Privacy Policy

Last updated: 13 September 2026 · Version: 1.1

Operator: Elexbig Limited (“Elexbig”, “we”, “us”, “our”)

Elexbig Limited (“Elexbig”) is committed to protecting your privacy and handling your personal information responsibly in accordance with the Nigeria Data Protection Act, 2023 (NDPA) and other applicable Nigerian data protection laws and regulations.

This Privacy Policy explains how we collect, use, disclose, store, retain, and protect your personal information when you use the Elexbig marketplace platform, website, applications, services, and related features.

1. Information We Collect

We collect various types of information to provide, maintain, secure, and improve our services.

Information You Provide Directly

1.1 When you create an account, make a purchase, sell products, or contact us, you may provide:

• Account information: Name, email address, phone number, date of birth, password
• Seller information: Business name, business registration details, CAC registration information, tax or business identification information where applicable, bank account details for payouts, business address, and other information required for Seller verification
• Buyer information: Delivery address, billing information, order details, and payment-related information
• Profile information: Profile photo, bio, preferences, saved items, wishlists, and other information you choose to provide
• Communications: Messages sent through our platform, emails to customer support, reviews and ratings, survey responses, complaints, reports, and feedback
• Identity verification: Government-issued identification, proof of address, business registration documents, and other verification documents where required for account verification, Seller onboarding, fraud prevention, or legal and regulatory compliance

Information Collected Automatically

1.2 When you access or use Elexbig, we may automatically collect:

• Device information: Device type, operating system, browser type and version, device identifiers, network information, and similar technical information
• Usage information: Pages viewed, search queries, products browsed, time spent on pages, click patterns, referral sources, and interactions with our services
• Location information: IP address and approximate geographic location. We may only collect precise location information where you provide the necessary permission
• Cookies and tracking: Information collected through cookies, pixels, local storage, web beacons, and similar technologies used to recognise your browser, remember preferences, analyse usage, and improve our services
• Transaction information: Purchase history, order history, browsing activity, saved items, cart activity, Seller performance information, and other marketplace activity

Information from Third Parties

1.3 We may receive information about you from:

• Payment processors: Payment status, transaction verification, fraud detection, and other payment-related information from payment providers
• Social login providers: If you choose to connect a social media account or use a social login feature
• Delivery and logistics partners: Shipping, tracking, delivery, and fulfilment information
• Analytics providers: Aggregated traffic, usage, and performance information
• Verification services: Identity verification, fraud prevention, compliance, and risk assessment information
• Public sources: Publicly available business registration records and other information used to verify business Sellers or prevent fraud
• Other users: Information provided by Buyers, Sellers, or other users when they communicate with us, report an account, submit a complaint, or participate in a transaction

2. How We Use Your Information

We use the information we collect for the following purposes:

Providing and Improving Services

2.1 To operate the Elexbig marketplace and provide our services:

• Create and manage your account
• Process and manage orders and transactions
• Facilitate communication between Buyers and Sellers
• Process payments and refunds
• Provide customer support and respond to enquiries
• Verify identities and authenticate users
• Enable Seller tools, dashboards, and marketplace features
• Manage returns, disputes, complaints, and Buyer protection processes
• Maintain and improve the performance and functionality of Elexbig

Personalising Your Experience

2.2 To customise and improve your experience:

• Show relevant product recommendations
• Remember your preferences, saved items, and search activity
• Provide personalised search results and listings
• Display relevant content and features based on your interactions with Elexbig
• Pre-fill information where appropriate to make checkout and account management easier
• Improve product discovery, marketplace recommendations, and user experience

Communication and Marketing

2.3 To communicate with you:

• Send transactional communications such as order confirmations, shipping updates, and account notifications
• Provide customer support and respond to your requests
• Send service announcements and important policy updates
• Send promotional and marketing communications where permitted by law and, where required, with your consent
• Send push notifications where you have enabled them
• Conduct surveys and request feedback to improve our services

You may opt out of marketing communications at any time, but you may still receive essential transactional and service-related communications.

