1. Introduction
This Privacy Policy explains how Symverge Technologies Limited ("we", "us", or "our"), as Data Controller, collects, uses, stores, shares, and protects personal data when you use the Public Notice System ("the Platform") — the official digital registry for publishing and verifying public notices in Federal Republic of Nigeria.
We are committed to protecting your privacy and processing personal data in accordance with the Nigeria Data Protection Regulation 2019 (NDPR), the Nigeria Data Protection Act 2023 (NDPA), the NDPR Implementation Framework 2020, and other applicable Nigerian laws.
By using the Platform, submitting a notice, or otherwise providing personal data to us, you acknowledge that you have read and understood this Privacy Policy. Where we rely on consent, we will obtain it separately and you may withdraw it at any time as described below.
2. Definitions
For the purposes of this Privacy Policy, the following terms have the meanings assigned under the NDPR and NDPA:
- Personal Data: any information relating to an identified or identifiable natural person.
- Sensitive Personal Data: personal data relating to genetic or biometric data, race, ethnic origin, religious beliefs, health status, sex life, political opinions, trade union membership, or other categories designated by the Nigeria Data Protection Commission (NDPC).
- Data Subject: the individual to whom personal data relates.
- Data Controller: the entity that determines the purposes and means of processing personal data.
- Data Processor: the entity that processes personal data on behalf of the Data Controller.
- Processing: any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
- Public Notice Data: notice content that you elect to publish and that becomes part of the public national registry.
3. Scope and Applicability
This Privacy Policy applies to personal data we process when you visit the Platform, start or complete a change-of-name notice, make a payment, upload supporting documents, search or verify notices, receive transactional communications from us, or interact with our administrative systems.
This policy does not apply to third-party websites or services linked from the Platform. We encourage you to review the privacy policies of any third-party services you use.
4. Categories of Personal Data We Collect
We collect only personal data that is adequate, relevant, and limited to what is necessary for the purposes described in this policy.
4.1 Identity and Notice Information
- Former legal name and new legal name
- Reason for the name change (e.g. marriage, spelling correction, religious, cultural, family, or other)
- Optional explanation (where "other" is selected)
4.2 Contact Information
- Email address (required)
- Nigerian phone number (optional)
4.3 Supporting Documents
We collect scanned or photographed affidavit images uploaded for verification purposes. These documents may contain additional personal data such as signatures and identification details.
4.4 Payment Information
Payment details are processed by our payment service provider. We do not store full card or bank account details on our systems. We only retain transaction references, status, amount, currency, and timestamp.
4.5 Public Notice Data (Intentionally Published)
When you publish a notice, the following information becomes part of the permanent public national registry and is accessible to anyone:
- Public Notice Number (PNN)
- Former name and new name
- Reason for the name change (and optional explanation, where provided)
- Publication date and verification status
Note: Your email address, phone number, and affidavit images are not published on the public registry.
5. Lawful Basis for Processing
We process personal data only where a lawful basis exists under NDPR Article 2.1 and Section 25 of the NDPA. The bases we rely on include:
- Consent: where you voluntarily provide data and agree to processing, including your explicit consent to public publication of notice content before payment and publication.
- Contract: where processing is necessary to perform our agreement with you to publish your notice and issue your PNN and certificate.
- Legal obligation: where we must retain or disclose data to comply with applicable Nigerian law, regulatory requests, or valid court orders.
- Public interest: where processing supports the operation of an official public notice registry in the public interest.
- Legitimate interests: where processing is necessary for fraud prevention, platform security, service improvement, and protection of our systems, balanced against your rights (e.g. hashed session binding, rate limiting, audit logging).
- Vital interests: in rare cases where processing is necessary to protect the vital interests of you or another person.
6. Purposes of Processing
We use personal data for the following specific, explicit, and legitimate purposes:
- Operating the change-of-name publication workflow from draft to live notice
- Verifying uploaded affidavits using automated document analysis
- Processing payments and confirming successful transactions
- Generating and assigning a unique Public Notice Number (PNN) and digital certificate
- Publishing approved notice content to the searchable public registry
- Sending transactional emails (e.g. resume links and publication confirmations)
- Preventing fraud, abuse, duplicate submissions, and unauthorised draft access
- Maintaining audit logs and administrative records
- Responding to data subject requests and regulatory enquiries
- Complying with NDPR, NDPA, and other legal obligations
7. Public Publication of Notice Data
A core function of the Platform is the lawful public disclosure of notice content. Before publication, you must confirm that the information is accurate and expressly consent to public publication as described in our Terms of Use.
Once published, your former name, new name, PNN, reason for change, and publication date become part of the permanent public registry and may be indexed by search engines. This processing is intentional, and you may not withdraw consent for the public portion after publication without a valid legal basis for restriction or erasure.
