Privacy Policy

Glofluence is a verified growth network that connects brands with interest-matched participants to deliver verified, retention-linked user acquisition across Africa and beyond. We are operated by Glofluence Technologies Ltd (“the Company”, “Glofluence”, “we”, “us”, or “our”), a company registered in Nigeria, operating in the United States through SolutionCrafts LLC, a limited liability company registered in the Commonwealth of Massachusetts.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you access or use the Glofluence platform, including our website at glofluence.com, our web application, our participant experience, and any related services (collectively, the “Platform”).

Please read this policy carefully. By creating an account or using the Platform in any capacity, you acknowledge that you have read, understood, and agree to the collection and use of your information as described in this policy.

This policy applies to all individuals who interact with the Glofluence Platform, including:

• Participants — individuals who register to discover and complete verified campaigns in exchange for cash or non-cash rewards.
• Brand Users — individuals who register on behalf of a brand or business to create and fund campaigns on the Platform.
• Business Dashboard Users — participants who have unlocked the Business Dashboard to manage one or more Brand accounts.
• Visitors — individuals who visit glofluence.com or any Glofluence web property without creating an account.

Where this policy uses the term “you,” it refers to any of the above.

We collect information in three ways: information you give us directly, information generated by your use of the Platform, and information we receive from third parties.

Account registration data

When you create a Glofluence account, we collect your full name, email address, phone number, and password (stored as an encrypted hash — we never store your password in plain text). If you register via Google or Facebook OAuth, we receive the name and email address associated with that account.

Demographics and interest data

As a condition of accessing the participant marketplace, we collect your date of birth, sex, country of residence, state or province, city, occupation category, and job role or title. We also collect your selected interest categories and sub-interests from our interest taxonomy. This data is the core input to our interest-matching engine. Without it, we cannot provide you with a meaningful service.

Profile enrichment data

You may optionally provide a profile photograph, a short bio, and links to your social media profiles on Instagram, Twitter/X, TikTok, LinkedIn, and Facebook. These are stored as plain URLs at this stage.

Identity verification data

When you choose to upgrade your identity verification tier, we collect your Bank Verification Number (BVN) or National Identification Number (NIN). This data is transmitted directly to our verified KYC provider for verification. We store the outcome (pass/fail, confidence score, timestamp, provider name) but do not retain your raw BVN or NIN on our own servers beyond the duration required for the verification call.

Financial and payout data

To process cash payouts, we collect your Nigerian bank account number, bank name, and account name. To process non-cash payouts (including airtime, data, electricity, and cable TV), we collect your phone number and utility account details as applicable. We may introduce additional reward options over time, and will collect only the details necessary to deliver the reward you select.

Brand and business data

If you create a Brand account, we collect your brand name, brand email address, brand phone number, brand category, website URL, social media handle, and brand logo. If you activate a Business Dashboard, we record your stated business intent and your acceptance of the Brand Partner Terms including timestamp and IP address.

Communications

If you contact us via email, in-app support, or any other channel, we retain records of those communications.

Usage and activity data

We collect data about how you use the Platform, including the campaigns you view, start, and complete; the actions you take within campaigns; the time and duration of your sessions; and the features you interact with.

Transaction and ledger data

We maintain a complete record of all financial movements associated with your account, including rewards earned, rewards pending, rewards released, payouts requested, payouts settled, and any adjustments or clawbacks. This data is maintained for the retention periods set out in Section 6.

Device and technical data

We collect your IP address, device type, operating system, browser type and version, screen resolution, timezone, and a device fingerprint hash computed from a combination of these signals. This data is used primarily for fraud detection and platform security.

Session data

We assign a unique session identifier (session_id) to each campaign action you initiate. This identifier is shared with the relevant brand’s verification system solely to confirm the completion of your action.

KYC providers

We receive identity verification outcomes, confidence scores, and match results from our identity verification providers — currently including Prembly (IdentityPass) and Smile Identity — when you submit your BVN or NIN for verification.

Payment providers

We receive payment confirmation data, transaction references, and payment status updates from our payment providers — currently including Paystack, Flutterwave, and Stripe — when a payment is made through the Platform. This list is not exhaustive, and we may engage additional payment providers from time to time.

OAuth providers

If you register or log in via Google or Facebook, we receive your name and email address from those providers. We do not receive your passwords or payment information from OAuth providers.