Safety and Security

2.4 To maintain safety, security, and integrity:

• Detect, prevent, and investigate fraud, abuse, scams, and illegal activity
• Verify identities and authenticate accounts
• Protect against spam, harassment, and policy violations
• Monitor compliance with our Terms and other policies
• Enforce our agreements and legal rights
• Secure our systems and prevent unauthorised access
• Investigate suspicious activity and transactions
• Respond to lawful requests and protect users and the public from harm

Analytics and Research

2.5 To analyse and improve our platform:

• Understand how users interact with Elexbig
• Analyse trends, usage patterns, and marketplace performance
• Conduct research and develop new features
• Test and improve user experience
• Create aggregated or anonymised statistics
• Measure the effectiveness of marketing campaigns

Legal and Compliance

2.6 To comply with legal and regulatory obligations:

• Meet applicable tax, accounting, record-keeping, and regulatory requirements
• Comply with court orders, lawful government requests, and legal processes
• Respond to law enforcement requests where legally required
• Enforce our agreements and policies
• Protect our rights, property, users, and the public
• Meet our obligations under applicable Nigerian laws and regulations

Our processing of personal data is based on applicable lawful bases under Nigerian data protection law, which may include consent, contractual necessity, legal obligation, legitimate interests, vital interests, or other lawful bases recognised by applicable law.

3. How We Share Your Information

We share your personal information only where necessary for the purposes described in this Privacy Policy, to provide our services, to comply with legal obligations, or where otherwise permitted by applicable law.

We do not sell your personal information to third parties.

Sharing with Sellers

3.1 When you place an order, we share information reasonably necessary for the Seller to process and fulfil your order. This may include your name, phone number, delivery address, order details, and other information necessary to complete the transaction.

Sellers may receive this information through:

• their Seller dashboard;
• email or other notifications;
• Elexbig marketplace systems and tools;
• APIs or other integrations where applicable; and
• other systems necessary to process or fulfil an order.

Sellers are required to use customer information only for legitimate purposes connected with the transaction and their obligations to Elexbig and the customer. Sellers must handle personal information in accordance with applicable Nigerian data protection laws and are responsible for protecting information stored on their own systems.

With Buyers

3.1a Buyers may receive information about a Seller necessary to facilitate a transaction, including the Seller's business name, store information, location information made available through the marketplace, and communication methods provided through Elexbig.

Where available, communications between Buyers and Sellers may be conducted through Elexbig's messaging system.

With Service Providers

3.2 We may share information with trusted service providers who assist us in operating Elexbig, including:

• Payment processors: Payment service providers that process payments, refunds, and related transactions
• Cloud hosting and storage: Providers that host our website, servers, databases, files, and other infrastructure
• Email and communication services: Providers used to send transactional, account, and marketing communications
• AI and automation services: We may use artificial intelligence and automation tools, including Elex AI, to assist with customer support, enquiries, content moderation, fraud prevention, dispute assistance, and other marketplace functions
• Analytics providers: Services used to analyse website and marketplace usage and performance
• Fraud prevention services: Services that help detect and prevent fraudulent or suspicious activity
• Delivery and logistics partners: Service providers involved in shipping, delivery, and order fulfilment
• Security and technical service providers: Providers that assist with system security, monitoring, error detection, maintenance, and technical support

Service providers are required to handle personal information appropriately and only for authorised purposes, subject to applicable contractual, legal, and data protection requirements.

AI-Assisted Services

3.2a Elexbig uses artificial intelligence and automation, including Elex AI, to assist with certain services.

Elex AI may process information such as:

• Support messages and enquiries
• Order-related information
• Product and listing information
• User communications
• Information submitted through the Elex AI support widget
• Information necessary to assist with disputes, reports, and customer support

AI systems may assist with customer service, initial dispute assessment, content moderation, fraud detection, recommendations, and other functions.

Where a matter requires human intervention or review, you may request that it be reviewed by a member of the Elexbig team in accordance with our applicable policies.

Biometric Authentication

3.3 If you choose to enable biometric authentication on a supported device, such as fingerprint or facial recognition, the biometric authentication may be processed by your device's operating system or secure hardware.

Elexbig does not intend to collect or store your actual biometric template on our servers merely because you use biometric authentication. The exact handling of biometric authentication may depend on your device and operating system.

