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The Nigeria Data Protection Regulation (NDPR) is the legal baseline for handling personal data in Nigeria. Guild was designed with NDPR principles built into the platform, not bolted on later. This page is the alignment, principle by principle.

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The seven principles

NDPR codifies seven principles for data processing. Each one maps to a specific feature or operational practice at Guild.

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Lawful basis, in detail

Different data types are processed under different lawful bases. The table: The privacy policy spells out each of these in plain Nigerian English. Users can read it before they consent to anything. Consent is granular, explicit, and revocable.

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Granularity

The signup flow asks for consent to specific things:
  • “I agree to Guild storing my phone, name, location, and trade.” (Tier 1 baseline.)
  • “I agree to Guild verifying my BVN with a registered partner.” (Tier 3 specific.)
  • “I agree to receive job alerts on WhatsApp / SMS / voice.” (Channel-specific.)
  • “I agree to Guild sharing my standing snapshot with [specific lender] for credit underwriting.” (Per-lender, per-grant.)
A user can consent to some things and not others. Refusing one consent doesn’t refuse all of them; it just means the corresponding feature isn’t accessible.

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Explicit

Consent is tap-to-agree, not pre-ticked. The privacy text is visible before the user agrees. The consent record is logged in channel_audit with a timestamp.

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Revocable

Every consent has a revoke path. Lender consents are revoked from partners.guild.com.ng. Channel consents are revoked from guild.com.ng/settings. Account-level data consent is revoked by deleting the account. A revoked consent is honoured immediately. The next read against the revoked consent fails with consent_revoked.

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The seven user rights

NDPR grants users seven rights over their data. Each one has a corresponding feature in the Guild dashboard.

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1. The right to be informed

The privacy policy at guild.com.ng/privacy explains what we collect, why, and how. Updated when policies change; users are notified.

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2. The right of access

Every user can fetch their own data. From guild.com.ng/settings, they see what we hold on them. The data is returned as a downloadable JSON archive, signed with our Ed25519 key (so they can prove later what we said we held).

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3. The right to rectification

User-editable data (name, location, trade, languages) can be updated from the dashboard at any time. KYC-verified data (BVN, NIN, address) can be re-verified through a fresh KYC pass.

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4. The right to erasure

A user who taps Delete my account triggers the erasure workflow:
  1. Personal identifiers in identity.users are anonymised.
  2. The encrypted KYC payload is deleted.
  3. Active sessions are revoked.
  4. Lender consents are revoked.
  5. Audit ledger rows persist with the anonymised user ID (required for transaction reconstruction).
  6. The user receives a confirmation.
The erasure completes within 30 days as required by NDPR. Most cases complete within minutes.

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5. The right to restrict processing

A user can pause processing without deleting their account. Channel notifications stop. Active flows freeze. The account stays reactivatable for 90 days.

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6. The right to data portability

The data export from the dashboard is the portability mechanism. JSON format, signed, machine-readable. A user can take it to another platform that supports import (or use it as their personal record).

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7. The right to object

A user can object to processing for marketing or analytics purposes without affecting service delivery. The notification-prefs page is the surface.

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Data residency

Hosting is on virtual private servers. Backups are cross-region replicated within the provider’s network. We do not transfer user data to third parties outside the consent boundary. For lender access, the consent explicitly states which lender will receive what data. No upstream lender-of-lender chains. No data brokerage. For verification partners (BVN, NIN), data crosses to the verification partner momentarily during the verification call. We do not store partner-side data; we only store the verified-yes-or-no result and the timestamp.

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Breach notification

In the event of a data breach with potential harm to users, NDPR requires notification to the regulator (Nigeria Data Protection Bureau) within 72 hours. Our incident response runbook includes the notification path. Affected users are also notified through the channels they’ve opted into (SMS, WhatsApp, email). We have not had a breach. If we do, the runbook fires.

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The Data Protection Officer (DPO)

NDPR requires organisations processing significant volumes of personal data to designate a Data Protection Officer. Guild has one. The DPO’s contact is published in the privacy policy. Users with privacy concerns or rights requests can email directly; we commit to a 30-day response under NDPR.

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Children’s data

Guild does not knowingly serve users under 18. The sign-up requires affirmation of age. If we discover an account belongs to a minor, we anonymise and inform the user.

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Marketing and analytics

We do limited marketing analytics. Aggregated, anonymised metrics inform product decisions (e.g., “users in Lagos use voice more than users in Kano”). No individual-level marketing profiling. Email and SMS marketing is opt-in only. Transactional notifications (payment confirmations, OTPs) are essential service messages and not subject to marketing opt-out.

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Third-party services

We use a small number of third parties for specific purposes. Each one has its own data handling that we vet at integration time. Each third party has its own privacy and security posture, contractually bound through our agreements.

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What we don’t do

For completeness:
  • No selling user data. Ever.
  • No advertising based on user behaviour. We don’t run ads.
  • No cross-platform tracking (Pixel, Analytics, etc.). The frontend is intentionally minimal in third-party scripts.
  • No data brokerage. Lender access is per-user, per-consent, per-purpose. No bulk data sales.

KYC tiers

Per-tier data collection and protection.

Audit ledger

The append-only contract.

Lender consent

The third-party consent model.