Privacy Policy

# Privacy Policy

Last updated: September 12, 2026

1. Introduction

This Privacy Policy explains how Trackdock Limited, trading as Trakroom ("Trakroom", "we", "us", or "our"), collects, uses, shares, stores, and protects personal data when you use Trakroom.

We are a company registered in Nigeria. Our registered address is 4H, Arc Farouq Musa Street, Brains and Hammers City, Life Camp, Abuja, FCT, Nigeria.

This Privacy Policy applies to trakroom.com, storefronts hosted on Trakroom subdomains, storefronts using custom domains, and other services operated by Trakroom that link to this Privacy Policy (collectively, the "Service").

Trakroom provides technology that allows Sellers to create online storefronts, sell and deliver digital products and licences, manage customers and orders, receive payments through supported payment providers, and use other related features.

This Privacy Policy should be read together with our Terms of Use, Merchant Service Agreement, Refund Policy, Intellectual Property Policy, and any other terms that apply to your use of the Service.

2. Legal Framework

We process personal data in accordance with applicable data protection and privacy laws.

Our primary data protection framework is:

• the Nigeria Data Protection Act 2023 ("NDP Act");
• the Nigeria Data Protection Act General Application and Implementation Directive 2025 ("GAID"); and
• regulations, directives, guidance, codes, and other legally applicable requirements issued by the Nigeria Data Protection Commission ("NDPC").

Where our processing activities are subject to data protection laws outside Nigeria, we will also comply with those laws to the extent that they apply to us.

Nothing in this Privacy Policy is intended to limit any right that you have under a mandatory provision of applicable data protection law.

3. Who Is Responsible for Your Data

3.1 Where We Are the Data Controller

Trakroom acts as a data controller where we determine why and how personal data is processed.

This generally includes personal data relating to:

• visitors to Trakroom;
• Trakroom account holders;
• Sellers using the platform;
• account creation and authentication;
• Seller onboarding;
• platform subscriptions and billing;
• customer support;
• platform administration;
• security and fraud prevention;
• service performance and analytics;
• legal and regulatory compliance; and
• our own communications and marketing.

3.2 Where a Seller Is the Data Controller

Each Seller operating a Store through Trakroom is responsible for personal data that the Seller uses for its own business purposes.

This may include customer information used by a Seller for:

• maintaining customer records;
• providing customer support;
• managing orders;
• fulfilling purchases;
• issuing licences;
• handling refunds or disputes;
• maintaining accounting or tax records; and
• sending marketing communications where legally permitted.

For these activities, the Seller is generally an independent data controller.

Where Trakroom processes customer personal data solely on the Seller's behalf in providing the Service, Trakroom acts as a data processor for that Seller in accordance with the applicable data protection provisions of our Merchant Service Agreement.

If your request relates to personal data controlled by a Seller, we may direct you to that Seller.

Where appropriate and technically possible, we may assist the Seller in responding to your request.

3.3 Where Trakroom Remains a Controller

Even where a Seller is the controller of its customer relationship, Trakroom may independently act as a controller of certain information generated through use of the platform.

This may include:

• transaction records;
• order records;
• payment status information;
• licence records;
• delivery records;
• security records;
• fraud-prevention information;
• platform activity records; and
• information needed to comply with our own legal obligations.

We may process this information for purposes including operating the Service, maintaining security, resolving disputes, preventing abuse, keeping appropriate business records, and complying with applicable law.

4. Data Protection Contact

If you have a privacy question, request, concern, or complaint, you can contact us at:

Data Protection Contact — Trackdock Limited

Email: [privacy@trakroom.com](mailto:privacy@trakroom.com)

Post: 4H, Arc Farouq Musa Street, Brains and Hammers City, Life Camp, Abuja, FCT, Nigeria

Phone: +234 708 425 4194

Where we are required by applicable law to designate a Data Protection Officer, appropriate Data Protection Officer contact information will be made available.

