Testing notes;
• Usability observations;
• Review or post links;
• Content-submission links;
• Proof of task completion;
• Correction requests;
• Resubmissions;
• Approval or rejection decisions;
• Quality scores;
• Dispute records;
• Payment eligibility; and
• Relevant communication between the tasker, PayFluence and the customer.

Taskers must avoid including unrelated personal information belonging to another person in task evidence.

5.4 Customer and campaign information

When a customer creates or funds a campaign, we may collect:

• Customer name;
• Business or brand name;
• Business contact details;
• Business-registration information;
• Campaign title;
• Campaign objective;
• Product or service information;
• Target audience;
• Eligibility requirements;
• Campaign instructions;
• Campaign budget;
• Number of required participants;
• Start and end dates;
• Links, documents and campaign assets;
• Survey questions;
• Testing scenarios;
• Reporting requirements;
• Payment information;
• Refund information;
• Complaints and disputes;
• Customer feedback;
• Campaign performance information; and
• Communication with taskers, creators or PayFluence.

Customers must not create tasks that unnecessarily request passwords, one-time passwords, card PINs, recovery codes, private financial credentials or unrelated sensitive personal data.

5.5 Celebrity, creator and influencer information

When a user applies to become a Celebrity User, we may collect:

• Legal name;
• Public or stage name;
• Biography;
• Profile description;
• Profile photograph;
• Promotional photographs or videos;
• Profession;
• Industry or category;
• Social-media usernames;
• Social-media profile links;
• Audience size;
• Engagement information;
• Account-verification information;
• Identity-verification documents;
• Video-call or Google Meet verification details;
• Supported social-media platforms;
• Services offered;
• Service duration;
• Availability;
• Rates and prices;
• Content restrictions;
• Brand preferences;
• Audience categories;
• Previous work;
• Ratings;
• Reviews;
• Booking history;
• Performance records;
• Payout information;
• Tax information, where required;
• Content-licensing preferences; and
• Publicity and usage permissions.

Public celebrity profiles may display:

• Public name;
• Profile photograph;
• Biography;
• Professional category;
• Social-media links;
• Follower or audience information;
• Verification badge;
• Services;
• Prices;
• Ratings;
• Reviews; and
• General availability.

Private identity documents, payout information and internal fraud records will not be displayed publicly.

5.6 Celebrity service and duration-monitoring data

PayFluence may collect evidence showing whether a Celebrity User has completed and maintained an agreed action for the required duration.

This may include:

• Date and time a follow was completed;
• Date and time a comment, post or engagement was published;
• Screenshots;
• Public profile information;
• Links to the relevant account or content;
• Scheduled end date;
• Evidence that an action remains active;
• Evidence that a follow was removed;
• Evidence that content was deleted, hidden or archived;
• Evidence that a comment, like, mention or share was reversed;
• Evidence of account suspension by a third-party platform;
• Customer complaints;
• Celebrity explanations;
• Service-monitoring results;
• Refund or payment-reversal records; and
• Dispute-resolution information.

We use this information to determine whether the Celebrity User maintained the service for the agreed period, such as:

• One hour;
• One day;
• One week;
• One month;
• One year;
• Another fixed duration; or
• An ongoing or indefinite period, where legally and contractually valid.

A Celebrity User’s duty not to unfollow, delete, hide, archive or reverse an agreed action before the agreed date is governed principally by the PayFluence Celebrity and Creator Terms, not by this Privacy Policy.

However, this Privacy Policy explains that PayFluence may process monitoring and evidence data to enforce that obligation, release or reverse payment, investigate disputes and protect customers.

5.7 Celebrity bookings and meetings

For creator campaigns, calls, appearances, promotional videos, shout-outs, live sessions or meetings, we may collect:

• Customer and Celebrity User identities;
• Booking date and time;
• Duration;
• Campaign brief;
• Meeting link;
• Communication platform;
• Discussion topic;
• Participant information;
• Brand assets;
• Recording permissions;
• Publication permissions;
• Content-reuse rights;
• Delivery evidence;
• Revision requests;
• Attendance information;
• Cancellation reasons;
• Refund requests; and
• Disputes.

