PRIVACY
Privacy notice
This notice explains how Qlutterbox collects, uses, shares, and protects personal data in line with NDPR/NDPA and GDPR, while staying aligned with the wider Qubicbox trust commitments published on Qubicweb and Qubictry.
Version 1.0. Effective 27 August 2026.
Who we are
- Qlutterbox is a commerce product operated by Qubicbox Limited, which also operates Qubicweb, Qubictry, the Trust Badge, and E-Fraud Watch. Qubicbox Limited generally acts as controller for direct customer and platform processing, and may act as processor only under a verified agreement with another controller.
- Registered office: 61 Ondo Street, Irawo, Mile 12, Kosofe, Lagos State, Nigeria.
Information we collect
- Identity and verification: names, pronouns, NIN and CAC evidence, guild references, and selfie or video captures used to issue badges or curate protected payment.
- Contact details: email, phone, messaging handles, notification preferences.
- Listings & inspections: inventory metadata, provenance notes, diagnostic logs, proof-of-condition media, dispute artefacts.
- Protected Payment & payout: bank account details, transaction IDs, invoice references, commission statements, settlement preferences.
- Technical telemetry: device fingerprints, IP addresses, session identifiers, MFA events, moderation audit logs, rate-limiting fingerprints.
- Trust graph signals: Trust Badge status, referrals, leaderboard rank, TrustOps annotations that feed Qubicweb overlays and Qubictry referrals.
Purposes & lawful bases
- Contract: onboarding Curators, publishing listings, processing protected payment, inspections, payouts, disputes, and restitution workflows.
- Legal obligation: meeting a specific applicable legal, tax, payment, consumer-protection, or preservation requirement where it applies.
- Legitimate interest: preventing fraud, securing the platform, measuring product usage with privacy-preserving telemetry, and improving moderation accuracy. Assessments are reviewed annually.
- Consent: optional marketing updates, referrals, saved searches, biometric capture where explicit consent is mandated. Withdraw anytime without affecting prior lawful processing.
Retention
- Operational records (listings, protected payment logs, payout statements): transaction close plus 7 years for audit and restitution.
- Curator KYC dossiers: duration of the relationship plus 5 years for regulatory requirements.
- TrustOps dispute files: 5 years post resolution.
- Evidence uploads: 24 months unless legal holds apply, then securely deleted from primary and backup storage.
- Marketing preferences: until withdrawn; requests honoured within 72 hours.
International transfers
- Some approved providers may process data outside Nigeria. We assess applicable transfer requirements and safeguards before relying on a cross-border transfer, and do not represent an unverified country or transfer mechanism as current fact.
Security controls
- Mandatory MFA for Curators, TrustOps, payout actors, and admin tooling.
- Role-based access, attributable audit records, and reviewable exceptions protect sensitive operational actions.
- Evidence access is restricted and material evidence actions are recorded. Additional sanitisation applies where the relevant workflow supports it.
- Rate limiting, abuse prevention, anomaly review, and incident procedures are applied according to the affected workflow and risk.
Your rights
- Access, rectification, deletion, restriction, objection, portability, and withdrawal of consent without affecting prior lawful processing.
- Right to complain to the Nigeria Data Protection Commission (NDPC) or your local EU supervisory authority.
- Right to understand automated decision-making; we do not run solely automated decisions with legal effects without human review.
How to exercise your rights
- Email privacy@qubicbox.com with the subject "Data Subject Request" and include the email/phone tied to your account. We acknowledge within one working day and fulfil within 30 days (extendable by 15 days for complex cases).
- Escalations: NDPC (complaints@ndpc.gov.ng) or your EU supervisory authority.
- Registered office: Qubicbox Limited, 61 Ondo Street, Irawo, Mile 12, Kosofe, Lagos State, Nigeria. Telephone: +234 1 700 2100.
Product-specific notes
- Qlutterbox protected payment and inspections rely on Trust Badge verification data; badge state synchronises with Qubictry referrals and Qubicweb trust overlays.
- Community submissions feeding E-Fraud Watch or OSINT Lab are reviewed and anonymised before publication. Reporters can remain anonymous.
Updates
- We review this notice whenever regulations, processors, or product scope changes. Updated versions appear here with a new revision date.
- Latest revision: 27 August 2026.