5. Personal Data We Collect

5.1 Data You Give Us

Depending on how you use the Service, we may collect:

• Identity information: First name, last name, artist name, producer name, display name, or username.
• Contact information: Email address, phone number, postal address, or business address.
• Account information: Account settings, login and authentication information, preferences, Store name, subdomain, and custom domain information.
• Seller information: Business or trading name, business registration information, tax information where required, and information associated with payment or payout accounts.
• Profile information: Profile images, logos, biographies, social links, website links, and other information added to a profile or Store.
• Content: Audio files, video files, artwork, images, product files, documents, product descriptions, licence terms, course materials, and other content uploaded to the Service.
• Transactional information: Products purchased, order details, amounts, currencies, transaction references, licence records, refund information, and delivery or download history.
• Communications: Support enquiries, feedback, complaints, refund requests, dispute correspondence, copyright notices, trademark complaints, counter-notices, and other communications with us.
• Collaboration information: Collaborator names, contact information, payment information where applicable, and split percentages or other collaboration details entered into the Service.
• Information submitted through forms: Any other personal data you choose to submit through forms or features available through the Service.

5.2 Data We Collect Automatically

When you access or use the Service, we may automatically collect information such as:

• IP address;
• browser type and version;
• device and browser characteristics;
• operating system;
• referring page or website;
• pages or features accessed;
• date and time of access;
• approximate location derived from network information;
• session and activity information;
• delivery and download events;
• security events;
• diagnostic information;
• error information; and
• other technical information reasonably required to operate and protect the Service.

We may collect this information through server logs, cookies, local storage, security systems, and similar technologies.

5.3 Data We Receive From Other Parties

We may receive personal data from third parties involved in providing the Service.

These may include:

• Payment providers: Transaction references, payment status, amount, currency, payment method type, settlement information, refund information, chargeback information, and limited fraud or risk information.
• Authentication providers: Identity, email, or authentication information where you choose to sign in using a supported third-party authentication service.
• Security and anti-abuse providers: Verification results, security signals, fraud indicators, or risk information used to protect the Service.
• Sellers: Information provided by a Seller where necessary to operate a Store, fulfil an order, provide customer support, or resolve a dispute.
• Financial institutions and payment networks: Information relating to payments, settlements, refunds, disputes, chargebacks, or fraud investigations where applicable.
• Other users: Information another user provides about you where necessary for features such as collaborations or account administration.

5.4 Payment Information

Payments made through Trakroom are generally processed using third-party payment providers.

Where payment details are entered directly into a payment provider's payment interface, the payment provider receives and processes those details.

Trakroom generally does not need to receive or store your complete payment card number, card security code, or online banking credentials where those details are collected directly by the payment provider.

We may receive limited information relating to the transaction, as described elsewhere in this Privacy Policy.

5.5 Sensitive Personal Data

We do not ask users to provide sensitive personal data unless it is reasonably necessary for a specific lawful purpose.

Sensitive personal data may include information concerning:

• racial or ethnic origin;
• religious or philosophical beliefs;
• political opinions;
• trade union membership;
• health information;
• sex life or sexual orientation;
• genetic information; or
• biometric information used for uniquely identifying a person.

Please avoid including unnecessary sensitive personal data in support requests, Store content, product descriptions, uploaded files, or other areas of the Service.

If sensitive personal data is provided to us without a legitimate need for us to retain it, we may delete or restrict access to it where appropriate.

6. Why We Process Your Data and Our Lawful Basis

We process personal data only where we have an appropriate lawful basis.

Depending on the circumstances, our lawful bases may include consent, performance of a contract, compliance with a legal obligation, protection of vital interests, legitimate interests, or another basis permitted by applicable law.

Our principal processing activities include:

