earnvoy. / privacy notice

Privacy notice.

What we collect, why, who else touches it, and how long we keep it. Covers PIPEDA in Canada, the NDPA and NDPR in Nigeria, and the UK GDPR in the United Kingdom.

Effective Date: 10th September 2026 · Last Updated: 10th September 2026

section 01

INTRODUCTION

1.1 About This Policy

This Privacy Policy explains how Earnvoy Inc., Earnvoy Limited (Nigeria) and Earnvoy Limited (England and Wales) (collectively, "Earnvoy," "we," "us," or "our") collect, use, disclose, and protect personal information when you access or use our peer-to-peer parcel delivery marketplace platform (the "Platform").

This Privacy Policy applies to all users of the Platform, whether senders, travelers, or visitors. It should be read together with our Terms of Service and Acceptable Use Policy.

1.2 Data Controllers

For users resident in Canada, the data controller is:

Earnvoy Inc.
44 Skyview Parkway NE
Calgary, Alberta, Canada
privacy@earnvoy.com

For users resident in Nigeria, the data controller is:

Earnvoy Limited (Nigeria)
Suite 50, Swift Plaza, Aguwan Anaekwe Street, Wuye
FCT, Abuja, Nigeria
privacy@earnvoy.com

For users resident in the United Kingdom, the controller is Earnvoy Limited (England and Wales). Earnvoy Limited (England and Wales) is established in the United Kingdom. No Article 27 representative is required.

Earnvoy Limited (England and Wales)
Flat 1, 1 Park Crescent
Wolverhampton, WV1 4PY
United Kingdom
privacy@earnvoy.com

1.3 Our Commitment

We are committed to protecting your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR) in Nigeria, the UK General Data Protection Regulation and Data Protection Act 2018 in the United Kingdom, and all other relevant privacy laws.

1.4 Privacy Officer

The Privacy Contact for all three entities is:

Privacy Contact
Earnvoy Inc., Earnvoy Limited (Nigeria) and Earnvoy Limited (England and Wales)
privacy@earnvoy.com
Chidi Agu, Founder and Chief Executive Officer
Earnvoy Inc., 44 Skyview Parkway NE
Calgary, Alberta, Canada

section 02

PERSONAL INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Registration Information:

  • Full legal name
  • Date of birth
  • Email address
  • Mobile phone number
  • Country of residence
  • Preferred language

Identity Verification Information:

  • Government-issued photo identification (passport, driver's license, national ID)
  • Selfie photograph for liveness verification
  • Address verification documentation
  • For Nigerian users: Bank Verification Number (BVN) if collected, as disclosed at the point of collection
  • For Canadian users: Additional documentation as required by FINTRAC

Identity verification is performed through our third-party verification provider (Persona) and is required before you can send or carry parcels.

Financial and Payment Information:

  • Bank account details for payout
  • Payment card information (processed by our payment processor, not stored by Earnvoy directly)
  • Transaction history
  • Tax identification information where required

Trip and Parcel Information:

  • Trip details (origin, destination, dates, flight information if applicable)
  • Parcel details (contents description, dimensions, weight, declared value)
  • Booking reference (PNR) if provided by traveler (see Section 5.3 for special protections)
  • Handover and delivery documentation

Communication Content:

  • Messages exchanged with other users through the Platform
  • Communications with our support team
  • Dispute reports and evidence

Profile Information:

  • Profile photograph (optional)
  • Verification badges earned through Platform activity
  • Traveler and sender ratings

2.2 Information Collected Automatically

Device and Technical Information:

  • Device type, model, and operating system
  • Browser type and version
  • IP address
  • Mobile device identifiers
  • Application version

Usage Information:

  • Pages viewed and features used
  • Time and duration of sessions
  • Click patterns and navigation paths
  • Search queries within the Platform

Location Information:

  • Approximate location derived from IP address
  • Precise geolocation at parcel handover and delivery (with your permission, for handover verification)
  • Location data associated with trip postings

Log Data:

  • Server logs including access times, error reports, and security events

2.3 Information from Third Parties

Identity Verification Providers:

Persona and other verification partners return verification results, extracted document data, and fraud signals.

Aviation Data Providers:

AviationStack returns flight verification results, including confirmed flight number, airline, route, and scheduled times.

Payment Processors:

Paystack and other payment partners return transaction status, settlement confirmations, and dispute notifications.

Banking Partners:

Our licensed banking partnership (Sourced Microfinance Bank in Nigeria and the applicable Canadian payment or safeguarding provider) returns escrow status and settlement information.