For Legal Reasons

3.4 We may disclose your information where required or permitted by applicable law, or where reasonably necessary to:

• Comply with legal obligations, court orders, or lawful government requests
• Enforce our Terms, policies, and agreements
• Detect, prevent, or address fraud, security issues, or illegal activity
• Protect our rights, property, and safety
• Protect the rights and safety of our users or the public
• Respond to claims that content violates third-party rights
• Assist competent authorities with investigations where legally required

Business Transfers

3.5 If Elexbig is involved in a merger, acquisition, restructuring, financing, asset sale, or similar corporate transaction, personal information may be transferred as part of that transaction, subject to applicable law and appropriate privacy protections.

Where required by law, we will provide notice of material changes affecting your personal information.

With Your Consent

3.6 We may share your information with third parties where you have provided valid consent or otherwise authorised the disclosure.

Anonymised and Aggregated Data

3.7 We may use and share anonymised, aggregated, or de-identified information that cannot reasonably identify you for analytics, research, service improvement, business planning, or other lawful purposes.

4. Cookies and Tracking Technologies

4.1 We use cookies, pixels, local storage, web beacons, and similar technologies to:

• Remember your preferences and settings
• Keep you logged in
• Provide personalised content and recommendations
• Analyse website usage and performance
• Improve marketplace functionality
• Prevent fraud and enhance security
• Understand the effectiveness of marketing campaigns

4.2 Types of cookies and similar technologies we may use include:

• Essential cookies: Required for the Website to function properly
• Functional cookies: Used to remember preferences and choices
• Analytics cookies: Help us understand how visitors use Elexbig
• Advertising or marketing cookies: Where applicable, used to deliver relevant advertising and measure campaign effectiveness

4.3 You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. However, disabling certain cookies may affect your ability to use some features of Elexbig.

4.4 We may also use web beacons or similar technologies in emails or web pages to understand whether communications are opened and links are interacted with, where permitted by applicable law.

5. Your Privacy Rights and Choices

Under the Nigeria Data Protection Act, 2023, you have rights regarding your personal information. Depending on the circumstances and applicable legal exceptions, these may include the right to be informed, access your personal information, request correction, object to processing, restrict processing, request data portability, request erasure, withdraw consent where processing is based on consent, and rights relating to automated decision-making.

Right to Access

5.1 You may request access to personal information we hold about you.

You can:

• View and update certain information through your Elexbig account
• Contact us at support@elexbig.com to request access to your personal information
• Request information about how your personal information is being processed

We may need to verify your identity before responding to a request.

Right to Correction

5.2 You may request correction of inaccurate, incomplete, or outdated personal information.

Where available, you may update your information directly through your account settings or contact us at support@elexbig.com.

Right to Erasure

5.3 You may request deletion or erasure of your personal information where permitted by applicable law.

We may retain certain information where necessary or legally required, including information:

• Required for legal, tax, accounting, or regulatory purposes
• Necessary to establish, exercise, or defend legal claims
• Required for the prevention or investigation of fraud
• Necessary to complete an ongoing transaction
• Required to comply with a legal obligation
• That has been anonymised and can no longer reasonably identify you

Right to Data Portability

5.4 Where applicable under Nigerian data protection law, you may request your personal information in a structured, commonly used, and machine-readable format.

To make a data portability request, contact support@elexbig.com with the subject line “Data Portability Request.”

Right to Object or Restrict Processing

5.5 Where applicable, you may object to or request restriction of certain processing of your personal information, particularly where the processing is based on legitimate interests or is used for direct marketing.

Withdrawal of Consent

5.6 Where we process your personal information based on consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Marketing Communications

5.7 You can opt out of marketing communications by:

• Clicking the “unsubscribe” link in a marketing email
• Adjusting your communication preferences where available
• Contacting us at support@elexbig.com

You cannot opt out of essential transactional communications that are necessary to provide our services.

Push Notifications

5.8 You can disable push notifications through your device settings or applicable Elexbig application settings.

Cookie Preferences

5.9 You may manage cookies through your browser settings and any cookie-management tools we make available.

Automated Decision-Making and Human Review

5.10 Where automated processing or artificial intelligence is used in a manner that triggers rights under applicable Nigerian data protection law, you may have the right to request human intervention or review.

