Privacy Policy

Last updated: 31 July 2026

Gemynate is building financial protection for Nigeria's informal economy. We are not live yet. Right now, this website does one thing: it lets you join our waitlist. This policy explains, in plain language, what we collect when you do that, why, and the rights you have over your data under the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR).

Who we are

Gemynate is a pre-launch Nigerian company. For anything to do with your data, we are the data controller and you can reach us at hello@gemynate.com.

What we collect

When you join the waitlist, we ask for:

• Your name, so we know what to call you.
• Your WhatsApp phone number, so we can reach you on WhatsApp when Gemynate launches, since that is where the product will live.
• Your email address (optional), so we can send you updates by email as well if you prefer.
• Your consent, recorded when you tick the consent box.

When you browse the site, we also collect a small amount of usage data through Google Analytics: pages viewed, buttons clicked, general device and browser information, and any campaign tags (UTM parameters) in the link that brought you here. These are aggregate usage measurements that help us understand how the site is used.

That is the full list. We do not collect financial information, identity documents, or anything sensitive, because there is nothing on this site that needs them.

Why we collect it, and our lawful basis

Under the NDPA, we need a lawful basis to process your personal data. Ours is your consent: you choose to join the waitlist, and you tick a box confirming you are happy for us to contact you. We use your data to:

• Keep you on the waitlist and send you occasional pre-launch updates.
• Contact you on WhatsApp, and by email if you shared your address, when Gemynate launches.
• Understand how people use this website so we can improve it.

We do not sell your data. We do not share it with advertisers. We do not use it for anything beyond what is listed here.

Who handles your data for us

We use a small number of service providers to run this site:

• Netlify hosts the website and processes the waitlist form. The details you submit are stored on Netlify's infrastructure.
• Google Analytics (provided by Google) measures how the site is used.

These providers process data on our behalf and under their own security and privacy commitments. Beyond them, we only disclose personal data if the law requires it.

International transfers

Netlify and Google store data on servers outside Nigeria, including in the European Union and the United States. This means your waitlist details and analytics data are transferred abroad. We only work with providers that apply recognised security and data protection safeguards, consistent with the cross-border transfer requirements of the NDPA.

How long we keep it

We keep your waitlist details until one of two things happens:

• Gemynate launches and you are invited to onboard, at which point the product will have its own privacy terms, or
• You ask us to delete your data, in which case we remove it.

If we ever wind down the waitlist without launching, we will delete the data rather than keep it around.

Your rights

Under the NDPA, you have the right to:

• Access the personal data we hold about you.
• Correct anything that is inaccurate or out of date.
• Delete your data and leave the waitlist.
• Withdraw your consent at any time, which has the same effect as deletion for our purposes here.

To use any of these rights, email hello@gemynate.com and we will act on your request promptly, and in any case within the timelines the NDPA sets. If you are not satisfied with how we handle it, you can complain to the Nigeria Data Protection Commission (NDPC).

Cookies and analytics

We do not run advertising cookies. Google Analytics sets a small number of cookies to measure site usage such as page views and visit counts; we do not use them for advertising. If you block these cookies, the site still works exactly the same.

Children

This site and the waitlist are intended for people aged 18 and over. If you believe a minor has submitted their details, contact us and we will delete them.

Changes to this policy

If we change how we handle data, we will update this page and the date at the top. If a change is significant, for example when the product launches, we will tell waitlist members directly.

Contact

Questions, requests, or concerns about your data: hello@gemynate.com.