Analytics Providers:

Plausible Analytics provides anonymized aggregate usage data. Plausible is privacy-first and does not use cookies or collect personal information.

2.4 Sensitive Personal Information

We collect certain categories of information that may be considered sensitive under applicable law:

  • Government-issued identification numbers (for identity verification and regulatory compliance)
  • Financial account information (for payments and payouts)
  • Biometric information (facial recognition in selfie verification, processed by our verification provider)
  • Precise geolocation (at handover and delivery, with your permission)

We collect this information only where necessary for the specific purposes described in Section 3 and protect it with enhanced security measures described in Section 8.

section 03

HOW WE USE YOUR INFORMATION

3.1 To Provide the Platform

  • Create and maintain your account
  • Facilitate matches between senders and travelers
  • Process payments and payouts
  • Verify identity and eligibility
  • Verify flights at match acceptance
  • Communicate about your transactions
  • Provide customer support
  • Enable dispute resolution

3.2 To Ensure Trust and Safety

  • Verify user identity
  • Detect and prevent fraud, abuse, and illegal activity
  • Enforce our Terms of Service and Acceptable Use Policy
  • Investigate reported violations
  • Protect the rights, property, and safety of Earnvoy, our users, and others

3.3 To Comply with Legal Obligations

  • Comply with anti-money laundering (AML) and know-your-customer (KYC) requirements
  • Make reports or disclosures to competent authorities where Earnvoy or the relevant regulated provider is required or permitted by applicable law
  • Maintain records as required by law
  • Respond to lawful requests from law enforcement or courts
  • Comply with tax reporting obligations

3.4 To Improve the Platform

  • Analyze usage patterns to improve features
  • Test and debug the Platform
  • Conduct research and analytics
  • Develop new features and services

3.5 To Communicate with You

  • Send transactional communications (match confirmations, payment notifications, delivery updates)
  • Respond to your inquiries and support requests
  • Send service announcements and Platform updates
  • Send marketing communications, only with your explicit consent (see Section 4.4)

3.6 Legal Bases for Processing (UK GDPR)

For users to whom the UK GDPR applies, we process personal information based on the following legal bases:

Contract Performance (Article 6(1)(b)): Processing necessary to provide the Platform and fulfill our obligations under the Terms of Service.

Legal Obligation (Article 6(1)(c)): Processing necessary to comply with AML, KYC, tax, and other legal obligations.

Legitimate Interests (Article 6(1)(f)): Processing for fraud prevention, security, and improving the Platform, where these interests are not overridden by your rights and freedoms.

Consent (Article 6(1)(a)): Processing based on your explicit consent, including for marketing communications and precise geolocation. You may withdraw consent at any time.

Vital Interests (Article 6(1)(d)): In rare circumstances, processing to protect vital interests of you or another person.

For UK biometric data used to uniquely identify a person, Earnvoy must establish both an Article 6 lawful basis and a separate Article 9 condition. Earnvoy may rely on explicit consent under Article 9(2)(a) where that consent is freely given, specific, informed, unambiguous, and capable of withdrawal without unlawful detriment. Article 9(2)(g) will be relied upon only where the particular processing is necessary for a substantial public interest expressly grounded in applicable UK domestic law, the statutory conditions and safeguards are satisfied, and an appropriate policy document is maintained where required. A general legal obligation or ordinary identity-verification purpose does not by itself satisfy Article 9(2)(g).

section 04

HOW WE SHARE YOUR INFORMATION

4.1 With Other Users

To facilitate transactions on the Platform, certain information is shared between senders and travelers:

Sender to Traveler:

  • First name and last initial
  • Parcel description (excluding sensitive contents details)
  • Pickup and delivery location details
  • Rating and completed transactions count

Traveler to Sender:

  • First name and last initial
  • Trip route and dates
  • Flight verification status (verified, not verified, reviewer-confirmed)
  • Existence of booking reference (but never the reference value itself — see Section 5.3)
  • Rating and completed transactions count

We do not share sensitive personal information (full identification, financial account details, precise addresses, booking reference values) between users.