To request human review of an AI-assisted decision or response, contact support@elexbig.com with the subject line “Request Human Review.”

6. Data Security and Protection

6.1 We implement appropriate technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss, destruction, or other unlawful processing. These measures may include:

• Encryption of data in transit using HTTPS/TLS
• Secure password hashing and authentication
• Access controls and permissions
• Security monitoring
• Vulnerability assessments and security reviews
• Employee and contractor confidentiality and security measures
• Secure hosting and infrastructure
• Backup and recovery procedures
• Incident response and data breach procedures

6.2 While we take reasonable steps to protect your information, no electronic system, website, network, or method of transmission can be guaranteed to be completely secure.

6.3 You are responsible for maintaining the confidentiality of your password and account credentials. You should use a strong password and never share your login credentials with another person.

Data Breach Notification

6.4 If Elexbig experiences a personal data breach, we will assess the breach and take appropriate steps in accordance with the Nigeria Data Protection Act, 2023 and applicable NDPC requirements.

Where a breach is likely to result in a risk to the rights and freedoms of individuals, applicable Nigerian data protection requirements may require notification to the Nigeria Data Protection Commission within 72 hours of becoming aware of the breach. Where required because of the level of risk, affected data subjects will also be notified.

6A. AI and Automated Processing

6A.1 Elexbig uses artificial intelligence and automated processing tools, including Elex AI, to assist with:

• Customer support and service enquiries
• Initial assessment of disputes and return-related matters
• Fraud detection and prevention
• Content moderation and review of listings and user-generated content
• Product search and recommendations
• Marketplace assistance and other support functions

6A.2 Depending on the service being provided, Elex AI or another automated system may process information such as account information, transaction information, messages, product information, and other information you provide through Elexbig.

6A.3 AI-assisted processing does not necessarily mean that a decision is made solely by an automated system. Where applicable, Elexbig may use human review, particularly for matters that may significantly affect a user's account, rights, or access to services.

6A.4 If you believe an AI-assisted response or decision has materially affected you, you may request human review by contacting support@elexbig.com with the subject line “Request Human Review.”

6A.5 AI systems may produce inaccurate or incomplete responses. You should not rely solely on an AI-generated response where the matter involves important legal, financial, safety, or other consequential decisions.

7. Data Retention

7.1 We retain personal information only for as long as reasonably necessary to provide our services, fulfil the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, or protect our legitimate interests, subject to applicable law.

7.2 Retention periods may vary depending on the type of information and the purpose for which it was collected.

Examples include:

• Account information: Retained while your account is active and for a reasonable period afterwards where necessary for legal, security, fraud-prevention, or operational purposes
• Transaction records: Retained for the period required by applicable tax, accounting, legal, and regulatory requirements
• Communications and support records: Retained for as long as reasonably necessary to provide support, resolve disputes, prevent abuse, and comply with legal obligations
• Marketing information: Retained until you withdraw consent or opt out, subject to applicable legal and operational requirements
• Dispute and legal records: Retained for the duration of the dispute or legal matter and any additional period required to protect our legal rights
• Analytics information: May be retained in accordance with the retention settings and policies of the relevant analytics service

7.3 We periodically review personal information and delete, anonymise, or securely dispose of information that is no longer required, subject to applicable legal and regulatory requirements.

8. Children's Privacy

8.1 Elexbig is primarily intended for individuals who are 18 years or older. We do not knowingly collect personal information from children in circumstances where such collection is prohibited by applicable law.

8.2 Where a person under 18 is permitted to use Elexbig with the involvement or consent of a parent or legal guardian, the parent or guardian is responsible for supervising that use.

8.3 If we become aware that we have collected personal information from a child in circumstances where appropriate consent was required but was not obtained, we will take reasonable steps to address the situation, including deleting the information where appropriate and legally permissible.

8.4 If you believe that we have improperly collected personal information from a child, please contact us at support@elexbig.com.

8A. Information for International Visitors

8A.1 Elexbig is operated by Elexbig Limited, a company operating in Nigeria, and the marketplace is primarily intended for users in Nigeria.

8A.2 If you access Elexbig from outside Nigeria, your personal information may be transferred to, stored in, and processed in Nigeria or other countries where Elexbig or its service providers operate.

