Felp Privacy Notice

1. Introduction

This Privacy Notice explains how Refiner Tech Solutions Ltd, operating the Felp platform (“Felp”, “we”, “us” or “our”), collects, uses, stores, shares and protects personal data when individuals use Felp.

Refiner Tech Solutions Ltd is a private company limited by shares registered in the Federal Republic of Nigeria with registration number RC 9268218.

Felp provides event discovery, registration, ticketing, payment integration, communications, event management, check-in and related services.

We are committed to processing personal data fairly, lawfully, transparently and securely in accordance with applicable data-protection law, including the Nigeria Data Protection Act 2023 and applicable regulatory requirements and guidance.

2. Scope

This Privacy Notice applies to personal data processed through Felp in connection with:

• visitors to Felp websites and applications;
• event attendees;
• guest attendees;
• registered attendees;
• Organizers;
• Organizer team members;
• individuals communicating with Felp support;
• individuals receiving legitimate Felp event communications;
• people whose information is otherwise processed through the Services.

Separate privacy terms may apply where another service is independently responsible for processing personal data.

3. Who Is Responsible for Your Data?

For personal data for which Felp determines the purposes and means of processing, the data controller is:

In some circumstances, an event Organizer independently determines why and how attendee information is processed. In such circumstances, the Organizer may act as a separate data controller and is responsible for its own compliance with applicable data-protection law.

Depending on the particular processing activity, Felp may also process certain information on behalf of an Organizer.

4. Personal Data We Collect

The information we collect depends on how you use Felp.

4.1 Account Information

Where you create an account, we may collect:

• name;
• email address;
• phone number;
• authentication information;
• account preferences;
• account role;
• verification status.

Passwords are not intended to be stored in readable form.

4.2 Guest Registration Information

You do not necessarily need a Felp account to register for an event.

For guest registrations, we may collect:

• name;
• email address;
• phone number;
• event registration information;
• ticket selection;
• answers to registration questions;
• communication preferences where applicable.

4.3 Organizer Information

For Organizers and Organizer team members, we may collect:

• name;
• business or organisation name;
• email address;
• phone number;
• role;
• organizer profile information;
• verification information;
• event information;
• payment-account or settlement information;
• team membership and permissions;
• communications with Felp.

4.4 Event and Registration Information

We may process:

• events viewed;
• events saved;
• registrations;
• ticket types;
• ticket references;
• QR ticket information;
• registration timestamps;
• waitlist information;
• check-in status;
• check-in time;
• attendance information;
• event preferences;
• registration responses.

4.5 Payment Information

For paid events, we may process:

• transaction amount;
• currency;
• payment status;
• transaction reference;
• payment-provider reference;
• ticket or registration associated with a payment;
• refund or dispute status;
• limited payment metadata supplied by our payment provider.

Payment-card details may be collected directly by the payment provider rather than Felp. Felp does not need to receive or store complete card credentials where the provider handles them directly.

4.6 Communications Information

Where Felp provides event communications, we may process:

• email address;
• phone number;
• communication channel;
• message type;
• delivery status;
• send time;
• failure status;
• interaction status where made available by the communication provider;
• communication preferences and consent information where applicable.

We may deliver communications through channels including email, WhatsApp and web push.

4.7 Check-In and Attendance Information

We may process:

• ticket identifier;
• QR verification information;
• check-in status;
• check-in time;
• event attended;
• manual check-in information;
• virtual attendance information where a supported integration is enabled.

4.8 Device and Technical Information

When you use Felp, we may automatically collect certain technical information, including:

• IP address;
• browser type;
• device type;
• operating system;
• pages or screens visited;
• timestamps;
• referral information;
• application or website performance information;
• security and diagnostic logs;
• cookie or similar technology identifiers where applicable.

4.9 Support and Dispute Information

If you contact us or submit a complaint, we may process:

• contact details;
• correspondence;
• event and transaction information;
• support history;
• evidence you voluntarily provide;
• information required to investigate or resolve the matter.

5. Information Organizers Request

An Organizer may configure additional registration questions for an event.

Felp may restrict questions that appear excessive, unlawful or inappropriate.

Organizers are responsible for ensuring that information they request through Felp is necessary and lawfully collected.

Attendees should review event-specific information before providing optional information requested by an Organizer.

6. How We Obtain Personal Data

We may obtain personal data:

• directly from you;
• from an Organizer;
• when you register for an event;
• when you purchase a ticket;
• when you use a Felp ticket;
• when you check in;
• automatically through your use of Felp;
• from payment providers;
• from communication providers;
• from virtual-event or calendar integrations;
• from other services you choose to connect to Felp;
• where otherwise permitted by law.

7. Why We Process Personal Data

We may process personal data to:

Provide Felp

This includes:

• creating and maintaining accounts;
• displaying and operating events;
• processing registrations;
• issuing tickets;
• maintaining ticket records;
• facilitating payments;
• supporting Organizer tools;
• providing attendee access;
• processing check-ins.

Communicate About Events

We may send:

• registration confirmations;
• payment confirmations;
• tickets;
• reminders;
• venue or schedule updates;
• cancellation notices;
• security messages;
• essential event instructions.

