This Privacy Policy describes how TRAXSTERS LTD collects, uses, stores, shares, and protects your personal data when you use the Traxsters platform. Please read it carefully. By using the Platform, you consent to the practices described in this Policy.
1. Introduction
TRAXSTERS LTD ("Traxsters", "we", "us", or "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit or use our platform at www.traxsters.com (the "Platform"), including all associated mobile applications, APIs, and services.
This Policy applies to all users of the Platform, including Producers (beatmakers and sellers) and Buyers (artists and licensees), as well as any visitors who browse the Platform without registering an account.
We operate in compliance with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Act 2023 (NDPA), and other applicable data protection laws. Where our services extend to users in other jurisdictions, we take reasonable steps to comply with relevant international data protection standards, including the General Data Protection Regulation (GDPR) where applicable.
If you do not agree with the terms of this Privacy Policy, please discontinue use of the Platform immediately.
2. Information We Collect
We collect different types of information depending on how you interact with the Platform. This includes information you provide directly to us, information collected automatically, and information from third parties.
2.1 Information You Provide Directly
When you register an account, make a purchase, upload content, or otherwise interact with the Platform, we may collect:
Account registration details: full name, username, email address, and password.
Profile information: profile photo, biography, social media handles, website URL, and genre preferences.
Payment and billing information: bank account details, mobile money numbers, and billing address (note: full card numbers are handled by our third-party payment processors and are not stored on our servers).
Tax information: where required by applicable law, we may collect tax identification numbers or related documentation.
Communications: messages, support tickets, feedback, and any other correspondence you send to us.
Uploaded content: Beats, cover artwork, metadata, and any other content you submit to the Platform.
Identity verification documents: government-issued ID or other verification materials, where required for payouts or compliance purposes.
2.2 Information Collected Automatically
When you access or use the Platform, we automatically collect certain technical and behavioural data, including:
Device information: IP address, device type, operating system, browser type and version, and unique device identifiers.
Usage data: pages visited, features used, search queries, Beat previews and plays, purchase history, and session duration.
Log data: server logs, error reports, and timestamps of your interactions with the Platform.
Location data: general geographic location inferred from your IP address.
Cookies and tracking technologies: as described in Section 9 of this Policy.
2.3 Information from Third Parties
We may receive information about you from third-party sources, including:
Payment processors (e.g. Paystack, Flutterwave, Stripe): transaction confirmation and status data.
Social media platforms: if you register or log in using a social media account (e.g. Google, Facebook), we receive basic profile information such as your name, email address, and profile photo, subject to your privacy settings on that platform.
Identity verification services: results of identity checks conducted by third-party providers.
Analytics providers: aggregated usage and performance data about the Platform.
3. How We Use Your Information
We use the personal data we collect for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was collected.
Specifically, we use your information to:
Create, manage, and authenticate your account on the Platform.
Process transactions, facilitate Beat licensing, and manage payouts to Producers.
Communicate with you about your account, transactions, Platform updates, and customer support matters.
Send you marketing and promotional communications, where you have opted in to receive them (you may opt out at any time).
Personalize your experience on the Platform, including displaying relevant Beats, recommendations, and search results.
Detect, investigate, and prevent fraudulent activity, intellectual property violations, and other prohibited conduct.
Comply with applicable legal obligations, including tax reporting, anti-money laundering (AML) requirements, and responses to lawful government requests.
Enforce our Terms of Use and other applicable policies.
Analyse Platform performance, conduct research, and improve our services.
Resolve disputes between Producers and Buyers.
Protect the rights, property, and safety of TRAXSTERS LTD, our users, and the public.
4. Legal Basis for Processing
Under the NDPA 2023 and applicable data protection frameworks, we process your personal data on the following legal bases:
Contractual necessity: processing required to perform our contract with you, including operating your account, processing payments, and delivering licenses.
Legitimate interests: processing that serves our legitimate business interests (such as fraud prevention, security, and platform improvement), balanced against your privacy rights.
Legal obligation: processing required to comply with applicable laws and regulations, including Nigerian tax laws and financial regulations.
Consent: processing based on your freely given, informed, and specific consent, such as sending you marketing communications or using non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
5. How We Share Your Information
We do not sell your personal data. We only share your information in the limited circumstances described below.
5.1 With Other Users
Certain profile information is visible to other users of the Platform by default, including your username, profile photo, biography, uploaded Beats, and sales activity. Buyers who purchase your Beat will receive your display name and contact information as necessary to complete the transaction and deliver the license. You can manage your profile visibility settings in your account dashboard.
5.2 With Service Providers
We share data with trusted third-party service providers who assist us in operating the Platform, subject to binding contractual obligations of confidentiality and data protection. These providers include:
Payment processors (e.g. Paystack, Flutterwave) for handling financial transactions.
Cloud hosting and infrastructure providers for storing data and serving the Platform.
Email and communication service providers for sending transactional and marketing messages.
Analytics providers for understanding Platform usage and performance.
Identity verification providers for KYC and compliance checks.
Customer support tools for managing support tickets and communications.
Our service providers are not permitted to use your data for their own independent purposes.
5.3 For Legal and Compliance Purposes
We may disclose your information to government authorities, law enforcement agencies, or other parties when we believe in good faith that such disclosure is necessary to:
Comply with a legal obligation, court order, or regulatory requirement under Nigerian law or any applicable jurisdiction.
Protect the rights, property, or safety of TRAXSTERS LTD, our users, or the public.
Investigate and prevent fraud, security breaches, or violations of our Terms of Use.
5.4 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of all or a portion of TRAXSTERS LTD's assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you via email or a prominent notice on the Platform prior to your data being transferred and becoming subject to a different privacy policy.