PayFluence will not record a private meeting unless recording is disclosed and supported by a lawful basis.

5.8 Payment, earnings and withdrawal information

We may collect or generate:

• Customer payments;
• Campaign deposits;
• Wallet balances;
• Task earnings;
• Referral bonuses;
• Leadership bonuses;
• Celebrity earnings;
• Platform fees;
• Service commissions;
• Withdrawal requests;
• Withdrawal status;
• Bank name;
• Bank-account number;
• Bank-account name;
• Payment-provider information;
• Transaction references;
• Payment dates;
• Refunds;
• Reversals;
• Chargebacks;
• Failed payments;
• Fraud indicators;
• Tax or accounting information; and
• Records relating to payment disputes.

Payments may be processed by third-party payment providers, banks or financial-technology companies.

Where a payment provider collects card details directly, PayFluence may receive only a transaction reference, status, amount and limited account information rather than complete card details.

PayFluence will never ask a user to provide a card PIN, bank PIN or one-time password through a task or support conversation.

5.9 Referral and community information

Where you use a referral link or participate in a community programme, we may collect:

• Referrer identity;
• Referred-user identity;
• Referral code;
• Date of referral;
• Account-registration status;
• Task qualification status;
• Referral earnings;
• Leadership assignment;
• Community group;
• Support activity;
• Referral-abuse indicators; and
• Dispute information.

Community leaders may receive limited information necessary to guide users or confirm referral eligibility.

They must not receive access to users’ passwords, bank security credentials, identity documents or private support information unless specifically authorised and legally justified.

5.10 Communication and support information

We may collect:

• Emails;
• Support tickets;
• WhatsApp messages sent to official PayFluence channels;
• In-platform messages;
• Complaint details;
• Appeal information;
• Reports of misconduct;
• Security reports;
• Call details;
• Meeting information;
• User feedback;
• Survey responses;
• Notification history; and
• Records of communication with authorised PayFluence staff or representatives.

5.11 Technical and usage information

When you access PayFluence, we may automatically collect:

• Internet Protocol address;
• Browser type;
• Browser version;
• Device type;
• Device identifiers;
• Operating system;
• Application version;
• Login dates and times;
• Session duration;
• Pages and features used;
• Referral source;
• Approximate location derived from IP address;
• Error logs;
• Diagnostic information;
• Security events;
• Failed-login attempts;
• Cookie identifiers;
• Multiple-account indicators;
• Device-account relationships;
• Suspicious-access information; and
• Performance and analytics information.

We may use such information to secure the platform, improve performance, distribute tasks, prevent duplicate accounts and detect fraud.

5.12 Information from third parties

We may receive information from:

• Payment providers;
• Banks;
• Identity-verification providers;
• Google authentication;
• Social-media platforms;
• App stores;
• Customers;
• Referrers;
• Community leaders;
• Hosting and security providers;
• Analytics providers;
• Publicly available profiles;
• Law-enforcement authorities;
• Regulators; and
• Other service providers supporting PayFluence.

We will only use information received from third parties where we have an appropriate lawful basis.

6. Sensitive personal data

PayFluence will only process sensitive personal data where it is necessary, proportionate, secure and supported by an appropriate lawful basis.

Sensitive data may include information concerning:

• Health;
• Religious or philosophical beliefs;
• Political opinions;
• Trade-union membership;
• Sexual orientation or sexual life;
• Genetic information;
• Biometric information used for identification;
• Criminal allegations or convictions; and
• Other categories protected under applicable law.

