Privacy Policy

1. Data We Collect

• Profile data: username, display name, avatar seed/output, account creation metadata.
• Authentication data: linked provider identifiers (Google, Apple, Email) and email address for permanent accounts.
• Content data: spills, replies, reactions, likes, bookmarks, follows, and notification events.
• Safety and moderation data: block lists, safety settings, word filters, and moderation events.
• Approximate geolocation: city/state/country inferred from request headers when available.
• Technical anti-abuse signals: captcha verification input and IP context used for verification and security checks.
• Payment anti-fraud data: IP address captured and used for fraud prevention on payment requests.
• Device signals: a hashed device fingerprint used for safety controls, including account abuse detection and fraud prevention.
• Fraud intelligence records: fraud signals, chargeback history, and risk review metadata.
• KYC compliance records: identity verification data and status, including KYC documents processed by [KYC provider].
• Payment and billing data: transaction references, processor-assigned identifiers, payment status, and tip settlement amounts processed via Stripe or Paystack. We do not store full card numbers or raw banking credentials — these are held exclusively by the payment processor.
• Wallet and earnings data: tip credit records, payout requests, and wallet balance counters stored in our operational systems to fulfil creator payouts.

2. Why We Process Data (Purpose)

• To create, maintain, and secure user accounts and sessions.
• To deliver core features: anonymous messages, thread replies, feeds, follows, bookmarks, and notifications.
• To protect users and platform integrity through abuse prevention, moderation, and anti-bot checks.
• To communicate service notifications (including email alerts where enabled and linked).
• To maintain logs and operational analytics required for reliability, safety, and troubleshooting.
• To process payments, record tip settlements, credit creator wallets, and action payout requests on the basis of contractual necessity.
• To detect and prevent payment fraud, velocity abuse, and chargebacks as a legitimate interest in protecting platform and user financial integrity.
• To enforce account safety controls, including limits on how many permanent accounts can be created or logged in from one device hash.
• To analyze behavioral patterns (including tip frequency, engagement rate, and device usage) for fraud scoring and abuse prevention.
• To use geographic location signals to detect suspicious account activity; such signals are not sold or shared with unrelated third parties for marketing use.

3. Lawful Bases Under Nigerian Law

• Contractual necessity: to provide the service you request.
• Legitimate interests: to secure, improve, and moderate the platform.
• Consent: where required, including optional settings and communications preferences.
• Necessary processing: security and anti-abuse processing required to provide a safe service environment.
• Legal obligation: where processing is required by applicable law or lawful authority.

4. Cookies and Local Storage

5. Processors and Cross-Border Transfers

We use vetted service providers to run core operations. Depending on provider infrastructure, data may be processed outside Nigeria. Where cross-border transfers occur, we apply contractual and organizational safeguards required under applicable law.

• Google Firebase (Authentication and Firestore data hosting)
• Upstash Redis (sessions, caching, counters and operational keys)
• Cloudflare Turnstile (anti-bot verification)
• Resend (transactional email delivery where enabled)
• Stripe (payment processing for USD transactions — card data held exclusively by Stripe)
• Paystack (payment processing for NGN transactions — card data held exclusively by Paystack)
• Vercel (application hosting, infrastructure telemetry, deployment runtime)

6. Security and Retention

• Sensitive profile fields and content are encrypted at rest in our managed data architecture.
• Access controls, provider-level security, and server-side checks are used to reduce unauthorized access risks.
• We retain data for as long as needed to provide services, comply with legal obligations, and resolve disputes.
• Short-lived operational caches and intent/security tokens are retained for limited periods by design.
• Fraud signals and chargeback history are retained for up to 90 days, then anonymised or aggregated where feasible.
• KYC documents are processed and stored by [KYC provider] and deleted after the applicable verification window and compliance retention period.

7. Your Rights Under NDPA

Subject to legal limits and verification requirements, you may request access, correction, erasure, restriction, objection, and where applicable portability of your personal data, and withdraw consent where consent is the lawful basis.

You also have a right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

8. Children and Safety

Spill It is not intended for children under 13. If you are under 18, you should use the service with parental or guardian guidance. We may remove or restrict accounts or content where required for safety or legal compliance.

9. Contact and Updates

For privacy requests or complaints, contact us at support@spillit.top. We may update this Policy to reflect legal, technical, or service changes and will update the date above when material revisions are made.