• Creating and administering accounts: We process identity, contact, authentication, and account information to create and maintain your account. The primary lawful basis is performance of our contract with you.
• Operating Seller Stores: We process account, profile, Store, content, and transaction information to provide Seller storefronts and related services. The primary lawful basis is performance of our contract.
• Hosting and delivering digital content: We process uploaded content and transaction information to store, display, stream, or deliver products purchased or accessed through the Service. The primary lawful basis is performance of a contract.
• Managing platform subscriptions and billing: We process account and transaction information to manage subscription plans, billing, renewals, cancellations, and related matters. The primary lawful basis is performance of a contract.
• Processing Store transactions: We process information necessary to initiate, confirm, record, support, or reconcile transactions. The applicable lawful bases may include performance of a contract, legitimate interests, and legal obligation.
• Delivering purchases and licence documents: We process customer contact, order, and licence information to provide purchased products and associated licences. The primary lawful basis is performance of a contract.
• Providing customer support: We process contact information, account information, communications, and transaction information to respond to requests and resolve problems. The applicable lawful bases include performance of a contract and legitimate interests.
• Handling refunds, disputes, and chargebacks: We process transaction and communication information to investigate and resolve payment or order disputes. The applicable lawful bases include performance of a contract, legitimate interests, and legal obligation.
• Preventing fraud and abuse: We process technical, account, usage, and transaction information to identify suspicious activity and protect Trakroom, Sellers, customers, and payment systems. The primary lawful basis is our legitimate interests and, where applicable, legal obligation.
• Protecting the Service: We process technical and security information to detect malicious activity, unauthorised access, attacks, spam, automated abuse, or other threats. The primary lawful basis is our legitimate interests in maintaining a secure Service.
• Maintaining and improving the Service: We process diagnostic, usage, and performance information to fix errors, measure performance, and improve features. The primary lawful basis is our legitimate interests in operating and improving the Service.
• Analytics: We may use usage information to understand how the Service is used. Where applicable law requires consent for analytics technologies, we rely on your consent.
• Sending service communications: We use contact information to send account, order, billing, security, policy, and other operational communications. The applicable lawful bases include performance of a contract and legal obligation.
• Marketing: Where permitted, we may use contact information to communicate about Trakroom products, services, or features. Where consent is required, we will obtain it and you may withdraw it at any time.
• Handling intellectual property complaints: We process identity, contact, content, and communications information to investigate copyright, trademark, and other rights complaints. The applicable lawful bases include legal obligation and legitimate interests.
• Maintaining business, tax, and accounting records: We process relevant account and transaction information where necessary to comply with legal and regulatory requirements.
• Legal claims: We may process information where reasonably necessary to establish, exercise, or defend legal claims.

Where we rely on legitimate interests, we consider whether our interests are reasonably necessary and whether they are overridden by your rights, freedoms, or reasonable expectations.

Where we rely on consent, you may withdraw your consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

7. Cookies and Similar Technologies

We use cookies, local storage, and similar technologies where necessary to operate, secure, personalise, and understand use of the Service.

These technologies may be used to:

• Operate the Service — including keeping you signed in, maintaining sessions, processing requests, and routing users to the appropriate Store.
• Remember preferences — including account settings, interface choices, and other preferences.
• Protect the Service — including detecting bots, spam, fraud, abuse, suspicious activity, and security threats.
• Measure performance — including identifying errors, monitoring reliability, and understanding technical performance.
• Understand usage — including analytics relating to how users interact with the Service.

Technologies that are strictly necessary to provide or secure the Service may be used without consent where permitted by applicable law.

Non-essential cookies, analytics technologies, or similar tracking tools will be used only where permitted by applicable law and, where required, after you have been given an appropriate choice.

Where consent is required, you may withdraw or change your preference through the available cookie or privacy controls.

You can also configure your browser to block or delete cookies. Some parts of the Service may not function correctly if necessary technologies are disabled.

8. Who We Share Data With

We do not sell your personal data.

We share personal data only where reasonably necessary to provide, operate, secure, support, and improve the Service, process transactions, comply with legal obligations, or for another purpose described in this Privacy Policy.

8.1 Sellers

When you make a purchase from a Store, the Seller may receive information reasonably necessary to fulfil and support your order.

This may include:

• your name;
• email address;
• order information;
• products or licences purchased;
• transaction reference;
• amount and currency;
• delivery information; and
• other information reasonably necessary to support the transaction.

The Seller is responsible for its own use of personal data as described in section 3.2.

8.2 Service Providers and Processors

We use third-party companies and service providers to help us operate, secure, maintain, and support the Service.

Categories of providers we may use include:

• Cloud hosting and infrastructure providers — to host and operate websites, applications, databases, and related infrastructure.
• Cloud storage and content delivery providers — to store, process, stream, and deliver audio, video, artwork, product files, documents, and other content.
• Email and communications providers — to send transactional emails, account notifications, order communications, security messages, and other service communications.
• Authentication providers — to support account sign-in and identity verification where applicable.
• Security and fraud-prevention providers — to detect malicious activity, bots, spam, fraud, abuse, and security threats.
• Analytics and performance providers — to measure usage, diagnose technical problems, and understand or improve Service performance.
• Monitoring and technical service providers — to help maintain the reliability, availability, and security of the Service.
• Customer-support and business-service providers — where used to help us respond to users or administer our operations.

These providers may process personal data only as reasonably necessary to provide their services to us and subject to applicable contractual, confidentiality, security, and data-protection obligations.

A service provider may use affiliates or approved subprocessors in providing its services.

We may change the companies we use as our Service develops, provided that our handling of personal data remains subject to this Privacy Policy and applicable law.