Customers must not create a campaign that requests sensitive personal data unless:

• The collection is strictly necessary;
• PayFluence has reviewed the campaign;
• The user has received clear notice;
• An appropriate lawful basis exists;
• Appropriate safeguards are implemented; and
• All regulatory requirements are satisfied.

Taskers should not upload another person’s sensitive information as task evidence.

7. How we use personal data

We may use personal data to:

7.1 Provide and manage accounts

• Register users;
• Authenticate logins;
• Maintain user profiles;
• Confirm eligibility;
• Manage account roles;
• Recover accounts;
• Verify identities;
• Process profile changes; and
• Communicate important account information.

7.2 Operate tasks and campaigns

• Display available tasks;
• Match users with eligible tasks;
• Allocate task slots;
• Monitor task deadlines;
• Receive submissions;
• Review evidence;
• Request corrections;
• Approve or reject tasks;
• Prevent duplicate submissions;
• Generate customer reports;
• Calculate earnings; and
• Resolve task disputes.

7.3 Operate product and website testing

• Assign testers;
• Record device categories;
• Collect bug reports;
• Review user feedback;
• Measure participation;
• Compile reports;
• Provide approved results to customers; and
• Confirm whether task requirements were completed.

7.4 Operate celebrity and creator services

• Review applications;
• Verify identity;
• Verify social-media account ownership;
• Publish approved public profiles;
• Display services and rates;
• Facilitate bookings;
• Deliver campaign instructions;
• Monitor service duration;
• Confirm completion;
• Detect early removal or reversal of an action;
• Release, hold or reverse payment;
• Process refunds;
• Resolve complaints;
• Manage ratings and reviews; and
• Protect customers and Celebrity Users.

7.5 Process payments and withdrawals

• Accept customer payments;
• Fund campaigns;
• Record wallet balances;
• Calculate earnings;
• Calculate commissions and fees;
• Process withdrawals;
• Verify bank details;
• Process refunds;
• Handle chargebacks;
• Investigate suspicious transactions;
• Maintain financial records; and
• Meet legal and accounting obligations.

7.6 Prevent fraud and platform abuse

We may use personal data to detect or investigate:

• Duplicate accounts;
• False identities;
• Account farming;
• Fake task evidence;
• Stolen screenshots;
• Manipulated screenshots;
• Automated submissions;
• Bots;
• Fake engagement;
• Impersonation;
• Referral manipulation;
• Payment fraud;
• Withdrawal fraud;
• Account takeover;
• Unauthorised access;
• Coordinated abuse;
• Reversal of completed services;
• Celebrity unfollowing before an agreed date;
• Deletion of paid posts before an agreed date;
• Taskers undoing an action after payment; and
• Other breaches of PayFluence rules.

7.7 Communicate with users

We may send:

• Account-verification messages;
• Task notifications;
• Task-availability alerts;
• Deadline reminders;
• Correction requests;
• Approval or rejection notices;
• Payment and withdrawal updates;
• Booking information;
• Customer messages;
• Celebrity campaign updates;
• Security alerts;
• Policy updates;
• Support replies; and
• Marketing messages where legally permitted.

7.8 Improve PayFluence

We may use information to:

• Understand platform usage;
• Improve task allocation;
• Improve dashboards;
• Fix errors;
• Develop new features;
• Improve fraud detection;
• Improve customer reporting;
• Conduct internal research;
• Measure service quality;
• Improve user support; and
• Evaluate business performance.

7.9 Meet legal obligations

We may process information to:

• Comply with the Nigeria Data Protection Act;
• Maintain financial and corporate records;
• Respond to lawful regulatory requests;
• Respond to court orders;
• Prevent unlawful activity;
• Investigate complaints;
• Establish, exercise or defend legal claims;
• Cooperate with law-enforcement authorities; and
• Protect the rights and safety of users and the public.

8. Lawful bases for processing

Depending on the activity, PayFluence may rely on one or more of the following lawful bases.

