Legal

Privacy Policy

FlagRisk Technologies Limited, RC 9690636. 325 Enugu Road, FCDA Quarters, Bwari, Abuja, Nigeria.
Effective from 10 October 2026.

The short version

We hold where you are, where you travel, and who you would call for help. That is unusually sensitive, and we treat that information accordingly.

Your location is shared with the people you choose, and with nobody else. We never sell personal data. Nothing we publish, license, or sell to any organisation identifies you or any other person, at any price, on any plan.

What we build a business on is the pattern, never the person.

1.Who we are

1.1

FlagRisk Technologies Limited, RC 9690636, of 325 Enugu Road, FCDA Quarters, Bwari, Abuja, Nigeria, is the data controller for the personal data described in this policy.

1.2

Data protection enquiries are received at hello@flagrisk.org.

1.3

This policy explains what we collect, why, who we share that data with, how long we keep that data, and what rights you have under the Nigeria Data Protection Act 2023, referred to in this policy as the Act.

1.4

This policy forms part of our Terms of Service.

2.What we collect

CategoryWhat it includesWhere it comes from
AccountName, mobile number, electronic mail address, password, verification statusYou, at registration
LocationPrecise location while the application is in use, and in the background during an alert or a declared journey; location history for the period your plan retainsYour device, with your permission
Followed placesThe places you choose to follow, being the name you give each place, its location, and the distance around that place within which we tell you of a report; and a record of each alert we send you about a followed place, being the place and its name, the incident, the distance between them, the time, and whether the alert was sent in the application or on WhatsAppYou, when you follow a place, and our record of the alerts we send you
Trusted circleNames and mobile numbers of the people you add, and their relationship to you if you record that relationshipYou
Alerts and journeysPanic events, check-ins, missed check-ins, declared origin and destination, timingYour use of the Service
ReportsIncident category, description, location, time, and any photograph or video you attachYou and other users
WhatsAppYour WhatsApp number, the identifier WhatsApp assigns to you for FlagRisk, and your WhatsApp profile name; a record of each message exchanged, being its type, purpose, time, and delivery status, without the text of the message; a current location you send in the chat; your choice to receive or to stop alerts there; and the private words you choose to raise and to end a panic alert, held in a form that cannot be read backYou and WhatsApp, when you write to the FlagRisk account on WhatsApp
PaymentPlan, billing history, and a payment reference. We do not receive or store your card detailsOur payment provider
Device and technicalDevice model, operating system, application version, notification token, network type, crash logs, internet protocol addressYour device, automatically
UsageScreens opened, features used, and timing, in a form linked to your accountYour use of the Service
2.1

Location data is not classified as sensitive personal data under the Act. We treat location data with the same care as if it were, because location can reveal where you live, work, worship, and travel.

2.2

We also hold incident information drawn from published news reports. That information concerns events, is attributed to its source, and is not collected from you.

2.3

On WhatsApp we store a location as your position only when you send your current location. A place you choose on the map is used to answer you and is not stored as your position. A location sent before your number is confirmed is used to answer you and is not stored. The location of a place you follow is stored as that place. It is not stored as your position, even where you sent your current location to mark that place.

2.4

A person who uses FlagRisk on WhatsApp holds one FlagRisk account, identified by their mobile number. The same account serves the application.

3.Why we process personal data, and on what basis

PurposeLawful basis under the Act
Creating and running your accountPerformance of our contract with you
Sending a panic alert with your location to your trusted circlePerformance of our contract with you, and the protection of your vital interests
Running Trip Watch and raising an alert on your silencePerformance of our contract with you, and the protection of your vital interests
Providing the Service through WhatsApp, including answering a request about an area, taking a report, and raising a panic alert or a timed watchPerformance of our contract with you, and the protection of your vital interests
Delivering alerts and notices on WhatsApp to a member of a trusted circleThe consent of that member, which the member may withdraw at any time, and the protection of the vital interests of the person the alert concerns
Asking a person near a reported incident, on WhatsApp, whether that incident is still happeningOur legitimate interest in keeping the Service accurate and safe for others
Reminding a member of a trusted circle, on WhatsApp, to send a current locationOur legitimate interest in keeping the members of a trusted circle within reach of an alert
Showing you the map of safety concerns and your risk scorePerformance of our contract with you
Keeping the places you follow, and telling you when a safety concern is reported near one of themPerformance of our contract with you. Where the alert is sent on WhatsApp, also your consent to alerts there, which you may withdraw at any time
Verifying your mobile numberPerformance of our contract with you, and our legitimate interest in preventing abuse
Moderating reports, checking attached media, and investigating misuseOur legitimate interest in keeping the Service accurate and safe for others
Taking payment for a paid planPerformance of our contract with you
Improving the Service and fixing faultsOur legitimate interest in operating a reliable service
Producing aggregate information on safety concernsOur legitimate interest in operating the Service and in developing safety information products
Sending you marketing messagesYour consent, which you may withdraw at any time
Meeting a legal obligation or responding to a lawful requestCompliance with a legal obligation
3.1

Where we rely on our legitimate interests, we have assessed those interests against your rights and freedoms and have recorded that assessment. You may ask us for a summary of that assessment.