8A.3 The collection, use, storage, and handling of your personal information is governed primarily by the Nigeria Data Protection Act, 2023 and other applicable Nigerian laws, together with any mandatory privacy protections that may apply to you.

8A.4 Where applicable, we will take reasonable steps to ensure that international processing and transfers are carried out in accordance with applicable Nigerian data protection requirements.

9. International Data Transfers

9.1 Your personal information may be transferred to, stored in, or processed outside Nigeria where necessary to provide Elexbig's services or where we use service providers located outside Nigeria.

9.2 Where personal information is transferred outside Nigeria, Elexbig will use appropriate safeguards and lawful transfer mechanisms required under applicable Nigerian data protection law.

These safeguards may include:

• Appropriate contractual protections
• Adequacy decisions or recognised transfer mechanisms
• Appropriate technical and organisational safeguards
• Other lawful mechanisms permitted under applicable Nigerian data protection law

9.3 Where required, we will provide appropriate information about international transfers and the safeguards applicable to them.

The Nigeria Data Protection Commission recognises cross-border data transfers under the Nigeria Data Protection Act and requires appropriate safeguards and lawful transfer mechanisms.

10. Third-Party Links and Services

10.1 Elexbig may contain links to third-party websites, services, applications, or platforms that are not controlled or operated by us.

10.2 This Privacy Policy does not apply to third-party websites or services that operate independently from Elexbig. We are not responsible for the privacy practices of those third parties.

10.3 We encourage you to review the privacy policies and terms of any third-party service before providing personal information to that service.

10.4 Sellers on Elexbig are independent third parties responsible for their own business and privacy practices. While Elexbig may require Sellers to comply with applicable privacy obligations, we cannot control how a Seller handles information provided directly to the Seller outside Elexbig's systems.

11. Changes to This Privacy Policy

11.1 We may update this Privacy Policy from time to time to reflect changes in our services, business practices, technology, legal requirements, or data protection obligations.

11.2 When we make material changes, we may notify you by:

• Updating the “Last updated” date at the top of this Privacy Policy
• Sending an email notification where appropriate
• Posting a notice on the Website or your account
• Providing an in-app or other electronic notification where appropriate

11.3 We encourage you to review this Privacy Policy periodically to remain informed about how Elexbig handles personal information.

11.4 Where permitted by applicable law, your continued use of Elexbig after an updated Privacy Policy becomes effective constitutes your acknowledgement of the updated policy.

12. Contact Us and Privacy Complaints

Privacy Questions and Requests

12.1 If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Email:support@elexbig.com

Postal Address:

Privacy Officer
Elexbig Limited
Abuja, Nigeria

Privacy Complaints

12.2 If you believe Elexbig has breached your privacy rights or has not handled your personal information in accordance with applicable law:

• Contact us at support@elexbig.com with details of your complaint
• We will review and investigate your complaint
• We may request additional information to verify your identity and properly investigate the matter
• We will respond within a reasonable period and in accordance with applicable legal requirements

You may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) where you believe your data protection rights have been violated. The NDPC provides mechanisms for data subjects to exercise their rights and report data protection concerns.

Nigeria Data Protection Commission

12.3 The Nigeria Data Protection Commission is Nigeria's supervisory authority for data protection and privacy.

Website:https://ndpc.gov.ng/
Phone: +234 916 061 5551
Location: Abuja, Nigeria

13. Your Consent and Lawful Processing

13.1 By using Elexbig, creating an account, placing an order, becoming a Seller, or otherwise providing personal information to us, you acknowledge that your personal information may be processed as described in this Privacy Policy and in accordance with applicable Nigerian data protection law.

13.2 We do not rely on consent as the lawful basis for every type of processing. Depending on the circumstances, we may process personal information where necessary for contractual purposes, compliance with legal obligations, legitimate interests, protection of vital interests, or other lawful bases recognised under the Nigeria Data Protection Act, 2023.

13.3 Where we rely on your consent for a particular processing activity, you may withdraw that consent at any time, subject to applicable law.

13.4 Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

13.5 Nothing in this Privacy Policy limits any privacy rights or remedies available to you under applicable Nigerian law.