4.2 With Service Providers

We share personal information with service providers who help us operate the Platform, including:

Identity Verification:
Persona (personal information for identity verification, including government ID, selfie, biometric data)

Payment Processing:
Paystack, other processors identified in our current service-provider register (payment card information, transaction details)

Banking and Escrow:
Sourced Microfinance Bank (escrow account information, settlement instructions)
the applicable Canadian payment or safeguarding provider

Aviation Data:
AviationStack (flight numbers and dates for verification queries — no other personal information transmitted)

Cloud Infrastructure:
Railway (application hosting), MongoDB Atlas (database), other infrastructure providers identified in our current service-provider register

Communications:
our transactional email provider (transactional email delivery)
our messaging provider, if used

Analytics:
Plausible Analytics (anonymized usage data only, no personal information)

Push Notifications:
Apple Push Notification service (APNs), Firebase Cloud Messaging (FCM) (device tokens for notification delivery)

Service providers are contractually required to protect your personal information and use it only for the purposes we specify.

4.3 With Regulatory Authorities and Law Enforcement

We disclose personal information to regulatory authorities and law enforcement where required by law, including:

Canada:

  • FINTRAC, where Earnvoy or the relevant Canadian reporting entity is legally required or permitted to report
  • Canada Revenue Agency for tax reporting
  • Office of the Privacy Commissioner of Canada for privacy-related regulatory matters
  • Courts, law enforcement agencies with valid legal process

Nigeria:

  • Nigeria Financial Intelligence Unit (NFIU), where Earnvoy or the relevant Nigerian reporting entity is legally required or permitted to report
  • Federal Inland Revenue Service for tax reporting
  • Nigeria Data Protection Commission (NDPC) for privacy-related regulatory matters
  • Courts, law enforcement agencies with valid legal process

We may also disclose personal information to protect the rights, property, or safety of Earnvoy, our users, or others, or to detect, prevent, or otherwise address fraud or security issues.

4.4 For Marketing Purposes

Marketing communications are opt-in only. We do not send marketing communications unless you have explicitly consented at signup or in your account settings.

If you consent to marketing communications, we may send you:

  • Updates about new features
  • Corridor availability announcements
  • Trust and safety education
  • Occasional promotional content

You may withdraw consent at any time by:

  • Clicking the unsubscribe link in any marketing email
  • Updating your notification preferences in account settings
  • Contacting privacy@earnvoy.com

Transactional communications (match confirmations, payment notifications, delivery updates, security alerts) are not subject to marketing consent and cannot be opted out of while you have an active account.

4.5 Business Transfers

If Earnvoy is involved in a merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

4.6 With Your Consent

We may share your personal information for other purposes with your explicit consent.

section 05

SPECIAL PROTECTIONS FOR CERTAIN DATA

5.1 Government Identification Numbers

Government-issued identification numbers (passport, driver's license, national ID, BVN, SSN if applicable) are:

  • Collected only for identity verification and regulatory compliance
  • Never displayed in your account or to other users
  • Encrypted in storage
  • Accessed only by authorized personnel for legitimate purposes
  • Retained for the periods required by law and then deleted

5.2 Financial Account Information

Financial account information (bank account details, payment card information):

  • Payment card information is processed by our PCI-DSS certified payment processor and not stored by Earnvoy directly
  • Bank account details for payout are encrypted in storage
  • Displayed to you in masked form (last four digits only)
  • Never displayed to other users

5.3 Booking References (PNR)

Booking references, if provided by travelers as part of flight verification:

  • Are entirely optional
  • Are never displayed to senders (senders see only that a reference has been provided)
  • Are visible to travelers in their own trip records
  • Are accessible to Earnvoy's administrators only when reviewing disputes or verification concerns, in a restricted admin-only interface
  • Are encrypted in storage

The distinction between "reference exists" (visible to senders) and "the reference value" (never visible to senders) is a deliberate privacy safeguard.

5.4 Biometric Information

If selfie comparison or liveness checks create or use biometric data for the purpose of uniquely identifying a person, that processing may be sensitive or special-category processing. Earnvoy and its identity-verification provider will process it only after providing a specific notice and establishing every lawful basis required in the relevant jurisdiction. For UK users, this includes an Article 6 basis and an applicable Article 9 condition, such as explicit consent where appropriate. For Canadian users, Earnvoy will obtain meaningful consent where required. For Nigerian users, Earnvoy will rely on consent or another condition permitted for sensitive personal data. Biometric processing:

  • Is processed by our identity verification provider (Persona)
  • Is not intended to be stored by Earnvoy directly; this statement must be verified against the implemented data flow, logs, backups, and vendor configuration
  • Is retained by the provider only for the configured and legally permitted period disclosed at collection
  • Is used solely to verify that you are the person depicted in your government identification

5.5 Location Information

Precise geolocation collected at parcel handover and delivery:

  • Is collected only with your explicit permission
  • Is used solely to verify handover events
  • Is retained with the transaction record
  • Is not used for real-time tracking or continuous location monitoring

5A. CONTROLLER ROLES AND LAWFUL BASES

Earnvoy Inc. is the controller for Canadian users. Earnvoy Limited (Nigeria) is the controller for Nigerian users. Earnvoy Limited (England and Wales) is the controller for UK users. Each is a separate legal entity. The entities may act as separate controllers when each determines its own purposes and means, or as joint controllers for shared cross-border platform functions. Internal arrangements allocate privacy responsibilities without limiting any individual’s rights.