8.1 Performance of a contract

We may process personal data where necessary to:

• Create and administer your account;
• Provide tasks;
• Accept submissions;
• Process campaigns;
• Facilitate bookings;
• Process payments;
• Release earnings;
• Provide support; or
• Enforce an agreement.

8.2 Consent

We may rely on consent for:

• Optional marketing;
• Certain cookies;
• Optional publicity;
• Recording a meeting;
• Using a user’s image in promotional material;
• Processing certain sensitive information; or
• Other processing for which consent is appropriate.

You may withdraw consent at any time.

Withdrawal does not affect the lawfulness of processing that occurred before consent was withdrawn.

8.3 Legal obligation

We may process information to comply with:

• Data-protection requirements;
• Accounting requirements;
• Tax requirements;
• Corporate requirements;
• Court orders;
• Lawful regulatory requests;
• Fraud-prevention obligations; or
• Other applicable Nigerian laws.

8.4 Legitimate interests

We may process information where necessary for legitimate interests such as:

• Operating PayFluence;
• Securing the platform;
• Preventing fraud;
• Protecting customer funds;
• Protecting tasker earnings;
• Reviewing task quality;
• Enforcing service durations;
• Investigating misconduct;
• Improving the service;
• Maintaining business records; and
• Defending legal claims.

We will consider whether these interests are overridden by users’ rights and freedoms.

8.5 Vital interests or public interest

In limited circumstances, information may be processed to protect a person’s life or safety or to comply with an applicable public-interest requirement.

9. Task evidence and customer access

Task evidence may be accessible to:

• The customer who created or funded the campaign;
• Authorised PayFluence administrators;
• Approved quality reviewers;
• Authorised community leaders, where strictly necessary;
• Fraud and security personnel;
• Service providers supporting secure storage or reporting;
• Professional advisers; and
• Regulators or authorities where legally required.

Customers may use task evidence only for:

• Verifying task completion;
• Assessing product performance;
• Reviewing campaign results;
• Compiling campaign reports;
• Resolving disputes; or
• Another purpose clearly disclosed before the task was accepted.

Customers must not:

• Sell taskers’ personal information;
• Use evidence for undisclosed surveillance;
• publish private evidence without permission;
• Contact taskers outside approved channels without lawful authority;
• Use data to harass, discriminate against or threaten users;
• Request passwords or one-time passwords;
• Use information for identity theft;
• Collect unnecessary sensitive information; or
• Reuse evidence for an unrelated campaign without an appropriate lawful basis.

PayFluence may redact, restrict, remove or reject submissions containing unnecessary personal information.

10. Public information

Certain information is intended to be public.

This may include:

• Username;
• Public name;
• Profile image;
• Biography;
• Professional category;
• Social-media links;
• Creator services;
• Rates;
• Verification badge;
• Ratings;
• Reviews;
• Public promotional content; and
• General service availability.

Users must not place the following in public profile fields:

• Passwords;
• PINs;
• One-time passwords;
• Bank-account security information;
• Government identification numbers;
• Private residential addresses;
• Private documents; or
• Information that they do not want publicly accessible.

Public information may be viewed, copied, indexed or shared by third parties outside PayFluence’s direct control.

11. Automated processing and task distribution

PayFluence may use automated systems, rules or algorithms to:

• Recommend tasks;
• Determine task eligibility;
• Distribute available task slots;
• Identify inactive slots;
• Detect duplicate accounts;
• Identify suspicious device activity;
• Detect reused evidence;
• Detect unusual transaction patterns;
• Assess fraud risk;
• Identify referral abuse;
• Detect early reversal of celebrity services; and
• Prioritise accounts for manual review.

An automated flag may result in:

• Additional verification;
• A temporary account restriction;
• A delayed payment;
• A delayed withdrawal;
• Manual review;
• A request for further evidence; or
• An investigation.

