Introduction
About This Privacy Policy
Welcome to Sportfolio, a fantasy sports prediction and virtual trading platform operated by Sportfolio Technologies ("we," "our," or "us"). This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you access or use the Sportfolio web application, mobile application, or any related services (collectively, the "Platform").
By registering for an account or using the Platform in any way, you confirm that you have read and understood this Privacy Policy and agree to its terms. If you do not agree, please stop using the Platform.
Our Commitment: We are committed to handling your data transparently and responsibly, in compliance with Nigeria's Data Protection Act (NDPA) and global best practices, including requirements set by the Google Play Store.
Section 1
Information We Collect
We collect information directly provided by you, information generated through your use of the Platform, and technical data from your device.
1.1 Account & Registration Information
| Data Type | Purpose |
|---|---|
| Full name | Account identification and personalisation |
| Email address | Login, account notifications, and communication |
| Phone number | Account verification and security alerts |
| Username / profile details | Public profile display within the Platform |
| Password (hashed) | Secure account access — never stored in plain text |
1.2 Platform Activity Data
- Virtual portfolio holdings (player and club shares owned)
- Prediction selections and outcomes
- In-platform trading history (buy/sell actions for virtual shares)
- Virtual wallet balance and token transaction history
- IPO participation records and index trading activity
1.3 Payment & Financial Data (where applicable)
- Deposit and withdrawal transaction records (amounts, dates, reference numbers)
- Bank account details provided for withdrawal processing
- Payment references generated by our payment processor (e.g., Korapay/Paystack). We do not store full card numbers or CVVs.
1.4 KYC & Identity Verification Data (optional / where required)
- Government-issued ID images (NIN, Voter's Card, Driver's License)
- Selfie or facial photograph for identity matching
- NIN or BVN number (where required for regulatory compliance or withdrawal approval)
1.5 Device & Technical Data
- Device model, operating system, and browser type
- IP address and approximate geographic location (country/city level)
- App usage analytics, session data, and feature interaction logs
- Error logs and crash reports for debugging purposes
- Push notification tokens for delivery of account alerts
1.6 Communications Data
- Support messages and inquiries submitted through our help channels
- Email and push notification interaction data (open rates, clicks)
Section 2
How We Use Your Information
We use your data solely to operate, secure, and improve the Sportfolio platform. Specifically:
Platform Operation
- ·Create and manage your account
- ·Process virtual trades and portfolio updates
- ·Record and display prediction outcomes
- ·Manage wallet deposits and withdrawals
- ·Send account and transaction notifications
Safety & Fraud Prevention
- ·Verify user identity via KYC
- ·Detect and prevent fraudulent activity
- ·Enforce our Terms of Service
- ·Investigate abuse or policy violations
- ·Monitor for suspicious login activity
Service Improvement
- ·Analyse aggregated usage for product decisions
- ·Debug errors and fix technical issues
- ·Improve market pricing algorithms
- ·Test new features and UI improvements
Legal & Compliance
- ·Comply with Nigerian law and regulations
- ·Respond to lawful government requests
- ·Maintain financial records as required by law
- ·Resolve user disputes and support claims
We Do Not Sell Your Data. Sportfolio Technologies does not sell, rent, or trade your personal information to third parties for any advertising or marketing purpose. Your data is used exclusively to operate and improve the Sportfolio platform.
Section 3
Virtual Economy & Entertainment Disclaimer
This section is important. Please read it carefully to understand the nature of the Sportfolio platform and how it relates to your personal data.
NOT a Gambling Platform
Sportfolio does not operate real-money gambling services or betting.
NOT a Crypto Exchange
SPF tokens and virtual assets are not cryptocurrencies or blockchain assets.
NOT a Financial Investment
Sportfolio does not provide investment advice or regulated financial services.
Sportfolio is a fantasy sports and virtual trading platform for entertainment purposes only. All player and club shares are virtual assets whose values are influenced by real-life football match performance, in-game market mechanics, and user activity — not by real financial markets.
While users may fund a virtual wallet and request withdrawals of available balances, these transactions relate to the game's virtual economy and are managed through our payment processing partnerships. Profits from the game are not guaranteed, and past performance of virtual assets does not indicate future results.
The data we collect in connection with your virtual trading activity (portfolio holdings, prediction records, wallet transactions) is used solely to operate the game and maintain accurate records of your in-platform activity. It does not constitute financial data regulated under investment law.
Section 4
KYC & Identity Verification
To protect users and maintain platform integrity, Sportfolio may require identity verification (Know Your Customer / KYC) before approving certain account actions, including processing withdrawal requests.
What KYC Data We Collect
- A clear image of a valid government-issued ID (National ID / NIN slip, Voter's Card, or Driver's License)
- A recent selfie or portrait photograph for identity matching purposes
- Your National Identification Number (NIN) or Bank Verification Number (BVN) where required
How KYC Data Is Used & Protected
- KYC data is used exclusively for identity verification, fraud prevention, and regulatory compliance — never for marketing or profiling.
- ID images and selfies are stored in encrypted, access-restricted cloud storage. Only authorised Sportfolio staff members involved in the verification review process may access them.