Depending on the activity and jurisdiction, processing is based on performance of a contract, compliance with legal obligations, legitimate interests such as fraud prevention and platform security, consent, or another lawful basis. Where consent is required, it will be specific and capable of withdrawal. We do not treat acceptance of the Terms as blanket consent to unrelated processing.

section 06

INTERNATIONAL DATA TRANSFERS

6.1 Cross-Border Data Flows

Because Earnvoy operates in Canada, Nigeria, and the United Kingdom, and because we use service providers located in various jurisdictions (including the United States and European Union), your personal information may be transferred to and processed in countries other than your country of residence.

6.2 Transfer Safeguards

Where personal information is transferred internationally, we implement appropriate safeguards, including:

For transfers from Canada:
Contractual provisions requiring recipients to provide protection substantially equivalent to PIPEDA.

For transfers from Nigeria:
Contractual provisions and consent mechanisms compliant with the NDPA and NDPR.

For restricted transfers from the United Kingdom: UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved EU Standard Contractual Clauses, or another lawful safeguard, together with a transfer risk assessment where required.

For transfers to the United States or another country without an applicable adequacy decision, we use the safeguards required by the law governing the relevant user, supplemented where necessary by technical and organisational measures.

6.3 Specific Cross-Border Flows

Personal information flows between:

  • Your device and our servers (hosted in the hosting region(s) identified in our current service-provider register)
  • Our servers and service providers (variously located in Canada, United States, European Union)
  • Between Earnvoy Inc., Earnvoy Limited (Nigeria) and Earnvoy Limited (England and Wales), including processing connected with Canadian, Nigerian, and United Kingdom users and transactions

section 07

YOUR PRIVACY RIGHTS

Your privacy rights depend on where you reside. We provide the following rights to all users to the extent applicable law permits or requires.

7.1 Rights of Canadian Users (PIPEDA)

Under PIPEDA, you have the right to:

  • Access: Request access to your personal information we hold
  • Correction: Request correction of inaccurate personal information
  • Withdraw Consent: Withdraw consent to the collection, use, or disclosure of your personal information, subject to legal and contractual restrictions
  • Complaint: File a complaint with the Office of the Privacy Commissioner of Canada if you believe we have not complied with PIPEDA

To exercise these rights, contact privacy@earnvoy.com. We will respond within thirty (30) days as required by PIPEDA.

7.2 Rights of Nigerian Users (NDPA and NDPR)

Under the Nigeria Data Protection Act 2023 and NDPR, you have the right to:

  • Access: Request access to your personal information we hold
  • Rectification: Request correction of inaccurate or incomplete personal information
  • Erasure: Request deletion of your personal information in certain circumstances
  • Restriction: Request restriction of processing in certain circumstances
  • Data Portability: Receive your personal information in a structured, machine-readable format
  • Object: Object to certain processing activities
  • Withdraw Consent: Withdraw consent where processing is based on consent
  • Complaint: File a complaint with the Nigeria Data Protection Commission (NDPC)

To exercise these rights, contact privacy@earnvoy.com. We will respond within thirty (30) days as required by the NDPA.

7.3 Rights of United Kingdom Users (UK GDPR)

If you are located in the United Kingdom, you have the right to:

  • Access: Obtain confirmation of processing and access to your personal information
  • Rectification: Request correction of inaccurate personal information
  • Erasure ("Right to be Forgotten"): Request deletion of your personal information
  • Restriction: Request restriction of processing
  • Data Portability: Receive your personal information in a structured, machine-readable format
  • Object: Object to processing based on legitimate interests or for direct marketing
  • Not Be Subject to Automated Decision-Making: Where applicable, not be subject to decisions based solely on automated processing
  • Withdraw Consent: Withdraw consent where processing is based on consent
  • Complaint: File a complaint with your local supervisory authority

To exercise these rights, contact privacy@earnvoy.com. We will respond without undue delay and ordinarily within one month, subject to any lawful extension under the UK GDPR.