Where a decision has a significant effect on you and applicable law gives you the right to human intervention, you may request manual review by contacting:

temitopejoshua@payfluence.com.ng

Automated indicators are not guaranteed to be correct. PayFluence will consider relevant evidence submitted through an appeal.

12. Cookies and similar technologies

PayFluence may use:

• Cookies;
• Local storage;
• Session storage;
• Software-development kits;
• Pixels;
• Analytics tools; and
• Similar technologies.

These technologies may be used to:

• Keep users signed in;
• Remember preferences;
• Protect accounts;
• Prevent fraud;
• Measure platform use;
• Diagnose errors;
• Improve performance; and
• Support marketing where permitted.

Cookies may include:

Strictly necessary cookies: Required for login, security and platform functionality.

Preference cookies: Remember user choices.

Analytics cookies: Help us understand how PayFluence is used.

Security cookies: Help identify suspicious activity.

Marketing cookies: Used for advertising or campaign measurement where appropriate consent has been obtained.

Where legally required, PayFluence will ask for consent before placing non-essential cookies.

Users may control cookies through the PayFluence cookie banner or browser settings. Disabling essential cookies may affect the operation of the platform.

13. When we share personal data

PayFluence does not sell users’ personal data.

We may share information as described below.

13.1 Customers

We may share relevant task evidence, campaign reports and participant information with the customer responsible for a campaign.

We will seek to limit shared information to what is reasonably necessary.

13.2 Taskers and Celebrity Users

We may share relevant campaign instructions, customer business details, booking requirements and approved campaign materials with assigned taskers or Celebrity Users.

13.3 Payment providers and banks

We may share information with:

• Payment processors;
• Banks;
• Financial-technology providers;
• Payout providers;
• Fraud-prevention providers;
• Refund processors; and
• Chargeback-management providers.

13.4 Technology providers

We may use third parties for:

• Cloud hosting;
• Database services;
• Media storage;
• Authentication;
• Email delivery;
• Messaging;
• Analytics;
• Security monitoring;
• Identity verification;
• Video meetings;
• Error reporting;
• Customer support;
• Data backup; and
• Payment infrastructure.

Our known technology arrangements may change as PayFluence develops. We will update this Privacy Policy where a material change affects how personal data is processed.

13.5 Professional advisers

Information may be shared with:

• Lawyers;
• Accountants;
• Auditors;
• Insurers;
• Compliance professionals;
• Data-protection advisers; and
• Other professional consultants.

13.6 Authorities and legal recipients

We may disclose information where necessary to:

• Comply with a court order;
• Respond to a lawful government request;
• Cooperate with the Nigeria Data Protection Commission;
• Investigate suspected fraud;
• Report suspected criminal activity;
• Protect users;
• Protect PayFluence;
• Enforce legal rights; or
• Defend a legal claim.

13.7 Business transfers

Where PayFluence is involved in a merger, acquisition, restructuring, financing, investment, asset sale or similar transaction, information may be disclosed to relevant parties subject to confidentiality and applicable law.

14. International data transfers

PayFluence primarily serves users in Nigeria. However, some hosting, authentication, analytics, communication, media-storage or payment providers may process data outside Nigeria.

Where personal data is transferred outside Nigeria, PayFluence will take reasonable steps to ensure that:

• There is a valid legal basis for the transfer;
• The receiving country or organisation provides appropriate protection;
• Contractual safeguards are used where appropriate;
• Access is limited;
• Security requirements are imposed; and
• Data-subject rights remain protected.

Transfer mechanisms may include adequacy decisions, contractual safeguards, consent where appropriate, contractual necessity or another mechanism permitted under Nigerian law.

15. Data security

PayFluence uses reasonable technical and organisational measures designed to protect information against:

• Unauthorised access;
• Unlawful disclosure;
• Accidental loss;
• Destruction;
• Alteration;
• Misuse;
• Account takeover;
• Fraud; and
• Other data breaches.