Provide Support

We use information to investigate and respond to questions, complaints, disputes and support requests.

Maintain Safety and Security

We may process information to:

• authenticate users;
• detect fraud;
• prevent abuse;
• investigate suspicious transactions;
• protect accounts;
• enforce our Terms;
• secure Felp infrastructure.

Improve Felp

We may analyse how the Services are used to improve:

• performance;
• reliability;
• usability;
• event discovery;
• organizer tools;
• features;
• security.

Comply With Legal Obligations

We may process and retain information where necessary to comply with:

• applicable laws;
• lawful regulatory requirements;
• court orders;
• tax and accounting obligations;
• fraud-prevention obligations;
• legal claims.

8. Lawful Bases for Processing

Depending on the activity and applicable law, Felp may rely on one or more lawful bases.

Contract

Processing may be necessary to provide a service you requested, such as registering you for an event, issuing a ticket or maintaining your Felp account.

Consent

We may rely on your consent where required, including for certain marketing, optional technologies or other processing activities.

Where processing is based on consent, you may withdraw consent subject to applicable law. Withdrawal does not invalidate processing that was lawful before withdrawal.

Legitimate Interests

We may process information where reasonably necessary for legitimate interests such as:

• securing Felp;
• preventing fraud;
• improving our Services;
• maintaining platform integrity;
• understanding service performance;
• protecting users.

We consider the rights and interests of affected individuals when relying on legitimate interests.

Legal Obligation

We may process personal data where necessary to comply with applicable legal or regulatory requirements.

Other Lawful Bases

Where applicable law permits another lawful basis, such as protection of vital interests or performance of a task in the public interest, we may rely on that basis where appropriate.

9. Operational Communications and Marketing

Operational event communications are different from promotional marketing.

Where you register for an event, we may send communications reasonably necessary to administer that registration, including tickets, reminders, schedule changes, venue information and cancellation notices.

Marketing communications will be handled separately and in accordance with applicable consent and opt-out requirements.

You may opt out of eligible marketing communications without losing access to essential transactional or operational messages required for events for which you remain registered.

10. WhatsApp Communications

Where you provide a phone number and WhatsApp is an available event communication channel, Felp may use supported WhatsApp services to deliver eligible event-related communications.

These may include:

• tickets;
• registration confirmations;
• reminders;
• event updates;
• cancellations;
• other permitted event communications.

WhatsApp is operated by a third party and its own terms and privacy practices also apply to its services.

11. Email Communications

Felp may use third-party email infrastructure to deliver transactional and permitted communications.

Email providers may process information necessary to deliver messages, detect failures, prevent abuse and provide delivery information.

12. Payments

Payments may be processed through third-party payment providers.

Those providers may independently process information necessary to:

• authorise payments;
• prevent fraud;
• perform regulatory checks;
• settle funds;
• handle refunds;
• handle disputes.

Their own privacy policies and terms may apply.

Felp receives the payment information reasonably necessary to operate registrations, tickets, settlements and support.

13. Virtual Events and Third-Party Integrations

Where an Organizer connects or uses a supported third-party service, such as a video-conferencing, calendar, storage or streaming service, Felp may exchange information with that provider as required to provide the integration.

Depending on the integration, this may include:

• event title;
• date and time;
• attendee name;
• attendee email;
• meeting information;
• attendance information;
• recording or resource metadata.

Felp will seek to limit integration data to what is reasonably necessary for the relevant feature.

Third-party providers may process information under their own terms and privacy notices.

14. When We Share Personal Data

We do not sell personal data as a business model.

We may disclose personal data to:

Event Organizers

When you register for an event, the Organizer may receive information necessary to administer that event.

This may include your name, contact information, ticket information, registration responses, payment status and attendance status where appropriate.

Service Providers

We may use providers for:

• cloud hosting and infrastructure;
• database and storage services;
• payments;
• email;
• WhatsApp and communications;
• monitoring and observability;
• security;
• analytics;
• maps;
• virtual meetings;
• other technical services.

Providers receive information only as necessary for the relevant service and subject to appropriate contractual or legal arrangements where required.

Professional Advisers

Information may be disclosed where reasonably necessary to auditors, lawyers, accountants, insurers and other professional advisers subject to appropriate confidentiality obligations.

Authorities and Legal Process

We may disclose information where required or permitted by law, including in response to lawful requests from courts, regulators or law-enforcement authorities.

Corporate Transactions

If Refiner Tech Solutions Ltd undergoes a merger, acquisition, restructuring, financing or sale of relevant assets, personal data may be transferred as part of that transaction subject to applicable law and appropriate safeguards.

15. International Data Transfers

Some Felp service providers or infrastructure may process personal data outside Nigeria.

Where personal data is transferred internationally, we will take measures required by applicable data-protection law to ensure that the transfer has an appropriate legal basis and safeguards.

Depending on the circumstances, these may include recognised adequacy mechanisms, contractual safeguards, consent where legally appropriate, or another transfer mechanism permitted by law.

16. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for legitimate legal, regulatory, security, accounting and dispute-resolution requirements.