7.4 Verification of Identity for Rights Requests

To protect your privacy, we require verification of your identity before responding to rights requests. We may ask for additional information to confirm your identity, which we will use only for verification purposes.

7.5 Limitations on Rights

Certain rights are subject to limitations under applicable law, including:

  • We may retain personal information required by an applicable legal or regulated-provider obligation, including a FINTRAC or NFIU retention rule only where that rule applies to the relevant entity and record
  • We may retain personal information necessary to establish, exercise, or defend legal claims
  • We may retain personal information necessary for fraud prevention

Where a right cannot be fully honored due to a legal or contractual obligation, we will explain the reason.

section 08

DATA SECURITY

8.1 Security Measures

We use, or require service providers to use, technical and organisational safeguards appropriate to the risk. The measures actually implemented may include the following, but each claim must be verified against current system and vendor configurations before publication:

  • Encryption in transit using supported industry-standard protocols
  • Encryption or equivalent protection for sensitive information at rest where supported and appropriate
  • Access controls limiting personnel access to personal information based on role and need
  • Multi-factor authentication for privileged or sensitive-system access where implemented
  • Risk-based security testing, vulnerability management, and independent review where appropriate
  • Secure development practices including code review and dependency management
  • Incident detection and response procedures
  • Employee training on privacy and security

8.2 No System Is Perfectly Secure

Despite our safeguards, no system is completely secure. We cannot guarantee absolute security of your personal information. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying us of any unauthorized access to your account.

8.3 Data Breach Notification

In the event of a personal data breach affecting your rights and freedoms, we will:

  • Notify affected users without undue delay where required by law
  • Notify the applicable supervisory authorities within the timelines required by law (the applicable statutory period, including notification to the ICO without undue delay and, where feasible, within 72 hours when UK law requires it)
  • Take appropriate steps to mitigate the breach and prevent recurrence

section 09

DATA RETENTION

9.1 Retention Periods

We retain personal information only for as long as reasonably necessary for the disclosed purpose and any applicable legal, tax, accounting, anti-money-laundering, payment, fraud-prevention, dispute, or recordkeeping requirement. Retention is governed by a documented schedule and the starting point may differ by record type.

Financial Transaction Records: Retained for the period required by the law applicable to Earnvoy or the regulated payment provider. Canadian tax and accounting records are commonly retained for six (6) years from the end of the relevant tax year. A FINTRAC period applies only if Earnvoy or the relevant provider is a reporting entity and depends on the record type. Nigerian payment, tax, and anti-money-laundering periods must be confirmed with the regulated provider and reflected in Earnvoy’s retention schedule.

Identity Verification and KYC Records: Retained for the legally required period applicable to the responsible reporting entity or verification provider, which may commonly be at least five (5) years under applicable anti-money-laundering rules. The trigger may be verification, transaction completion, or the end of the business relationship. Earnvoy will not apply a FINTRAC or NFIU period unless the relevant entity, record, and legal obligation have been confirmed.

Support and Dispute Records: Three (3) years after resolution.

Account Data (non-transactional): Retained while the account is active and then deleted or anonymised under the documented retention schedule, subject to backup cycles, fraud prevention, disputes, and legal holds. The previously proposed thirty-day deletion period must be confirmed operationally before publication.

Marketing Consent Records: Retained as long as consent is active, plus a reasonable period after withdrawal to demonstrate compliance.

Communication Records: Retained for three (3) years after your last communication, unless longer retention is required.

Log and Analytics Data: Retained in identifiable form only for the security, reliability, analytics, and legal period documented in the retention schedule, then deleted or anonymised. The production retention period must be confirmed before publication.

9.2 Retention Beyond Standard Periods

We may retain personal information beyond the standard periods where:

  • Required by law or regulation
  • Necessary for legal claims, disputes, or investigations
  • Necessary for fraud prevention
  • Anonymized so that it can no longer be linked to you

9.3 Deletion Upon Request

You may request deletion of your personal information as described in Section 7. We will delete or anonymize your personal information within the timelines required by applicable law, except where retention is required.

section 10

COOKIES AND TRACKING TECHNOLOGIES

10.1 Our Approach

We use minimal cookies and tracking technologies. Because we use Plausible Analytics (a privacy-first, cookieless analytics platform), we do not require cookies for analytics purposes.

10.2 Cookies We Use

Strictly Necessary Cookies: Session cookies required for authentication and Platform functionality. These cookies do not track you across sites.