Measures may include:

• Encrypted communication;
• Password hashing;
• Access controls;
• Role-based permissions;
• Secure hosting;
• Activity logging;
• Backups;
• Fraud monitoring;
• Account-verification procedures;
• Security testing;
• Staff confidentiality requirements; and
• Incident-response processes.

No internet service is completely secure. PayFluence cannot guarantee that a cyberattack, user error, third-party failure or other event will never affect personal data.

Users must:

• Use a strong password;
• Protect their email account;
• Protect their WhatsApp account;
• Protect their Google account;
• Protect their social-media accounts;
• Avoid sharing login details;
• Avoid sharing one-time passwords;
• Sign out from shared devices;
• Review suspicious login alerts; and
• Report suspected account compromise promptly.

PayFluence representatives will not ask for your password, bank PIN, card PIN or one-time password.

16. Personal-data breaches

Where PayFluence becomes aware of a suspected personal-data breach, we may:

• Investigate the incident;
• Contain the incident;
• Assess affected information;
• Restrict compromised access;
• Preserve relevant evidence;
• Reset affected credentials;
• Notify relevant service providers;
• Notify the Nigeria Data Protection Commission where required; and
• Notify affected users where legally required.

A user notification may explain:

• What happened;
• What information may be affected;
• The likely risks;
• What PayFluence has done;
• What the user should do; and
• How to contact us.

Users should report suspected privacy or security incidents to:

temitopejoshua@payfluence.com.ng

17. Data retention

PayFluence retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention depends on:

• The type of information;
• The purpose for which it was collected;
• Whether the account remains active;
• Whether a campaign is still running;
• Payment and accounting requirements;
• Fraud-prevention requirements;
• Dispute and chargeback periods;
• Legal limitation periods;
• Regulatory requirements;
• Security needs; and
• The need to establish, exercise or defend legal claims.

PayFluence may generally apply the following framework:

17.1 Account information

Account information may be retained for the duration of the account and for a reasonable period after closure to resolve disputes, enforce restrictions and meet legal obligations.

17.2 Financial records

Transaction, withdrawal, refund, commission, campaign-payment and accounting records may be retained for the legally required financial and tax-retention period.

17.3 Task evidence

Task evidence may be retained until:

• The campaign is completed;
• Customer reporting is completed;
• Payment disputes have expired;
• Fraud review is completed; and
• Any applicable legal-retention period has passed.

17.4 Identity-verification information

Identity information may be retained while necessary to:

• Verify the account;
• Prevent duplicate accounts;
• Prevent banned users from returning fraudulently;
• Process withdrawals;
• Investigate fraud; and
• Meet legal obligations.

17.5 Celebrity duration evidence

Evidence relating to a celebrity or creator service may be retained until:

• The agreed service duration ends;
• Payment is finally settled;
• The refund and dispute period ends;
• Any chargeback is resolved;
• Fraud review is completed; and
• Legal claims are no longer reasonably anticipated.

Where a service is agreed to remain active indefinitely, PayFluence may periodically review whether continued monitoring and retention remain necessary and proportionate.

17.6 Support and complaint records

Support, complaints and appeals may be retained until the matter is resolved and for a reasonable period afterward.

17.7 Fraud and restriction records

Limited records may be retained after account closure where necessary to prevent:

• Duplicate fraudulent accounts;
• Re-entry by banned users;
• Repeated payment fraud;
• Identity abuse; or
• Other serious violations.

When information is no longer required, PayFluence will delete, anonymise, aggregate or securely isolate it.

18. Account deletion

Users may request account deletion through an available account setting or by emailing:

temitopejoshua@payfluence.com.ng

Deleting an account does not necessarily result in immediate deletion of every record.

PayFluence may retain limited information where necessary to:

• Complete pending tasks;
• Complete pending withdrawals;
• Process refunds;
• Resolve disputes;
• Investigate suspected fraud;
• Prevent banned users from creating replacement accounts;
• Maintain transaction and accounting records;
• Comply with legal obligations;
• Enforce contracts; or
• Establish, exercise or defend legal claims.