8.3 Payment Providers and Financial Services

We use and support third-party payment and financial-service providers to facilitate transactions.

These services may be used for:

• Trakroom subscription payments;
• Store purchases;
• payment authorisation;
• recurring payments;
• settlements;
• refunds;
• payouts;
• connected payment accounts;
• payment disputes;
• chargebacks;
• fraud prevention; and
• other payment-related services.

The payment provider available for a particular transaction may depend on factors such as:

• the Seller's payment configuration;
• the customer's selected payment method;
• transaction currency;
• customer location;
• Seller location; and
• availability of a particular payment method.

Some Sellers may connect their own account with a supported payment provider to their Store.

Where this occurs, information necessary to initiate, process, confirm, settle, refund, or investigate the transaction may be transmitted to that provider.

Payment providers may collect information directly from you, including payment card details, bank information, billing information, identity information, device information, and other information they require to process or verify a transaction.

Information provided directly to a payment provider is also subject to that provider's privacy practices, terms, and regulatory obligations.

We may receive information from payment providers including:

• transaction reference;
• payment status;
• amount;
• currency;
• payment method type;
• customer name or email;
• limited payment method information;
• authorisation information;
• refund information;
• settlement information;
• payout information;
• chargeback information; and
• fraud, risk, or dispute information.

We may share relevant transaction, account, order, delivery, and customer information with payment providers, financial institutions, acquiring institutions, payment networks, Sellers, or other relevant parties where reasonably necessary to:

• process or verify a transaction;
• process a refund;
• complete a settlement or payout;
• investigate fraud or unauthorised activity;
• respond to a payment dispute;
• respond to a chargeback;
• enforce applicable agreements;
• comply with financial, fraud-prevention, anti-money-laundering, sanctions, or other regulatory obligations; or
• establish, exercise, or defend legal claims.

The applicable payment provider may be identified to you during checkout, billing, payment configuration, onboarding, or another relevant part of the Service.

8.4 Professional Advisers

We may share personal data with professional advisers where reasonably necessary.

These may include:

• lawyers;
• accountants;
• auditors;
• tax advisers;
• insurers;
• compliance professionals; and
• other professional consultants.

Where applicable, these parties are subject to professional, contractual, or legal confidentiality obligations.

8.5 Legal and Regulatory Disclosure

We may disclose personal data where we reasonably believe disclosure is necessary to:

• comply with applicable law;
• comply with a court order;
• comply with a lawful government or regulatory request;
• respond to law enforcement where legally required;
• enforce our agreements, policies, or rights;
• investigate fraud, abuse, or unlawful activity;
• investigate or respond to a security incident;
• protect Trakroom, Sellers, customers, users, or members of the public;
• protect property or legal rights; or
• establish, exercise, or defend legal claims.

We may challenge requests that we reasonably believe are invalid, excessive, unlawful, or outside the authority of the requesting body where appropriate.

8.6 Corporate Transactions

If Trackdock Limited or the business operating Trakroom becomes involved in a merger, acquisition, investment, financing, restructuring, reorganisation, insolvency, sale of assets, or similar corporate transaction, personal data may be disclosed or transferred as part of that transaction.

Where required by applicable law, we will take reasonable steps to ensure appropriate protection of personal data and provide any legally required notice.

8.7 Changes to Third-Party Providers

The individual companies and providers we use may change as we develop, improve, or expand the Service.

We do not necessarily identify every individual service provider in this Privacy Policy where applicable law permits us to describe recipients by category.

Where required by law, additional information about recipients or categories of recipients may be provided upon request or at the point where the relevant service is used.

9. International Transfers of Data

Trakroom is operated by a company established in Nigeria, but some of the third parties that support the Service may process personal data in other countries.

As a result, personal data may be:

• transferred from Nigeria to another country;
• processed in a country other than the country in which you live; or
• transferred to Nigeria where you access the Service from another country.

We do not need to use the same country or service location for every category of processing, and those locations may change as our providers, infrastructure, or services change.

Where the NDP Act applies to a transfer of personal data from Nigeria to another country, we will use a transfer mechanism permitted under sections 41 to 43 of the NDP Act.

Depending on the circumstances, this may include:

• transferring information to a recipient subject to an appropriate level of data protection;
• using contractual or other approved safeguards;
• relying on another legally recognised transfer mechanism;
• transferring information where necessary to perform a contract involving you;
• transferring information where necessary for important public-interest reasons;
• transferring information where necessary for legal claims;
• transferring information where necessary to protect vital interests; or
• relying on informed consent where legally appropriate.