4.Who can see your location

4.1

The people in your trusted circle see your location when you raise a panic alert, and during a declared journey where that feature is active. You choose those people and you can remove them at any time.

4.2

Other users of FlagRisk never see your location, your identity, or your movements. A report you submit appears on the map without your name.

4.3

Our staff may access your data only where access is necessary for a specific task, such as investigating a fault or moderating a report. Access is logged. Our staff are contractually prohibited from looking up any person for personal reasons or on behalf of a third party, and breach is a dismissal matter.

4.4

We do not permit any organisation to locate, track, or identify an individual user through our products.

4.5

An alert delivered on WhatsApp carries one position, with its source and its age. We show no moving trail of a person on WhatsApp.

4.6

If you choose to tell your trusted circle about a report you have made, the members you tell see your name, the kind of report, and where you made it. A person who is asked whether a reported incident is still happening is never told who reported it.

4.7

A person you invite to your trusted circle sees your name. A person who receives a note you send through Tell a friend sees your name, because you send that note from your own WhatsApp.

4.8

You are shown which members of your trusted circle have marked a panic alert as seen.

4.9

The places you follow, and the names you give them, are shown to you alone. No member of your trusted circle and no other user sees them. Following a place does not share your position with anyone.

5.Aggregate information and our business model

5.1

We combine reports and incident data to produce aggregate information on safety concerns, such as the level of reported safety concerns in an area by street, hour, and season. That is the basis of the products we sell to organisations.

5.2

Aggregate information is stripped of names, mobile numbers, account identifiers, and device identifiers, and is generalised so that an individual cannot reasonably be singled out.

5.3

We do not sell personal data. We do not license, publish, or otherwise make available to any customer any data that identifies a user, and no plan or price tier changes that.

5.4

A photograph attached to a report is checked by an automated service for relevance to the report before the photograph is shown to other people. We do not use your data to make an automated decision that produces a legal effect for you or that significantly affects you.

6.Who we share data with

RecipientWhy
Your trusted circleTo alert them and show them your location, as you have chosen
Hosting and database providerTo store and serve the data behind the Service
Messaging providerTo send verification codes and alert messages to mobile numbers
Meta Platforms, as the operator of WhatsAppTo carry messages between FlagRisk and a person who uses FlagRisk on WhatsApp
Push notification servicesTo deliver alerts and notices to devices
Payment providerTo take payment for a paid plan
Mapping and places providerTo display maps and to resolve places and addresses
Automated content checking providerTo check that a photograph attached to a report is relevant to that report
Analytics and error reportingTo measure use and diagnose faults
Professional advisersWhere necessary for legal, accounting, or audit purposes
A buyer or investorOn a sale of the business or of a part of the business, or in a corporate reorganisation, subject to equivalent protection
AuthoritiesWhere we are compelled by law, as described in clause 7
6.1

Subject to clause 6.2, each provider acts as our processor under a written contract, may process your data only on our instructions, and may not use that data for its own purposes.

6.2

WhatsApp is operated by Meta Platforms. Every message between a person and FlagRisk on WhatsApp passes through the WhatsApp Business Platform. Meta receives the content of each such message, the mobile numbers involved, and the time and delivery status of each message. That includes the content of an alert, being the name of the person the alert concerns, its time, and its position. An alert about a place you follow carries the name you gave that place, the kind of incident reported, its time, its distance from that place, and the position at which it was reported. Meta also provides WhatsApp to you under its own terms and its own privacy policy, and we do not control that handling.

6.3

We send a message to a person on WhatsApp only after that person has written to the FlagRisk account on WhatsApp. We send no advertising through WhatsApp.

7.Requests from law enforcement and authorities

7.1

We disclose personal data to a law enforcement agency or other authority only where we are compelled to do so by a valid legal instrument, such as a court order, or where disclosure is necessary to protect the vital interests of a person facing an immediate danger of serious harm.

