Privacy Policy

Emplug Ltd. ("Hawkerbay," "we," "us," or "our") is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and share data when you use the Hawkerbay platform — including our mobile application and website. By using Hawkerbay, you consent to the practices described in this Policy.

• Account Information: name, email address, phone number, and profile photo provided during registration.

• Location Data: real-time and approximate location to enable proximity-based discovery of vendors and products.

• Transaction Data: purchase history, payment method details (processed by our payment partners), and delivery addresses.

• Communications: messages sent through the in-app chat feature between Buyers and Vendors.

• Device & Usage Data: device type, operating system, IP address, app version, pages visited, and interactions within the Platform.

• User-Generated Content: product listings, photos, descriptions, and reviews you post on the Platform.

• To create and manage your account and provide core Platform features.

• To match Buyers with nearby Vendors using location-based search and discovery.

• To facilitate in-app chat, order processing, payment, and delivery coordination.

• To send transactional notifications, service updates, and (with your consent) promotional communications.

• To improve Platform performance, personalise your experience, and develop new features.

• To detect, investigate, and prevent fraud, abuse, and security incidents.

• To comply with our legal obligations under applicable Nigerian and international law.

We process your personal data on the following legal bases: (a) contractual necessity — to perform our obligations under these Terms; (b) legitimate interests — to operate, secure, and improve the Platform; (c) legal compliance — to meet regulatory requirements; and (d) your consent — for optional features such as marketing communications, which you may withdraw at any time.

• With Vendors or Buyers as necessary to complete a transaction (e.g. delivery address shared with Vendor).

• With trusted third-party service providers: payment processors, cloud hosting, analytics, and customer support tools — each bound by confidentiality obligations.

• With law enforcement or regulatory authorities when required by applicable law or to protect the safety of users.

• In connection with a merger, acquisition, or sale of assets, where your data may be transferred to the acquiring entity.

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

Location data is central to the Hawkerbay experience — it powers vendor discovery and proximity search. We collect precise location only when the app is in use (foreground). You can disable location access via your device settings at any time, though this will limit certain Platform features. Location data is not shared with other users beyond what is needed to show your approximate proximity to a vendor.

We retain your personal data for as long as your account is active or as needed to provide our services. After account deletion, we may retain certain data for up to 12 months to fulfil legal obligations, resolve disputes, and enforce our agreements. Transaction records may be retained for up to 7 years in accordance with Nigerian financial regulations.

• Access: request a copy of the personal data we hold about you.

• Correction: request that we correct inaccurate or incomplete data.

• Deletion: request deletion of your data, subject to legal retention obligations.

• Portability: receive your data in a structured, machine-readable format.

• Objection: object to processing based on legitimate interests.

• Withdrawal of Consent: withdraw consent for optional processing (e.g. marketing) at any time without affecting prior processing.

• To exercise any of these rights, contact us at privacy@hawkerbay.com.

We implement industry-standard technical and organisational measures to protect your data — including TLS encryption for data in transit, AES-256 encryption for sensitive data at rest, role-based access controls, and regular security audits. While we take every reasonable precaution, no system is completely secure. We encourage you to use a strong, unique password and to report any suspected security issues immediately.

Our web platform uses cookies and similar tracking technologies to maintain session state, understand usage patterns, and improve the user experience. You can manage cookie preferences through your browser settings. Disabling cookies may affect certain web features but will not affect the mobile application.

The Platform is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that a minor has provided us with personal information, we will take steps to delete that data promptly. If you believe a minor has registered on our Platform, please contact us at privacy@hawkerbay.com.

The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing any personal information.

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. We will notify you of material changes via in-app notification or email at least 14 days before the changes take effect. The "Effective Date" at the top of this Policy indicates when it was last revised.

Emplug Ltd. is the data controller responsible for your personal information. For privacy-related enquiries, requests, or complaints, contact our Data Protection Officer at privacy@hawkerbay.com or write to: Emplug Ltd., Lagos, Nigeria.