Retention periods may vary according to the type of information.

For example:

• active account information may be retained while an account remains active;
• registration and ticket records may be retained for event administration, historical ticket access, fraud prevention and dispute handling;
• transaction records may be retained as required for financial, tax, accounting and legal obligations;
• security logs may be retained for an appropriate security period;
• consent and communication records may be retained to demonstrate compliance;
• information subject to a legal dispute or regulatory requirement may be retained until the matter is resolved.

When information is no longer required, we will delete, anonymise or otherwise dispose of it in accordance with applicable requirements and our retention procedures.

17. Data Security

We use reasonable technical and organisational safeguards designed to protect personal data against:

• unauthorised access;
• unlawful processing;
• accidental loss;
• alteration;
• disclosure;
• destruction.

Measures may include access controls, encryption where appropriate, network controls, secure authentication, logging, monitoring, backups and restrictions on staff or service-provider access.

No system connected to the internet can guarantee absolute security.

18. Your Privacy Rights

Subject to applicable law and relevant exceptions, you may have rights including:

• the right to be informed about processing;
• the right to access your personal data;
• the right to correct inaccurate or incomplete information;
• the right to request deletion in applicable circumstances;
• the right to restrict processing in applicable circumstances;
• the right to object to certain processing;
• the right to data portability where applicable;
• the right to withdraw consent where processing relies on consent;
• rights relating to certain automated decision-making;
• the right to lodge a complaint with the Nigeria Data Protection Commission.

Some rights are not absolute and may be subject to lawful exemptions.

19. Exercising Your Rights

To exercise a privacy right, contact: Privacy: [email protected]

We may need to verify your identity before fulfilling a request in order to protect personal data from unauthorised disclosure.

We will respond in accordance with applicable legal requirements.

You may also lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your personal data has been processed unlawfully.

20. Account Deletion

Where supported, users may request deletion of their Felp account.

Deleting an account does not necessarily require immediate deletion of every record associated with that account.

We may retain information where reasonably necessary to:

• comply with legal obligations;
• maintain financial or transaction records;
• establish or defend legal claims;
• prevent fraud;
• resolve disputes;
• maintain ticket or event integrity;
• honour lawful retention requirements.

Information that no longer needs to identify an individual may instead be anonymised.

21. Cookies and Similar Technologies

Felp may use cookies, local storage and similar technologies to:

• maintain sessions;
• authenticate users;
• remember preferences;
• protect the Services;
• measure performance;
• understand how Felp is used;
• provide permitted analytics or advertising functionality.

Where consent is legally required for a category of cookies or similar technology, Felp will seek the appropriate consent before using it.

Essential technologies required to provide or secure the Services may operate without optional consent where permitted by law.

22. Analytics and Advertising Technologies

Felp may use analytics technologies to understand traffic, registrations, conversion, performance and product usage.

Where Felp or an Organizer uses advertising or conversion technologies such as advertising pixels, their use must comply with applicable privacy requirements.

Where required, users will be given appropriate information and choices concerning non-essential tracking technologies.

23. Children’s Privacy

Felp is not intended to enable unlawful collection of children’s personal data.

Where an event is intended for children or requires information relating to children, the Organizer must comply with applicable consent, safeguarding and data-protection requirements.

Felp may impose additional restrictions or verification requirements for such events.

24. Automated Decision-Making

Felp may use automated systems to assist with security, fraud detection, event ranking, abuse prevention and platform operations.

Where applicable law provides rights in relation to decisions based solely on automated processing that produce legal or similarly significant effects, we will honour those rights and provide appropriate safeguards.

25. Links to Other Websites and Services

Felp events may contain links to external websites, virtual-event services, payment services, social networks or other third-party platforms.

Felp is not responsible for the privacy practices of independent third parties.

You should review their privacy notices before providing personal information directly to them.

26. Organizer Responsibilities

Organizers that receive attendee personal data through Felp must:

• process it lawfully and fairly;
• use it only for appropriate purposes;
• protect it against unauthorised access;
• avoid unnecessary collection;
• honour applicable privacy rights;
• not sell or unlawfully disclose attendee information;
• comply with applicable data-protection laws.

An Organizer may be independently responsible as a data controller for processing it determines.

27. Data Breaches

Where a personal-data breach occurs, Felp will investigate and take reasonable measures to contain and remediate it.

Where applicable law requires notification to affected individuals or the Nigeria Data Protection Commission, we will provide the required notification in accordance with applicable requirements.

28. Changes to This Privacy Notice

We may update this Privacy Notice to reflect changes in:

• our Services;
• technology;
• integrations;
• processing activities;
• legal requirements;
• regulatory guidance.

The latest version will be published on Felp and will display its effective or last-updated date.

Where a change materially affects how personal data is processed, we will provide additional notice where required or appropriate.

29. Contact Us

For questions about this Privacy Notice or Felp’s processing of personal data:

Product

Felp

Website

felp.ng

Privacy enquiries

[email protected]

General support

[email protected]

Security reports

[email protected]

You may also contact the Nigeria Data Protection Commission regarding your rights under Nigerian data-protection law.