Functional Cookies: Cookies that remember your preferences (language, notification settings). These are set only where necessary.

We do not use advertising cookies or third-party tracking cookies.

10.3 Managing Cookies

You may manage cookies through your browser settings. Disabling strictly necessary cookies will affect Platform functionality.

section 11

CHILDREN'S PRIVACY

The Platform is not intended for use by anyone under the age of eighteen (18). We do not knowingly collect personal information from anyone under 18.

If we learn that we have collected personal information from someone under 18, we will delete that information promptly. If you believe we may have collected personal information from someone under 18, contact privacy@earnvoy.com.

section 12

AUTOMATED DECISION-MAKING

12.1 Where We Use Automated Decision-Making

We use automated processing in certain limited contexts:

  • Identity Verification Scoring: Our identity verification provider uses automated processes to assess verification submissions. Results are reviewed by human personnel for edge cases.
  • Fraud Detection: We use automated systems to flag potentially fraudulent activity. Flagged activity is reviewed by human personnel.
  • Flight Verification: Automated verification of flight status through our aviation data provider. Outage cases proceed to human review.

12.2 Your Right to Human Review

Where automated decisions significantly affect you (such as account restriction), you have the right to request human review of the decision. Contact privacy@earnvoy.com to request review.

12.3 No Profiling for Advertising

We do not use profiling or automated decision-making for advertising purposes.

section 13

CHANGES TO THIS PRIVACY POLICY

13.1 Updates

We may update this Privacy Policy from time to time. When we make material changes, we will:

  • Post the updated Privacy Policy on the Platform with a revised "Last Updated" date
  • Notify you through the Platform or by email at least thirty (30) days before material changes take effect
  • Where required by law, obtain your consent for material changes

13.2 Continued Use

An updated Privacy Policy is a notice, not a substitute for consent or another lawful basis. Continued use may acknowledge receipt of updated information or acceptance of related contractual service changes, but it will not be treated as consent to a new processing purpose where applicable law requires consent. We will obtain fresh, specific consent before beginning processing that requires it. You may stop using the Platform or close your account, subject to legal retention obligations.

section 14

CONTACT US AND COMPLAINTS

14.1 General Inquiries

For questions about this Privacy Policy or our privacy practices:

Email: privacy@earnvoy.com
Postal (Canada):
Earnvoy Inc.
Attention: Privacy Officer
44 Skyview Parkway NE
Calgary, Alberta, Canada

Postal (Nigeria):
Earnvoy Limited (Nigeria)
Attention: Privacy Contact
Suite 50, Swift Plaza
Aguwan Anaekwe Street, Wuye
FCT, Abuja, Nigeria

Postal (United Kingdom):
Earnvoy Limited (England and Wales)
Attention: Privacy Contact
Flat 1, 1 Park Crescent
Wolverhampton, WV1 4PY
United Kingdom

14.2 Complaints Process

If you believe we have not complied with this Privacy Policy or applicable privacy laws, please contact our Privacy Officer at privacy@earnvoy.com. We will:

  • Acknowledge your complaint within seven (7) days
  • Investigate the complaint
  • Respond with our findings within thirty (30) days
  • Take appropriate steps to address any confirmed non-compliance

14.3 External Complaints

If you are not satisfied with our response, you have the right to file a complaint with:

Canada:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
1-800-282-1376
https://www.priv.gc.ca

Nigeria:
Nigeria Data Protection Commission
Current contact details: https://ndpc.gov.ng

United Kingdom:
Information Commissioner’s Office (ICO)
https://ico.org.uk

section 15

JURISDICTION-SPECIFIC PROVISIONS

15.1 Canada

Canadian users may also have rights under substantially similar provincial private-sector privacy laws, including those of Alberta, British Columbia, and Quebec, where applicable. Earnvoy will apply the law governing the relevant processing and will not reduce a right available under mandatory provincial law.

15.2 Nigeria

Earnvoy Limited (Nigeria) processes personal data in accordance with the Nigeria Data Protection Act 2023 and applicable directives of the Nigeria Data Protection Commission. Where required, Earnvoy will conduct data protection impact assessments, make required filings, appoint appropriate compliance personnel, and use a lawful basis and transfer mechanism.

15.3 United Kingdom

Earnvoy Limited (England and Wales) processes UK personal data under the UK GDPR and Data Protection Act 2018. We identify a lawful basis for each purpose, apply the additional conditions required for special-category or criminal-offence data, honour applicable data-subject rights, and use UK-compliant safeguards for restricted transfers.