• Create and maintain your account
• Authenticate your identity when you log in
• Match you to campaigns based on your interests and demographics
• Process campaign actions and verify their completion
• Calculate, stage, and release rewards to your wallet
• Process payouts to your bank account or via non-cash settlement
• Send transactional notifications about your account, rewards, and payouts

• Detect and prevent fraudulent activity, multi-accounting, and reward system abuse
• Compute device fingerprints and flag suspicious behavioural patterns
• Enforce KYC-based payout limits and eligibility gates
• Review flagged actions and take appropriate enforcement action
• Maintain audit logs of all financial transactions

• Refine the interest-matching algorithm based on your campaign completion behaviour
• Update your interest score weights based on campaign engagement
• Improve the accuracy and relevance of campaign recommendations over time

• Share the minimum necessary data with brands to enable campaign verification (session identifiers only — we do not share your name, contact details, or personal profile with brands without your explicit consent)
• Generate post-campaign reports for brands containing anonymised and aggregated participant data

• Send OTP codes for account verification and login
• Deliver transactional alerts (reward released, payout settled, campaign updates)
• Send platform announcements and important policy updates
• Respond to your support enquiries

• Comply with the NDPR, the NDPA, and all other applicable privacy and data protection laws
• Comply with applicable anti-money laundering (AML) and know-your-customer (KYC) requirements in Nigeria
• Respond to lawful requests from regulatory authorities in any applicable jurisdiction
• Maintain financial records as required by Nigerian law

• Investigate and act on breaches of our Terms of Use, Brand Partner Terms, or other platform policies
• Suspend or terminate accounts found to be in violation of our policies

We are required by applicable law to identify the legal basis on which we process your personal data.

Where the CCPA applies to you as a California resident, we identify the following business purposes for processing:

If you access the Platform from a country other than Nigeria or the United States, your personal data will be processed in accordance with this policy. Where the law of your country of residence grants you additional rights, we will honour those rights to the extent they apply to us.

We share data with third-party service providers who help us operate the Platform. All service providers are bound by data processing agreements and are required to process your data only for the purposes we specify, and to the same data protection standards we apply ourselves.

We share the following with brands in the context of campaign delivery:

• Your session identifier, for the sole purpose of verifying campaign action completion
• Aggregated, anonymised post-campaign reports — including demographic breakdowns, interest category distribution, and retention milestone data. This data does not identify you individually.

We do not share your name, email address, phone number, bank details, social media profiles, or any directly identifying personal information with brands.

We may disclose your information to law enforcement, regulators, or other authorities in Nigeria or any other applicable jurisdiction if required to do so by law, court order, or regulatory directive. This includes compliance with the NDPC, the CBN, the SEC (Nigeria), and other relevant bodies. We will notify you of such requests where we are legally permitted to do so.

If Glofluence is acquired, merged, or undergoes a significant corporate restructuring, your data may be transferred to the successor entity. We will notify you via email and in-app notice before your data is transferred and becomes subject to a different privacy policy.

We retain your personal data for as long as your account is active and for a period thereafter as required by law and our operational needs.

You may request deletion of your personal data at any time (see Section 8). Where we are required by law to retain certain data, we will delete all other data associated with your account and isolate the retained data from active processing.

We implement industry-standard technical and organisational security measures:

• All data encrypted in transit using TLS 1.2 or higher
• All data encrypted at rest using AES-256 encryption
• Authentication tokens stored in secure httpOnly cookies, expiring after 15 minutes
• Access to production systems restricted to authorised personnel only, enforced by role-based access control
• Financial transactions protected by double-entry accounting and immutable audit logs
• KYC data transmitted to verification providers over encrypted channels and not logged in transit
• Regular security reviews and vulnerability assessments

You have the following rights regarding your personal data:

To exercise any of these rights, contact us at privacy@glofluence.com. We will respond within 30 days under Nigerian law and within 45 days for verifiable consumer requests under the CCPA, extendable once by a further 45 days where reasonably necessary.

We do not use third-party advertising cookies. We do not participate in behavioural advertising networks.

Glofluence is operated from Nigeria and the United States. Your data is processed in both countries: our Nigerian entity operates the Platform and our US operations, conducted through SolutionCrafts LLC, hold certain infrastructure and service-provider relationships on our behalf. Your data may additionally be processed on servers located in other countries — including in the European Union — via our cloud infrastructure providers.

Where data is transferred outside Nigeria, we ensure that adequate protections are in place in accordance with the NDPA’s cross-border transfer provisions, including data processing agreements with all service providers.

We do not transfer data to countries or entities that do not provide an adequate level of protection without appropriate safeguards.

The Platform is not intended for individuals under the age of 16. We do not knowingly collect personal data from anyone under 16.

In the United States, the Children’s Online Privacy Protection Act (COPPA) prohibits the collection of personal information from children under 13 without verifiable parental consent. We do not knowingly collect personal information from children under 13 under any circumstances, and we do not seek such consent because the Platform is not directed to children.

If we become aware that a user is under 16, we will terminate their account and delete their data promptly. If you believe a child has registered on our Platform, please contact us immediately at privacy@glofluence.com.

We may update this Privacy Policy from time to time to reflect changes in our practices, the Platform, or applicable law.

Every version of this policy carries the date on which it was last updated and the date on which it takes effect, both shown at the top of this page. We may notify you of changes via email or in-app notification, but we are not obliged to do so, and we may make changes without individual notice.

For all privacy-related enquiries, data subject requests, or complaints: