Legal Documentation

Privacy Policy

Effective Date: May 2026

1. Introduction

TSN Digital Solutions ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and use the Spark Ecosystem (including Spark Pay, Spark Legal, and Spark Artisan). This policy applies to our operations within the Federal Republic of Nigeria and complies with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR).

2. Data We Collect

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data: First name, maiden name, last name, username, marital status, title, date of birth, and gender.
  • Contact Data: Billing address, delivery address, email address, and telephone numbers.
  • Financial Data: Bank account and payment card details (specifically for Spark Pay).
  • Biometric Data: Fingerprint or facial recognition data used exclusively for our "Biometric Handshake" local authentication.

3. Lawful Basis for Processing

Under the NDPA, we must have a lawful basis for processing your personal data. We rely on the following bases:

  • Consent: Where you have provided clear consent for us to process your personal data for a specific purpose.
  • Contract: Where processing is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract.
  • Legal Obligation: Where we need to comply with a legal or regulatory obligation in Nigeria (e.g., AML/CFT regulations by the CBN).

4. Data Security & H-Seal Verification

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. The Spark ecosystem utilizes military-grade End-to-End Encryption and proprietary H-Seal Verification to guarantee the integrity of your data and documents.

5. Your Legal Rights

Under the NDPA and NDPR, you have rights under data protection laws in relation to your personal data, including the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data (Right to be Forgotten).
  • Object to processing of your personal data.
  • Request the transfer of your personal data.

6. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer (DPO) at:
Email: info@tsndigitalsolutions.com
Address: 1 Rudy Ohikhokhai Street, Iyowa, off Benin-Akure Road, Benin City, Edo State.