We take reasonable steps to ensure that international transfers are subject to safeguards appropriate to the nature of the personal data and the risks involved.

You may contact [privacy@trakroom.com](mailto:privacy@trakroom.com) if you have a question about international transfers of your personal data.

10. Your Rights

Depending on applicable law and the circumstances of the processing, you may have rights over your personal data.

Under the NDP Act, these rights include:

• Right to be informed — to receive appropriate information about how your personal data is processed.
• Right of access — to ask whether we process your personal data and request access to applicable personal data and information about its processing.
• Right to rectification — to request correction of inaccurate personal data and completion of incomplete personal data where appropriate.
• Right to erasure — to request deletion of personal data in circumstances provided by applicable law.
• Right to restriction — to request that certain processing be restricted in circumstances provided by applicable law.
• Right to object — to object to certain processing, including processing based on legitimate interests and direct marketing.
• Right to data portability — where applicable, to receive certain personal data in a structured, commonly used, machine-readable format and request transmission to another controller where technically feasible.
• Right to withdraw consent — to withdraw consent where processing relies on your consent.
• Rights relating to automated decision-making — to receive applicable safeguards where a decision producing legal or similarly significant effects is made solely through automated processing.
• Right to complain — to lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority where applicable.

These rights are subject to applicable legal conditions, limitations, exemptions, and the nature of our role in relation to the relevant personal data.

How to Exercise Your Rights

You may submit a privacy request by emailing:

[privacy@trakroom.com](mailto:privacy@trakroom.com)

Where possible, contact us using the email address associated with your account.

Please explain:

• the right you wish to exercise;
• the personal data your request concerns; and
• any information reasonably necessary for us to locate the relevant data.

You may also write to us using the postal address in section 4.

Identity Verification

We may request information reasonably necessary to verify your identity before responding to a privacy request.

This is intended to prevent personal data from being disclosed, altered, or deleted at the request of an unauthorised person.

We will not request more verification information than reasonably necessary for the request.

Response Time

We will respond to valid requests without undue delay and within the period required by applicable law.

For requests subject to the NDP Act and applicable NDPC requirements, we generally aim to resolve requests within 30 days.

Where applicable law allows additional time because a request is complex or because multiple requests have been submitted, we will inform you where required.

Fees

We generally do not charge a fee for exercising data protection rights.

Where applicable law permits it, we may charge a reasonable fee or decline to act on a request that is manifestly unfounded, excessive, repetitive, or abusive.

Where we do so, we will provide an explanation where required by law.

Requests Concerning Seller Data

If your request primarily concerns personal data controlled independently by a Seller, we may direct you to that Seller.

We may assist the Seller where appropriate and where we are able to do so.

See section 3.2.

11. How Long We Keep Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for legitimate business, legal, accounting, tax, security, fraud-prevention, and dispute-resolution purposes.

The appropriate retention period depends on factors including:

• the type of personal data;
• why it was collected;
• the relationship between you and Trakroom;
• whether your account remains active;
• whether a transaction or licence may need to be evidenced later;
• applicable tax, accounting, or corporate-record requirements;
• fraud or security risks;
• disputes or legal claims; and
• applicable law.

Our standard retention approach includes:

• Account and profile information: Generally retained while the account is active and for a limited period following account closure, subject to legal and operational requirements.
• Uploaded content and product files: Generally retained while necessary to provide the applicable Store or product and for a limited period after account closure, product deletion, downgrade, or termination where appropriate.
• Transaction, billing, accounting, and tax information: Retained for the period required by applicable accounting, tax, corporate, payment, and record-keeping laws.
• Licence and order records: May be retained for an extended period where necessary to establish the licence granted, confirm a transaction, resolve disputes, or protect the rights of Sellers, customers, or Trakroom.
• Payment and settlement information: Retained as necessary for reconciliation, refunds, chargebacks, fraud prevention, accounting, and legal compliance.
• Support communications: Retained for a reasonable period after the matter is resolved.
• Legal and intellectual-property complaints: Retained for a reasonable period following resolution and longer where a claim, investigation, or proceeding is ongoing or reasonably anticipated.
• Marketing preferences and consent records: Retained for as long as relevant to the communication and for a reasonable period afterward where necessary to demonstrate or respect your preferences.
• Security and technical logs: Retained for a period reasonably necessary for security monitoring, investigation, troubleshooting, abuse prevention, and service reliability.
• Fraud and abuse information: May be retained for longer periods where reasonably necessary to prevent repeat abuse, protect users, or defend legal claims.