- KYC data is never shared with third parties except as required by Nigerian law enforcement or regulatory authority requests.
- You will be notified within the platform when KYC is required and for what purpose.
KYC verification is voluntary in most cases but may be required to process withdrawals or access higher platform limits. Choosing not to complete KYC will not affect your ability to use core platform features, only certain financial transactions.
Section 5
Data Security
We implement robust technical and organisational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.
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Encryption in transit: All data between your browser/app and our servers is transmitted over HTTPS with TLS encryption, protecting it from interception.
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Password hashing: User passwords are never stored in plain text. We use industry-standard cryptographic hashing algorithms to store credentials securely.
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Access controls: Internal access to user data is restricted to authorised personnel on a need-to-know basis, with internal access logs maintained.
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Secure payment processing: We use regulated third-party payment processors (e.g., Korapay/Paystack). We do not store full card numbers, PINs, or CVVs on our servers.
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Secure KYC storage: Uploaded ID images and selfies are stored in encrypted, access-restricted cloud storage separate from our general database.
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Regular security reviews: We periodically review our infrastructure, API security, and codebase to identify and remediate vulnerabilities.
No system is 100% impenetrable. While we take all reasonable measures, we cannot guarantee absolute security. If you suspect unauthorized access to your account, contact us immediately at info@sportfolio.ng.
Section 6
Data Sharing & Third Parties
We do not sell your personal information. We share data only in the following limited and necessary circumstances:
| Recipient | Purpose | Data Shared |
|---|---|---|
| Korapay / Paystack | Processing deposits and withdrawals | Name, bank details, transaction amount |
| Cloud Hosting Providers | Secure server infrastructure | Encrypted database and file storage |
| Email / SMS Providers | Delivering transactional notifications | Email address, phone number, notification content |
| Nigerian Authorities | Legal compliance, fraud investigations | Data requested under lawful order only |
All third-party service providers are contractually bound to protect your data and may only use it to provide their services to Sportfolio Technologies. We do not integrate with advertising networks, data brokers, or social tracking platforms.
Business Transfers
In the event of a merger, acquisition, or sale of Sportfolio Technologies, user data may be transferred to the successor entity. We will provide notice via email or in-app notification before your data becomes subject to a materially different privacy policy.
Section 7
Data Retention
We retain your personal information only as long as necessary to fulfil the purposes described in this policy or to comply with applicable law.
| Data Category | Retention Period | Reason |
|---|---|---|
| Account information | Duration of account + 90 days post-deletion | Account management |
| Transaction & financial records | 7 years | Nigerian financial record-keeping law |
| Virtual trading activity | Lifetime of account | Portfolio history and dispute resolution |
| KYC documents (ID, selfie) | Verification period + 12 months | Fraud prevention and regulatory compliance |
| Server logs & IP data | 90 days | Security monitoring and debugging |
| Support communications | 2 years from resolution | Quality assurance and dispute history |
When data is no longer needed, we securely delete or anonymize it so it can no longer be linked to any individual user.
Section 8
Your Rights & Choices
You have meaningful control over your personal data. The following rights are available to all Sportfolio users:
Right to Access
Request a copy of the personal data we hold about you at any time.
Right to Correct
Update inaccurate or incomplete personal information in your account.
Right to Delete
Request deletion of your account and personal data, subject to legal retention obligations.
Right to Portability
Request your data in a structured, machine-readable format.
Opt Out of Notifications
Manage or disable push notifications and marketing emails at any time.
Account Closure
Close your account at any time. Outstanding balances must be withdrawn or forfeited per our Terms.
To exercise any of the above rights, contact us at info@sportfolio.ng. We will respond within 30 days. We may require identity verification before processing certain requests.
Account deletion requests will result in the removal of your active profile from our systems within 90 days. Some information (e.g., financial transaction records) may be retained as required by Nigerian law even after account closure.
Section 9
Children's Privacy
The Sportfolio platform is intended for users who are 13 years of age or older. We do not knowingly collect personal information from children under the age of 13.
If you are a parent or guardian and believe that your child under 13 has created an account or submitted personal data on our platform without your consent, please contact us immediately at info@sportfolio.ng. We will promptly investigate and delete any such information.
Additionally, because the Platform involves funded wallet activities and financial transactions, we strongly recommend that users be at least 18 years of age to engage in deposit and withdrawal features. KYC verification requirements serve as a practical enforcement mechanism for this.
If we discover that we have inadvertently collected data from a child under 13, we will delete that account and all associated data without delay. We encourage parents to actively monitor their children's use of online platforms.
Section 10
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our services, technology, or legal obligations. When changes are made, we will:
- Update the Effective Date at the top of this page
- Notify registered users via email or in-app notification for material changes
- Provide at least 14 days' notice before changes that materially affect your rights take effect
Your continued use of the Sportfolio Platform after changes become effective constitutes your acceptance of the revised Privacy Policy. The most current version will always be accessible at sportfolio.ng/privacy_policy.php.
Section 11
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or how Sportfolio Technologies handles your personal data, please contact us. We are committed to resolving all privacy-related inquiries promptly and transparently.
We aim to respond to all privacy inquiries within 5 business days. For data access, correction, or deletion requests, please allow up to 30 days for processing.