We apply data minimisation to the public registry: email addresses, phone numbers, payment references, affidavit files, and internal identifiers are never exposed in public search results or API responses.
8. Data Processors and Third-Party Recipients
We share personal data with trusted third-party service providers only where necessary to operate the Platform and deliver our services. These providers are engaged under written agreements that require them to handle personal data in compliance with the NDPR and NDPA. We do not permit them to use your personal data for their own marketing purposes or any purpose unrelated to the services they provide to us.
We engage the following categories of service providers:
- Payment processing providers
- Email and communication delivery services
- Cloud storage and infrastructure providers
- Security and content delivery services
- Automated analysis and verification service providers (used strictly for internal processing with no public exposure)
9. International Data Transfers
Some of our processors may store or process data outside Nigeria. Where personal data is transferred internationally, we ensure appropriate safeguards as required by NDPR Article 2.12 and Part IX of the NDPA, including contractual clauses, adequacy assessments, and security controls.
By using the Platform, you acknowledge that limited technical processing (such as email delivery, cloud storage, or AI verification) may occur in jurisdictions outside Nigeria, subject to the safeguards described above.
10. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer period is required by law.
- Published notice records (public registry): retained permanently as part of the national public notice archive, unless deletion is required by law or a valid erasure request is granted where legally permissible.
- Draft applications not published: retained for up to three (3) years after last activity, then securely deleted.
- Payment and transaction records: retained for six (6) years after the last transaction, in line with the NDPR Implementation Framework and accounting requirements.
- Affidavit files for unpublished drafts: deleted when the draft is deleted or after the draft retention period expires.
- Affidavit files for published notices: retained for the duration of the published record for verification and dispute resolution, in private storage.
- Technical logs and security records: retained for up to twelve (12) months unless required longer for investigations.
10.1 Secure destruction
When retention periods expire, personal data is securely deleted or irreversibly anonymised in accordance with industry best practices.
11. Security Measures
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure.
These measures include:
- Encryption of data in transit and at rest
- Strict access controls and authentication mechanisms
- Protection of uploaded documents, including metadata handling
- Secure logging and monitoring of system activity
- Regular security assessments, testing, and updates
12. Your Rights as a Data Subject
Under the NDPR and NDPA, you have the following rights in relation to your personal data, subject to applicable exceptions:
- Right of access — to obtain confirmation of processing and a copy of your personal data
- Right to rectification — to request correction of inaccurate or incomplete data
- Right to erasure — to request deletion where processing is no longer necessary, consent is withdrawn, or processing is unlawful (subject to legal and public-registry limitations)
- Right to restriction of processing — to request limitation of processing in specified circumstances
- Right to data portability — to receive your data in a structured, commonly used, machine-readable format where technically feasible
- Right to object — to object to processing based on legitimate interests
- Right to withdraw consent — at any time, without affecting the lawfulness of processing before withdrawal
- Right not to be subject to solely automated decisions with significant effects, except where permitted by law with appropriate safeguards
12.1 How to exercise your rights
To exercise any of these rights, please contact our Data Protection Officer at dpo@publicnotice.ng. We will respond to your request in accordance with applicable data protection law. We may ask you to verify your identity before processing your request.
We do not charge a fee for standard requests. Where a request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable administrative fee or refuse the request as permitted by law.
12.2 Limitations
Your rights may be limited where processing is necessary for compliance with a legal obligation, establishment or defence of legal claims, or where deletion would impair the integrity of the public notice registry. We will explain any refusal and your options for review.
13. Automated Processing and Affidavit Verification
We use automated image analysis to assess whether an uploaded document appears to be a genuine change-of-name affidavit. This assists our review process but does not by itself determine your legal entitlement to a name change.
Automated results (confidence scores and verdict categories) are stored with your draft. You may contact the DPO for human review if you believe an automated decision adversely affected your application.
14. Children's Personal Data
The Platform is intended for adults publishing change-of-name notices. We do not knowingly collect personal data from children under 18 without appropriate parental or guardian consent and legal authority.
If you believe we have collected a child's personal data without proper authority, contact the DPO immediately and we will take steps to delete it.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in law, regulatory guidance, or our processing activities. The "Last updated" date at the top of this page will be revised accordingly.
Material changes will be communicated through the Platform or by email where appropriate. Continued use of the Platform after changes take effect constitutes acknowledgement of the updated policy, unless otherwise required by law.
17. Contact Us
For any questions about this Privacy Policy or our data protection practices:
Data Protection Officer: dpo@publicnotice.ng
General support: support@publicnotice.ng
Postal address: Symverge Technologies Limited, Suite E3, SHM Complex, Before Federal Min. of Works, Mabushi, FCT-Abuja, Nigeria