5.5 With Your Consent
We may share your information with third parties in any other circumstances where you have given us your explicit, informed consent to do so.
6. Data Retention
We retain your personal data for as long as your account is active or as necessary to provide you with our services. Specifically:
Account data is retained for the duration of your account and for a period of up to 5 years after account deletion, to comply with legal, tax, and audit obligations.
Transaction records are retained for a minimum of 6 years in accordance with Nigerian financial record-keeping requirements.
Communication records (support tickets, emails) are retained for up to 3 years after the last interaction.
Marketing preferences and opt-out records are retained indefinitely to ensure we honour your communication preferences.
When data is no longer required for any legitimate purpose, we will securely delete or anonymise it. Where anonymisation is not possible, we will securely destroy the data. You may request deletion of your personal data at any time, subject to our legal retention obligations (see Section 7).
7. Your Rights
Under the NDPA 2023 and applicable data protection law, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at privacy@traxsters.com.
Right of Access: You have the right to request a copy of the personal data we hold about you and information about how we use it.
Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where we have no legal basis for retaining it. Note that we may be required by law to retain certain data.
Right to Restriction of Processing: You have the right to request that we restrict the processing of your data in certain circumstances, such as while we investigate a dispute.
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another service provider.
Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease processing your data for that purpose immediately.
Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
Right to Lodge a Complaint: You have the right to file a complaint with the Nigeria Data Protection Commission (NDPC) or any other applicable supervisory authority if you believe your data rights have been violated.
We will respond to all valid data rights requests within 30 days. In complex cases, we may extend this period by a further 30 days, and we will notify you if this is necessary.
8. Data Security
TRAXSTERS LTD implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, disclosure, alteration, or destruction. These measures include:
Encryption of data in transit using Transport Layer Security (TLS) protocols.
Encryption of sensitive data at rest within our databases.
Role-based access controls restricting employee access to personal data on a need-to-know basis.
Regular security audits, vulnerability assessments, and penetration testing.
Multi-factor authentication (MFA) options for user accounts.
Incident response procedures for detecting and responding to data breaches.
Notwithstanding the above, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with applicable law, within 72 hours of becoming aware of the breach where required.
9. Cookies and Tracking Technologies
9.1 What Are Cookies
Cookies are small text files stored on your device when you visit a website. We use cookies and similar tracking technologies (such as web beacons, pixels, and local storage) to operate and improve the Platform, personalize your experience, and analyse usage.
9.2 Types of Cookies We Use
Strictly Necessary Cookies: Essential for the Platform to function. They enable core features such as account login, session management, and security. These cannot be disabled.
Performance & Analytics Cookies: Help us understand how users interact with the Platform, which pages are most visited, and where errors occur. This data is aggregated and anonymous.
Functionality Cookies: Remember your preferences (such as language, region, and playback settings) to provide a personalized experience.
Marketing & Targeting Cookies: Used to deliver relevant advertisements and track the effectiveness of our marketing campaigns, where you have consented to this use.
9.3 Managing Cookies
You can manage your cookie preferences through our cookie consent banner when you first visit the Platform, or through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, visit www.allaboutcookies.org.
10. International Data Transfers
TRAXSTERS LTD is based in Nigeria and primarily processes your data within Nigeria. However, some of our third-party service providers (such as cloud hosting providers and payment processors) may be located outside Nigeria and may process your data in other countries, including countries within the European Economic Area (EEA) or the United States.
Where we transfer personal data outside Nigeria, we take steps to ensure that adequate safeguards are in place in accordance with the NDPA 2023, including entering into appropriate data transfer agreements and ensuring that recipient countries or organisations offer an adequate level of data protection. If you would like more information about the safeguards in place for international transfers, contact us at privacy@traxsters.com.
11. Children's Privacy
The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately at privacy@traxsters.com and we will take prompt steps to delete such data from our systems.
If we become aware that we have inadvertently collected personal data from a child under 18, we will delete that information as quickly as possible and terminate the associated account.
12. Third-Party Links and Services
The Platform may contain links to third-party websites, applications, or services that are not operated by TRAXSTERS LTD. This Privacy Policy applies solely to data collected through our Platform. We have no control over, and assume no responsibility for, the privacy practices or content of any third-party services. We strongly encourage you to review the privacy policy of every third-party site or service you visit.
Where the Platform integrates with third-party tools (such as social media platforms, payment gateways, or analytics services), your interactions with those tools are governed by their respective privacy policies.
13. Marketing Communications
With your consent, we may use your email address or phone number to send you promotional messages, newsletters, new Beat recommendations, and information about Traxsters features and offers. You can opt out of marketing communications at any time by:
Clicking the "Unsubscribe" link at the bottom of any marketing email.
Updating your notification preferences in your account settings.
Contacting us directly at support@traxsters.com.
Please note that even if you opt out of marketing communications, we will continue to send you transactional and service-related messages that are necessary for the operation of your account (such as payment confirmations, license delivery emails, and security alerts).
14. Changes to This Privacy Policy
TRAXSTERS LTD reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will:
Post the updated Policy on this page with a revised "Last Updated" date.
Notify you by email at the address associated with your account at least 14 days before the changes take effect.
Display a prominent notice on the Platform.
Your continued use of the Platform after the effective date of the revised Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you must discontinue use of the Platform and may request deletion of your account.
15. Contact Us & Data Protection Officer
If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact us at:
TRAXSTERS LTD — Data Privacy
Federal Republic of Nigeria
Privacy Enquiries: privacy@traxsters.com
General Support: support@traxsters.com
Website: www.traxsters.com
We are committed to working with you to resolve any privacy concerns fairly and promptly. If you are not satisfied with our response, you have the right to escalate your complaint to the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.
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