Where information must be retained, PayFluence may restrict it from ordinary use.

Public content already shared by third parties may remain outside PayFluence’s control.

19. Your data-protection rights

Subject to applicable law, you may have the right to:

• Be informed about the processing of your personal data;
• Request access to your personal data;
• Request correction of inaccurate information;
• Request completion of incomplete information;
• Request deletion of personal data;
• Request restriction of processing;
• Object to certain processing;
• Withdraw consent;
• Object to direct marketing;
• Request data portability where applicable;
• Request human intervention in certain automated decisions;
• Challenge a significant automated decision;
• Lodge a complaint with PayFluence;
• Lodge a complaint with the Nigeria Data Protection Commission; and
• Seek another remedy available under Nigerian law.

These rights are not absolute.

A request may be restricted or refused where permitted by law, including where information is required for:

• Fraud prevention;
• Transaction records;
• Legal obligations;
• Protection of another person’s rights;
• Legal claims;
• Security investigations; or
• Public-interest requirements.

20. How to exercise your rights

To exercise a privacy right, email:

temitopejoshua@payfluence.com.ng

Include:

• Your full name;
• The email or telephone number connected to your account;
• Your PayFluence user ID, where available;
• The right you wish to exercise;
• The information concerned; and
• Sufficient details to help us identify the relevant record.

We may request reasonable evidence to verify your identity.

This is intended to prevent an unauthorised person from obtaining, changing or deleting your information.

PayFluence will respond within the period required under applicable law. Where additional time is legally permitted because a request is complex or numerous, we will inform you.

21. Marketing communications

PayFluence may send information about:

• New tasks;
• Campaign opportunities;
• Product-testing opportunities;
• Celebrity services;
• Creator bookings;
• Platform features;
• Referral programmes;
• Community programmes;
• Training;
• Events; and
• Promotions.

Where consent is required, promotional communications will only be sent after consent has been obtained.

You may opt out by:

• Selecting the unsubscribe option;
• Changing available notification preferences; or
• Contacting temitopejoshua@payfluence.com.ng.

You may still receive essential messages concerning:

• Account security;
• Task status;
• Payments;
• Withdrawals;
• Refunds;
• Bookings;
• Policy changes;
• Legal notices; and
• Other operational matters.

22. Third-party services and platforms

PayFluence campaigns may involve third-party platforms such as:

• Social-media platforms;
• App stores;
• Websites;
• Video-meeting services;
• Payment providers;
• Email services; and
• Communication platforms.

Third-party platforms operate under their own terms and privacy policies.

PayFluence is not responsible for a third party’s independent collection or use of information.

Users must not use PayFluence to:

• Obtain another person’s password;
• Obtain a one-time password;
• Circumvent platform security;
• Impersonate another person;
• Steal an account;
• Create deceptive identities;
• Use bots or unauthorised automation;
• Install malicious software;
• Conduct unlawful surveillance;
• Submit stolen task evidence; or
• Engage in another unlawful activity.

23. Customer responsibilities

Customers who create campaigns or receive participant data must:

• Provide clear campaign instructions;
• State why information is required;
• Collect only necessary information;
• Use information only for the disclosed purpose;
• Protect tasker and creator information;
• Restrict access to authorised personnel;
• Avoid requesting passwords or security credentials;
• Avoid unlawful discrimination;
• Avoid harassment or surveillance;
• Respect user privacy rights;
• Delete or anonymise information when no longer required;
• Report suspected breaches; and
• Comply with Nigerian data-protection and consumer-protection law.

A customer may be independently responsible as a data controller for information it receives or collects.

