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 collect, use, disclose, store, and protect your information when you visit our website in Nigeria and overseas and use the Spark Ecosystem (including Spark Pay and Spark Legal). We are committed to protecting and respecting your privacy and ensuring that your personal data is handled securely and lawfully. This policy applies to our operations within the Federal Republic of Nigeria and complies with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR), and the General Data Protection Regulation (GDPR).

2. Data We Collect

We may collect, use, store, and transfer different kinds of personal data about you, with consent, 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.
  • Technical Information: IP address, device information, browser type, operating system, app usage data, cookies, and analytics data where applicable.
  • Communication Data: Messages exchanged on the Platform, customer service interactions, feedback, and surveys.

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. International Data Transfers

Because our Platform connects users globally, personal data may be transferred outside Nigeria, the UK, or the European Economic Area (EEA). Where international transfers occur, we implement appropriate safeguards including:

  • Standard Contractual Clauses (SCCs)
  • Data Processing Agreements
  • Adequacy decisions
  • Secure encryption measures

We ensure that transferred data receives adequate protection consistent with applicable laws.

6. Your Legal Rights

Under the NDPA, NDPR, and GDPR 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.

7. 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.

8. Consent

By using our Platform, you acknowledge that you have read, understood, and agreed to this Privacy Policy.