Privacy Policy

This privacy policy describes the personal information that we, Codematic Labs Ltd d/b/a as Conviso (“Conviso,” “we,” “our” or “us”), collect:

From individuals when they visit our website (the “Site”), interact with our marketing communications, register for events, or interact with our social media profiles.
On behalf of our customers who utilize the Conviso event-driven technology to power their digital marketing and automation (the “Services”).

Security First

Your data is encrypted and protected with enterprise-grade security measures.

Transparency

We're clear about what data we collect and how we use it.

Your Control

You maintain full control over your data and privacy settings.

1. Introduction

In accordance with the General Data Protection Regulation (GDPR) and Nigeria Data Protection Act (NDPA) 2023, this policy clarifies where we act as a Data Controller (for our own business purposes) and where we act as a Data Processor or Service Provider (on behalf of our customers).

Individuals interacting with a brand that uses Conviso should refer to that brand's privacy policy to understand how their data is managed. For our customers, our obligations are further defined in our Data Processing Addendum (DPA).

2. Personal Information We Collect & Purpose of Processing

Categories of Personal Information	Examples	Purpose for Processing	Categories of Third Parties Shared With
Identifiers	Name, email address, unique platform ID, device ID, advertising ID, and IP address.	To provide and monitor the Services; to segment recipients for automated marketing; for internal R&D; and to manage support inquiries.	Customers, Service Providers (GCP/AWS), Messaging Partners (Infobip/Twilio).
Customer Records	Name, address, telephone number, products/services purchased, and transaction dates.	To facilitate targeted messaging campaigns; for billing and administrative purposes; and to support customer inquiries.	Payment Processors, Messaging Applications, CRM systems.
Geolocation	Coarse IP-based location (not precise GPS).	To perform analytical analysis of Site performance and provide locale-specific marketing content for Services.	Customers, Analytics Providers (Google Analytics).
Internet & Network Activity	Browsing history, search history, and interaction with emails or advertisements.	To track recipient interaction with automated messages; to perform data analytics for product development; and to ensure platform security.	Customers, Service Providers, Marketing Applications.
Audio & Electronic Information	Support call recordings or video meeting logs.	For customer support training, sales quality assurance, and administrative purposes.	Internal Staff, Support Ticketing Systems.
Inferences & Behavioral Data	Profiles drawn from user behavior, interests, and engagement patterns.	To help customers create segments and predict churn; for sales training and business optimization.	Customers, Third-Party Business Integrations.
Sensitive Personal Information	While we discourage the processing of sensitive data (e.g., religious beliefs, health data), customers may upload this to the Services.	We do not collect this for our own purposes. If processed, it is solely as a Processor under the direction of our Customers.	Third-Party Messaging Applications (where applicable).

3. How We Collect Personal Information

We collect information through the following channels:

Direct Interaction: When you complete forms, request demos, or respond to our communications.
From Our Customers: Information provided to us by companies using Conviso to track their end-users.
Service Providers & Partners: Data from third-party business partners, including messaging platforms (Twilio/Infobip), analytics providers (Google Analytics), or social media (LinkedIn).
Automated Tracking: We use cookies, web beacons, and unique identifiers to collect data on IP addresses and device types when you visit our Site or interact with a message sent via our Services.

4. How We Use Personal Information

Conviso utilizes personal information to:

Provide and personalize the Site and Services.
Process transactions and communicate administrative updates.
Conduct research and development to improve our AI-driven engagement engines.
Identify trends and monitor the security/integrity of our infrastructure.
Detect and prevent fraudulent activities or unauthorized access.
Comply with regulatory and legal obligations under Nigerian law.

5. How We Share Personal Information

We share information with:

Customers: We provide data about end-users back to the specific customer who initiated the tracking.
Service Providers: Infrastructure partners (Google Cloud Platform) and professional service providers (legal/accounting). Click here to see a list of our subprocessors.
Messaging Applications: Third-party gateways such as Twilio, Infobip, or Apple (for Push) to deliver communications.
Legal Authorities: When required by a valid subpoena, court order, or the Nigeria Data Protection Commission (NDPC).

6. Data Subject Rights (Nigeria & International)

Under the General Data Protection Regulation (GDPR) and Nigeria Data Protection Act (NDPA), you have the following rights:

Right to Access: To request a copy of the personal data we hold about you.
Right to Rectification: To correct inaccurate or incomplete information.
Right to Erasure ("Right to be Forgotten"): To request the deletion of your data under certain conditions.
Right to Object: To stop the processing of your data for direct marketing.
Right to Portability: To receive your data in a structured, machine-readable format.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.
Right to Restrict Processing: Request limitation on how we use your data.

To exercise these rights, please contact [email protected]. If your request relates to data we process on behalf of a customer, we will direct you to contact that brand directly.

7. How We Protect Personal Information

Conviso utilizes a "Defense-in-Depth" strategy. Built on Google Cloud Platform (GCP), we employ:

Encryption: Data is encrypted at rest (AES-256) and in transit (TLS 1.2+).
Access Controls: Multi-factor authentication (MFA) and least-privilege access for all employees.
Monitoring: Continuous security logging and vulnerability scanning.
Physical Security: Hosting in Tier III/IV data centers with 24/7 surveillance.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law:

Account Data: Retained while your account is active and for 30 days after deletion
Customer Data: Deleted within 30 days of account termination or upon request
Billing Records: Retained for 7 years for tax and accounting purposes
Security Logs: Retained for 12 months for security and fraud prevention
Analytics Data: Anonymized and retained indefinitely for research purposes

9. Third-Party Services and Integrations

Our Service may contain links to third-party websites, applications, and services not operated by us. We are not responsible for the privacy practices of third parties. We recommend reviewing the privacy policies of any third-party services you interact with.

When you integrate third-party services with Conviso, you authorize us to access and process data from those services on your behalf. These integrations are subject to the terms and privacy policies of the respective third-party providers.

10. Children's Privacy

Our Service is not intended for use by children under the age of 16 ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and become aware that your Child has provided us with personal data, please contact us. If we discover that we have collected personal data from Children without verification of parental consent, we will take steps to remove that information from our servers.

11. Changes to this Policy

We may update this privacy policy to reflect changes in our practices or the Nigerian regulatory landscape. We will notify you of significant changes by posting the new policy on our Site. Continued use of our Services constitutes acceptance of these updates.

12. Contact Us

For questions regarding our privacy practices or to lodge a concern with our Data Protection Officer, please contact:

Codematic Labs Ltd d/b/a as Conviso

25B Sunmola Street, Mende, Maryland, Lagos, Nigeria.

Email: [email protected]

Support: [email protected]

Website: www.conviso.ai

Response Time: We aim to respond within 48 hours