Introduction

Hilanaw (“we”, “our”, “us”) is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the Hilanaw platform at hilanaw.com (“Platform”).

This Policy is prepared in compliance with the Nigeria Data Protection Act 2023 (“NDPA”) and other applicable data protection regulations. By using our Platform, you consent to the practices described in this Policy.

Data Controller: Hilanaw Technology Ltd., registered under the laws of the Federal Republic of Nigeria (“Hilanaw,” “we,” “us,” or “our”).

This Privacy Policy explains how we collect, use, share, and protect personal data when you use the Hilanaw platform — including our website, chat interface, Task Studio, community features, and WhatsApp integration — in line with the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR).

1. Information We Collect

1.1 Account & Identity Data: Name, email address, phone number, business/venture name and details, account role (Entrepreneur, Sponsor, or Investor).

1.2 Business & Venture Data: Information you provide about your business, entered through onboarding, chat conversations, or Task Studio (e.g., financial figures, business plans, co-founder details, grant applications).

1.3 Conversation & Chat Data: Messages you send to Hilanaw’s AI mentorship system, including context used to personalize your curriculum and memory-driven continuity.

1.4 Community Data: Profile information, connection requests, messages, and interactions with other Hilanaw users through community features.

1.5 Payment Data: Handled directly by our payment processors (Paystack or Flutterwave). Hilanaw does not store full card or bank details — we receive confirmation of payment status and relevant transaction metadata only.

1.6 WhatsApp Data: If you opt in, your WhatsApp number and message interaction history (e.g., nudge responses, opt-out status) for delivering reminders.

1.7 Technical Data: IP address, device/browser information, and usage data collected automatically as you use the Platform.

1.8 Investor Report Data: Where an Entrepreneur consents to share their profile or business data with an Investor, the specific data disclosed for that report (see Section 5).

2. How We Use Your Information

We use personal data to:

• Provide AI-powered mentorship, curriculum guidance, and Task Studio document generation;
• Process subscription payments and manage Sponsor-purchased slots and redeemable codes;
• Enable community connections between entrepreneurs;
• Send WhatsApp nudges and reminders (with consent);
• Generate Investor reports strictly with Entrepreneur consent;
• Maintain platform security, prevent fraud, and enforce our Terms of Use;
• Improve the Platform, including through future analytics tooling (see Section 7).

Legal basis: Processing is based on your consent (at signup and for optional features like WhatsApp/Investor reports), the necessity of processing to perform our contract with you (subscription services), and Hilanaw’s legitimate interest in operating and securing the Platform.

3. AI Processing and Cross-Border Data Transfer

3.1. Hilanaw uses a multi-provider AI routing system (via OpenRouter) to power mentorship conversations and Task Studio document generation. Depending on routing decisions, your conversation and business data may be processed by one of several underlying AI model providers, **most commonly Google Gemini**, though other providers may be used for flexibility, redundancy, or performance reasons.

3.2. This means your data may be transferred to and processed on servers located **outside Nigeria**. Where this occurs, we take reasonable steps to work with providers who maintain adequate data protection safeguards, and processing is limited to what’s necessary to generate your requested AI response.

3.3. We do not permit AI providers to use your data to train their models where such controls are available to us, and we do not sell your data to any AI provider or third party.

3.4. If you have concerns about specific data being sent to AI providers (e.g., highly sensitive financial figures), you may choose not to include such details in your conversations or Task Studio inputs.

4. Sponsor Data

4.1. If you purchase Sponsor slots, we collect your payment and contact information to process the transaction and generate redeemable codes.

4.2. Sponsors do not receive access to, or visibility into, the personal data, mentorship conversations, or Task Studio documents of the Entrepreneur who redeems their code. The Sponsor-Entrepreneur relationship is limited to the initial gifting transaction.

5. Investor Data Sharing

5.1. Investors do not have automatic access to any Entrepreneur’s data. Data is shared with an Investor **only when the Entrepreneur explicitly consents** to generate and share a report or profile view for that specific Investor.

5.2. Entrepreneurs can control what business information is included in a shared report and may revoke future access at any time; revocation does not retract reports already shared.

5.3. Hilanaw is not responsible for how an Investor subsequently uses information once lawfully shared with their consent-based access, outside of Hilanaw’s own systems (e.g., if an Investor downloads and stores a report externally).

6. Data Sharing with Third Parties

We share data only with:

• AI model providers (via OpenRouter, e.g., Google Gemini and others) — to generate mentorship and document content;
• Payment processors (Paystack, Flutterwave) — to process subscription and Sponsor payments;
• WhatsApp Business API / Meta — to deliver opted-in nudges and reminders;
• Hosting infrastructure (Contabo VPS) — to store and run the Platform;
• Legal or regulatory bodies — only where required by Nigerian law.

We do not sell personal data to third parties.

7. Cookies and Analytics

7.1. Hilanaw does not currently use analytics or tracking cookies beyond what’s essential for the Platform to function (e.g., login sessions).

7.2. We intend to introduce an analytics tool in the future to understand usage patterns and improve the Platform. When implemented, this Privacy Policy will be updated to name the specific tool and describe what data it collects, and — where required by NDPR — we will request your consent before activating non-essential tracking.

8. Data Retention and Deletion

8.1. We retain your personal data for as long as your account remains active, in order to provide the Platform’s services.

8.2. Upon your request, we delete your personal data immediately.** To request deletion, contact support@hilanaw.com. Note that:

• Some data may briefly persist in backup systems until the next backup cycle overwrites it;
• Transaction records required for tax, accounting, or legal compliance may be retained separately as required by Nigerian law, even after account deletion;
• Data already shared with an Investor with your consent (Section 5) cannot be retracted from that Investor’s own copy.

9. Your Rights Under NDPR

As a Nigerian data subject, you have the right to:

• Access the personal data we hold about you;
• Request correction of inaccurate data;
• Request deletion of your data (see Section 8);
• Withdraw consent for optional processing (e.g., WhatsApp nudges, Investor report sharing) at any time;
• Object to processing based on legitimate interest;
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.

To exercise any of these rights, contact support@hilanaw.com.

10. Data Protection Responsibility

Hilanaw Technology Ltd. currently manages data protection matters directly rather than through a designated Data Protection Officer. As the Platform grows, we will assess and comply with any NDPR requirement to appoint a formal DPO and will update this policy accordingly.

11. Data Security

We implement reasonable technical and organizational measures to protect your data, including access controls on our hosting infrastructure and secure handling of payment data through licensed processors. However, no system is completely secure, and we cannot guarantee absolute security of data transmitted to or from the Platform.

12. Children’s Privacy

Hilanaw is not intended for individuals under 18. We do not knowingly collect data from minors. If we become aware that a minor has provided us personal data, we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time, particularly as we introduce analytics tooling, appoint a Data Protection Officer, or adjust our AI provider arrangements. Material changes will be communicated via the Platform or email.

14. Contact Us

For privacy questions, data requests, or complaints:

Email: support@hilanaw.com