Privacy Policy

Luuk Market Nigeria Limited ("Luuk", "we", "us", "our") operates the Luuk mobile application and the luuk.ng website (together, the "Services"). This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and the rights you have over it, in line with the Nigeria Data Protection Act (NDPA) 2023 and the regulations of the Nigeria Data Protection Commission (NDPC).

By using Luuk, you agree to the collection and use of information as described in this policy. If you do not agree, please do not use the Services.

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1. Information We Collect

1.1 Information you provide directly

• Account data: full name, phone number, email address, password, profile photo, and date of birth.
• Verification data: government-issued ID, BVN or NIN where required for seller verification or escrow payouts, and selfie-match data used to confirm identity.
• Transaction data: items bought or sold, prices, negotiation messages, delivery addresses, and order history.
• Payment data: card details and bank account information are collected and processed by our CBN-regulated payment partners, not stored directly on Luuk's servers.
• Content you upload: product videos, photos, reviews, messages, and any other content you post.
• Communications: messages you send to our support team, including contact form submissions.

1.2 Information collected automatically

• Device data: device model, operating system, unique device identifiers, and mobile network information.
• Usage data: pages viewed, videos watched, search queries, time spent in-app, and interaction patterns used to personalise your feed.
• Location data: approximate location (from IP address) and, with your permission, precise location to show nearby sellers and estimate delivery times.
• Cookies and similar technologies: used on luuk.ng to remember preferences and measure site performance.

2. How We Use Your Information

• To create and manage your Luuk account and authenticate your identity.
• To process orders, hold and release Luuk Lock escrow funds, and facilitate delivery.
• To verify sellers and reduce fraud, in partnership with our licensed financial and KYC partners.
• To personalise the video feed and product recommendations you see.
• To communicate with you about orders, security alerts, and platform updates.
• To investigate and resolve disputes between buyers and sellers.
• To comply with legal obligations, including anti-money-laundering (AML) and know-your-customer (KYC) requirements under CBN guidelines.
• To improve the Services through aggregated, anonymised analytics.

3. Legal Basis for Processing

We process your personal data under the following lawful bases recognised by the NDPA: your consent (e.g. for marketing communications and precise location), performance of a contract (e.g. processing your orders), compliance with a legal obligation (e.g. KYC/AML checks), and our legitimate interests (e.g. fraud prevention and service improvement), balanced against your rights.

4. Who We Share Data With

• CBN-regulated payment processors and licensed financial institutions who hold Luuk Lock escrow funds and process payouts.
• Logistics partners who need delivery addresses and contact details to fulfil orders.
• Identity verification providers who confirm BVN/NIN and ID document authenticity.
• Other users — your public profile, store name, ratings, and reviews are visible to other users by design of a marketplace.
• Regulators and law enforcement, where required by Nigerian law or a valid court order.

We do not sell your personal data to third parties for their own marketing purposes.

5. Data Retention

We retain your data for as long as your account is active, and for a reasonable period afterward to comply with legal, tax, and dispute-resolution obligations — typically up to 6 years for transaction and KYC records, in line with CBN and tax record-keeping requirements. You may request earlier deletion of non-essential data at any time (see Section 7).

6. Data Security

We use industry-standard encryption in transit and at rest, restricted internal access controls, and regular security reviews to protect your data. No system is completely immune to risk, but we treat the security of your financial and identity data as a top priority — it is the same trust layer the entire Luuk Lock escrow system depends on.

7. Your Rights

Under the NDPA, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your data, subject to legal retention requirements.
• Withdraw consent for optional processing (e.g. marketing messages) at any time.
• Object to certain types of processing, including automated decision-making that significantly affects you.
• Request a portable copy of your data in a structured, commonly-used format.

To exercise any of these rights, contact us using the details below. We will respond within the timeframe required by the NDPC.

8. Children's Privacy

Luuk is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from minors. If we learn that a minor has created an account, we will take steps to delete it.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the app or via email before they take effect. Continued use of Luuk after changes take effect constitutes acceptance of the updated policy.

A note on escrow funds

Luuk Lock financial services are provided in partnership with CBN-regulated payment processors and licensed financial institutions. Funds held in escrow are not deposits and are not insured by the NDIC.