Privacy policy

1. Introduction and Scope

This Privacy Notice describes how Robovolts Energy Nigeria Limited ("we," "us," or "our") collects, uses, shares, and protects the personal data of users interacting with our platform, application, and associated hardware (collectively, the "Services").

We are committed to protecting the privacy of all users of our website, mobile applications, and social media accounts (together, the "Sites"). We comply with global data protection standards, including the Nigeria Data Protection Act (NDPA) 2023. We are the "controller" of the personal information we process, unless otherwise stated.

This Notice applies specifically to:

• Renters: Individuals who use the app to locate, rent, and return our modular solar battery capsules.
• Robovolts Generator Owners: Individuals or entities who own or manage generator hubs, provide rental inventory, and receive payments through the app.

2. Information We Collect

We collect information in three primary ways: data you provide to us, data created during your use of our Services, and data from third parties.

a) Data You Provide

• Account details: When you create an account or change settings, we collect your name, contact details, phone number, email address, and physical address.
• KYC and Identity Verification: To comply with Central Bank of Nigeria (CBN) Anti-Money Laundering (AML) directives, we collect government-issued identification. This includes processing your Bank Verification Number (BVN) or National Identity Number (NIN) through licensed verification partners, biometric data (for face-match verification), tax identification numbers, and business registration details (for commercial Custodians).
• Financial Information: Bank account details, wallet addresses, or payment card information required to facilitate rental payments and/or disburse earnings.
• Communications & Support: When you contact us or a Custodian, participate in surveys, or report an issue, we collect the conversation history, order ratings, and any photographs provided. We may also collect health information only where you explicitly volunteer it (e.g., reporting an injury involving the hardware).

b) Information Generated When You Use Our Sites

When you interact with our platform, we automatically collect essential operational data, beginning with precise or approximate location information from your mobile device. For renters, this foreground location data is critical for identifying the nearest battery available for rent, processing rental unlocks, live tracking of batteries, and navigating returns; for custodians, it allows us to verify hub deployment and actively prevent fraud and hardware theft.

Alongside location tracking, we record specific transaction and usage details—such as rental dates, times, durations, hardware travel distances, charges, and wallet balances—as well as technical device telemetry, including hardware models, operating systems, IP addresses, unique device identifiers, and mobile network information.

c) Data from Third Parties

• Financial & Authentication Providers: Data from third-party payment processors regarding the status of your wallet top-ups or withdrawals, and data from account authentication or fraud detection providers.
• Verification Partners: Information from identity verification partners confirming your KYC, BVN, or NIN status.
• Data Brokers: Demographic information from reputable data brokers to enrich our customer insights.
• Social media: If you link third-party accounts, we keep a record of your handle and data made available according to your privacy settings on those platforms.

3. How We Use Your Data

We rely on contractual necessity, legal obligations, and our legitimate business interests to process your data for the following purposes:

• To Provide the Services: Creating your account, matching Renters to Custodian hubs, unlocking hardware, processing wallet transactions, taking payments, and managing account credits.
• Safety, Security, and Fraud Prevention: Verifying your identity, tracking the physical location of unreturned batteries, ensuring the physical safety of Custodian hubs, and troubleshooting software issues.
• Financial Compliance: Disbursing earnings to Custodians, maintaining wallet ledgers, and fulfilling statutory tax reporting and AML obligations.
• Customer Support: Resolving disputes between Renters and Custodians, responding to complaints, and training our staff via interaction analysis.
• Business Improvement: Analysing traffic, testing new tools, requesting feedback, and generating aggregated statistics to improve delivery efficiency and platform features.
• Legal Defense: Defending legal claims, responding to regulatory requests, and upholding our Terms and Conditions.

Note: If you fail to provide mandatory information, you may not be able to use our Services, and we may have to cancel our contract with you.