Where personal data is subject to a legal hold, regulatory request, investigation, dispute, chargeback, or actual or anticipated legal claim, we may retain relevant information until that matter has been concluded and any applicable retention period has expired.

When personal data is no longer reasonably required, we will delete it, anonymise it, de-identify it, or otherwise dispose of it in accordance with our legal and operational obligations.

Backup copies may remain for a limited period until they are overwritten or deleted through ordinary backup cycles.

12. Security

We use technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access, misuse, or other inappropriate processing.

Depending on the nature of the information and the Service, these measures may include:

• encryption of information during transmission;
• appropriate protection of authentication credentials;
• access controls;
• role-based permissions;
• separation of customer and Seller environments where appropriate;
• restricted administrative access;
• secure mechanisms for accessing protected files;
• logging and monitoring;
• security testing;
• fraud and abuse controls;
• backup and recovery measures;
• incident-response procedures; and
• assessment of third-party providers.

Access to personal data by personnel is limited according to legitimate business responsibilities and appropriate authorisation.

No website, application, network, transmission method, or storage system can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your account credentials and should use a strong and unique password.

If you believe your account or personal data has been compromised, contact us promptly at [privacy@trakroom.com](mailto:privacy@trakroom.com).

13. Personal Data Breaches

We maintain procedures intended to identify, investigate, contain, document, and respond to personal data breaches.

Where a personal data breach is likely to result in a risk to the rights and freedoms of individuals and notification is required under the NDP Act, we will notify the Nigeria Data Protection Commission within the legally applicable period, including within 72 hours of becoming aware of the breach where required.

Where a breach is likely to result in a high risk to affected individuals, we will notify those individuals as required by applicable law.

A notification may include information about:

• the nature of the incident;
• the categories of information affected;
• the likely consequences;
• measures we have taken or intend to take;
• steps you can take to reduce potential harm; and
• how to contact us for further information.

We maintain appropriate records of personal data breaches in accordance with applicable law.

14. Children

Trakroom is not directed at children.

You must be at least 18 years old to create a Trakroom account, operate a Store, or make a purchase through the Service unless we expressly permit otherwise in accordance with applicable law.

We do not knowingly seek to collect personal data from children through the Service.

If we become aware that personal data has been collected from a child in circumstances where we should not have collected it, we may delete the information, restrict the account, suspend the account, or take other appropriate action.

If you believe a child has provided personal data to us inappropriately, contact:

[privacy@trakroom.com](mailto:privacy@trakroom.com)

We will investigate and take appropriate action in accordance with applicable law.

15. Complaints

If you believe that we have handled your personal data improperly or have not adequately responded to a privacy request, please contact us at:

[privacy@trakroom.com](mailto:privacy@trakroom.com)

We would like the opportunity to investigate and address your concern.

Nothing in this Privacy Policy prevents you from exercising your right to lodge a complaint directly with a competent data protection authority.

In Nigeria, the relevant supervisory authority is:

Nigeria Data Protection Commission (NDPC)

Website:
https://ndpc.gov.ng

Where applicable, you may also have the right to complain to a data protection or privacy authority in another jurisdiction.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Reasons for an update may include:

• changes to the Service;
• new features;
• changes to how personal data is processed;
• changes to the categories of third parties we use;
• changes to payment or operational arrangements;
• changes to legal or regulatory requirements; or
• improvements to our privacy and security practices.

When we update this Privacy Policy, we will update the "Last updated" date.

Where a change materially affects how we process personal data or your rights and applicable law requires additional notice, we may provide notice through email, the Service, your account dashboard, or another appropriate method.

Your continued use of the Service does not constitute consent to processing where applicable law requires us to obtain separate consent.

17. Contact

For questions about this Privacy Policy or our processing of personal data, contact:

Trackdock Limited, trading as Trakroom

Address: 4H, Arc Farouq Musa Street, Brains and Hammers City, Life Camp, Abuja, FCT, Nigeria

Privacy and data protection: [privacy@trakroom.com](mailto:privacy@trakroom.com)

General enquiries: [info@trakroom.com](mailto:info@trakroom.com)

Phone: +234 708 425 4194

Related policies:

• Terms of Use & Digital Product Licence Agreement
• Merchant Service Agreement
• Refund, Cancellation & Subscription Policy
• Intellectual Property & Copyright Policy
• Contact Information