7.2

We do not give any agency standing or bulk access to our systems, and we do not respond to informal requests.

7.3

We record every request we receive and the response we give.

7.4

We tell you if we have disclosed your data, unless we are legally prohibited from doing so or telling you would put a person in danger.

8.Where your data is held

8.1

Our infrastructure providers hold data on servers located outside Nigeria.

8.2

We transfer personal data outside Nigeria only where the Act permits the transfer, which for us means under a written contract imposing protection equivalent to that required by the Act, or to a country recognised as providing an adequate level of protection.

8.3

You may ask us for the current list of the countries in which your data is held.

9.How long we keep personal data

DataRetention
Account and profileWhile your account is open, and for ninety days after you close your account
Location history visible to youThe period your plan provides, being 7, 30, 90, or 180 days
A position from a current location sent on WhatsAppUsed to decide who is within reach of an alert for seventy-two hours. Kept as location history for the period your plan provides
A place you follow, with the name you give itUntil you stop following that place, and otherwise for as long as we keep your account
The record of alerts sent to you about a place you follow, which holds the name of that placeFor as long as we keep your account, including after you stop following that place
Alert and journey recordsTwelve months, then deleted or de-identified
The record of messages exchanged on WhatsApp, which holds no message textTwelve months, then deleted
An invitation to a trusted circle that is not acceptedFourteen days, after which the invitation expires
The private words that raise and end a panic alert on WhatsAppUntil you replace them or your account is closed
Reports you submitRetained as part of the incident record, de-identified from you after ninety days
Photographs and videoNinety days, unless retained for a moderation or legal matter
Billing recordsSix years, to meet tax and accounting obligations
Aggregate information on safety concernsIndefinitely. Aggregate information on safety concerns contains no personal data
9.1

Where we are required to keep data for a legal or regulatory reason, we keep that data for the required period and no longer.

10.Security

10.1

We protect data in transit and at rest using encryption, restrict access to our systems by role, require multi-factor authentication for administrative access, and log access to user data.

10.2

No system is perfectly secure. If a breach occurs which is likely to result in a risk to your rights and freedoms, we notify the Nigeria Data Protection Commission within seventy-two hours where the Act requires notification, and we tell you without undue delay where the risk to you is high.

10.3

Keep your device locked and your account credentials private. Tell us immediately if you think someone else has access to your account.

11.Your rights

Under the Act you have the right to:

  • be informed about how we use your data, which is the purpose of this policy;
  • ask for a copy of the personal data we hold about you;
  • have inaccurate data corrected;
  • ask us to delete your data, where we have no overriding reason to keep that data;
  • ask us to restrict how we use your data while a concern is resolved;
  • object to processing we carry out on the basis of our legitimate interests;
  • receive your data in a portable form, or have your data sent to another provider;
  • withdraw consent at any time, where we rely on consent; and
  • complain to the Nigeria Data Protection Commission.
11.1

To exercise a right, write to the data protection address in clause 14. We respond within one month, and we tell you if we need longer because the request is complex.

11.2

We do not charge for this, unless a request is manifestly unfounded or excessive.

11.3

You can delete your account in the Service at any time, which starts the deletion described in clause 9. A person who uses FlagRisk only on WhatsApp asks us to delete their account by writing to the data protection address in clause 14.

11.4

You withdraw your consent to alerts on WhatsApp by sending STOP ALERTS to the FlagRisk account on WhatsApp. Sending START ALERTS turns those alerts on again. We record each choice with its time. Choosing to follow a place on WhatsApp turns alerts on there, unless you have stopped them. STOP ALERTS also stops the alerts on WhatsApp about the places you follow.

11.5

You stop following a place at any time from My places in the FlagRisk chat on WhatsApp. That place is then deleted.

12.Children

12.1

The Service is for people aged 18 and over. We do not knowingly collect data from anyone under 18.

12.2

If we learn that we hold data of a person under 18, we delete that data and close the account.

13.Changes to this policy

We may update this policy. We publish the revised version with a new effective date and, where a change materially affects you, we tell you before the change takes effect.

14.Contact and complaints

Data protectionhello@flagrisk.org
General enquirieshello@flagrisk.org
Postal addressFlagRisk Technologies Limited, 325 Enugu Road, FCDA Quarters, Bwari, Abuja, Nigeria
RegulatorNigeria Data Protection Commission

If you are not satisfied with our response, you may complain to the Nigeria Data Protection Commission. We would rather hear from you first, and we will try to put the matter right.

This policy is read together with the Terms of Service.