4. How We Share Your Data

We do not sell your personal data. We share your data only as necessary:

• Between Users: Renters will see the location and public profile of Custodian hubs. Custodians will see limited details of Renters (e.g., first name, rental ID, and phone numbers) when a battery is collected or returned.
• With Service Providers: Third-party payment gateways, cloud hosting providers, and licensed identity verification services.
• For Legal Reasons: With law enforcement or regulatory bodies if required by applicable law, or in the event of a dispute requiring legal intervention (e.g., hardware theft).

5. International Data Transfers

To provide our Services reliably, the personal data we collect from you may be transferred to, and stored at, secure cloud servers located outside of Nigeria. We strictly comply with the NDPA regarding cross-border transfers. We ensure your data is protected through Standard Contractual Clauses (SCCs) or mechanisms approved by the Nigeria Data Protection Commission (NDPC) that mandate our foreign service providers treat your data with the highest security standards.

6. Data Retention and Deletion

We retain user data for as long as your account is active or as necessary to provide the Services.

• Financial & KYC Data: Retained for a minimum of 5 to 7 years to comply with global tax and AML regulations, even if your account is deleted.
• User Deletion Rights: Users may request account deletion at any time via the in-app settings or our web portal. Upon request, we will delete non-essential data and anonymize transaction histories.

7. Your Data Protection Rights

Under the NDPA and applicable global laws, you have the right to:

• Access the personal data we hold about you.
• Rectify inaccurate or incomplete data.
• Request erasure of your data (subject to legal retention requirements).
• Object to or restrict the processing of your data.
• Data Portability, allowing you to receive your data in a structured, commonly used format.
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe we have mishandled your data.

8. Security and Personal Data Breach Management

We implement industry-standard technical and organizational measures to protect your data, including encryption of data in transit (HTTPS/TLS) and at rest, secure wallet ledger architectures, and strict access controls for our personnel.

We take the security of your data seriously and have implemented strict incident response protocols. In the unfortunate event of a personal data breach (defined as the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data), we will take the following steps:

• Containment and Investigation: We will act immediately to contain the breach, secure our platform and your Robovolts Wallet, and conduct a thorough forensic investigation to determine the scope of the compromised data.
• Regulatory Notification: In compliance with the NDPA, if we determine that the breach is likely to result in a risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the incident.
• User Notification: If the breach poses a high risk to your personal, financial, or physical security (such as the exposure of KYC documents or Wallet credentials), we will notify you directly and without undue delay. This communication will clearly outline the nature of the breach, the potential consequences, the mitigation measures we have taken, and actionable steps you must take to protect yourself (such as resetting your password or verifying recent rental transactions).

9. Marketing Communications

We want to keep you informed about new Robovolts generator hubs, hardware upgrades, and special rental promotions. With your explicit consent, or where we have a legitimate business interest as permitted by law, we may send you promotional communications via:

• Email & SMS: Newsletters, discount codes, referral rewards, and ecosystem updates.
• Push Notifications & In-App Messages: Real-time alerts about nearby available batteries, dynamic pricing discounts, or new integration hardware releases.

Third-Party Marketing: We will never share or sell your personal data to third parties for their own independent marketing purposes without your explicit, opt-in consent.

Your Right to Opt-Out: You have absolute control over the marketing you receive from us. You can withdraw your consent and opt out at any time by:

• Emails: Clicking the "unsubscribe" link located at the bottom of any promotional email.
• SMS: Replying "STOP" to any promotional text message.
• Push Notifications: Adjusting the notification permissions within your mobile device's operating system settings.
• In-App: Updating your communication preferences directly within the Robovolts app account settings.

Note on Essential Service Messages: Please note that opting out of marketing communications does not apply to essential operational messages. You will continue to receive mandatory transactional notifications, such as rental receipts, wallet top-up confirmations, security alerts, and hardware recovery notices.

10. Contact Us

For privacy-related inquiries, or to exercise your data rights, please contact our Data Protection Officer at:

• Email: privacy@robovolts.com
• Mail: Attn: Data Protection Officer, Robovolts, 2nd Floor, Turbo Energy Building, Oladipo Diya road, Gudu, FCT, Nigeria