24. Tasker responsibilities

Taskers must:

• Provide accurate account information;
• Use their own authorised account;
• Submit authentic task evidence;
• Avoid submitting another person’s proof;
• Avoid unnecessary exposure of private information;
• Follow lawful campaign instructions;
• Protect confidential campaign materials;
• Report suspicious tasks;
• Secure their PayFluence account;
• Avoid bots and unauthorised automation;
• Avoid fake engagement;
• Avoid impersonation;
• Avoid stolen proof;
• Avoid fabricated submissions; and
• Comply with applicable third-party platform rules.

A tasker who receives another person’s personal data during a campaign must not retain, publish, sell or use it for an unrelated purpose.

25. Celebrity and creator responsibilities

Celebrity Users must:

• Provide accurate identity information;
• Provide accurate social-media information;
• Use accounts they own or are authorised to control;
• Protect customer campaign materials;
• Respect privacy and recording permissions;
• Clearly disclose paid endorsements where required;
• Avoid deceptive testimonials;
• Avoid unlawful or harmful content;
• Obtain appropriate permission before publishing another person’s image or information; and
• Use booking data only to provide the agreed service.

Where a Celebrity User accepts an action that must remain active for an agreed duration, PayFluence may monitor relevant public information and evidence for that period.

The Celebrity User must not, contrary to the applicable service agreement:

• Unfollow the customer before the agreed date;
• Delete an agreed comment;
• Remove an agreed like;
• Delete or hide a sponsored post;
• Archive required campaign content;
• Reverse an agreed share;
• Remove an agreed mention;
• Undo another paid action; or
• Otherwise terminate the service early without proper approval.

Information collected to investigate such conduct may be used for:

• Manual review;
• Customer notification;
• Payment withholding;
• Payment reversal;
• Refund processing;
• Wallet adjustment;
• Account restriction;
• Suspension;
• Removal of verification status;
• Dispute resolution; and
• Legal claims.

Any payment, refund, deduction or suspension must also be governed by the applicable PayFluence Terms and Conditions and Celebrity/Creator Agreement.

26. Referral leaders and authorised representatives

Referral leaders and community representatives must not:

• Request users’ passwords;
• Request payment PINs;
• Request one-time passwords;
• Access a user’s account without permission;
• Misrepresent themselves as company employees;
• Collect unnecessary identification information;
• Sell user information;
• Publish private information;
• Harass users;
• Threaten users; or
• Use referral information for an unrelated purpose.

PayFluence may suspend or remove a leader who misuses personal data.

27. Changes to this Privacy Policy

PayFluence may update this Privacy Policy to reflect:

• New features;
• Changes in business operations;
• New task categories;
• Changes to celebrity services;
• Changes to payment arrangements;
• Changes in technology providers;
• Security improvements;
• Legal or regulatory developments; or
• Changes in data-processing practices.

The updated version will display a revised “Last updated” date.

Where a change materially affects users’ rights or the use of personal data, PayFluence may provide additional notice through:

• Email;
• The website;
• The dashboard;
• An in-app notification; or
• Another appropriate communication channel.

Where fresh consent is legally required, continued use alone will not replace that consent.

28. Complaints

Privacy complaints should first be submitted to:

PayFluence Privacy Team Fluence Social Network Ltd No. 2, Aanuoluwapo Street, Ogo-Oluwa, Osogbo, Osun State, Nigeria Email: temitopejoshua@payfluence.com.ng

Please provide sufficient information for us to investigate the complaint.

You may also lodge a complaint with the Nigeria Data Protection Commission. The NDPC publishes complaint and contact channels as Nigeria’s data-protection regulator.

29. Contact information

For privacy requests, data-access requests, deletion requests, complaints or security concerns, contact:

Fluence Social Network Ltd Trading as PayFluence RC number: 9620018 Registered address: No. 2, Aanuoluwapo Street, Ogo-Oluwa, Osogbo, Osun State, Nigeria Email: temitopejoshua@payfluence.com.ng Website: www.payfluence.com.ng