Privacy Policy

1. Introduction

This Privacy Policy explains how Sei Media Technologies ("SEI MEDIA", "we", "us", "our") collects, uses, discloses, retains and protects Personal Data in connection with the THE BRAIN GIG mobile application, thebraingig.com and related services (the "Service"). It also describes your rights under the Nigeria Data Protection Act 2023 ("NDPA") and how to exercise them.

Note: This Privacy Policy should be read in conjunction with our Terms of Use, which govern your use of the Service.

2. Personal Data We Collect

We collect Personal Data you provide directly, including:

• Identity: name, date of birth, gender.
• Contact: email address, phone number, postal address.
• Account & login: username, password, profile picture.
• Financial: bank account number, bank name, account type (where you voluntarily provide this for payouts).
• Usage & device: device identifiers, IP address, device model, operating system, app usage logs.
• Communications: messages you send to our support team.

We may collect certain information automatically through cookies and similar technologies (see our Cookie Notice).

3. Lawful Basis for Processing

We process Personal Data on lawful grounds permitted under the NDPA, including:

• Consent: where you have given consent (e.g., marketing communications).
• Contract: to perform our contract with you (e.g., to process payouts).
• Legal obligation: to comply with law, court orders or regulatory requests.
• Legitimate interests: where necessary for fraud prevention, platform security and service improvements, balanced against your rights.

4. Purpose of Processing

We use Personal Data to:

• Provide, operate and improve the Service.
• Process Rewards and payouts.
• Verify identities and prevent fraud and abuse.
• Communicate with you about your account and support requests.
• Comply with legal and regulatory obligations.
• Personalise user experience and show relevant ads (where applicable).

5. Sharing and Disclosure

We do not sell Personal Data. We share Personal Data only in limited circumstances:

• Service providers: cloud hosts, payment processors, analytics, customer support — only to perform services on our behalf and under contract.
• Ad partners: third-party ad networks for ad delivery and monetisation. Ad networks may collect information for advertising purposes under their own policies.
• Legal & safety: where required by law or to protect rights, property or safety.
• Business transfers: in connection with mergers, acquisitions or asset sales.

6. Cross-border Transfers

Personal Data may be transferred to countries outside Nigeria. We will take steps to ensure transfers comply with the NDPA (adequacy decisions, contractual protections or other lawful safeguards).

7. Data Retention

We retain Personal Data only as long as necessary for the purposes described, or to comply with legal obligations, resolve disputes, and enforce agreements.

8. Data Security

We use reasonable technical and organisational measures (encryption, access controls, audits) to protect Personal Data. However, no security measure is perfect; we cannot guarantee absolute security.

9. Data Subject Rights

Under the NDPA you may, subject to verification and applicable limits, exercise the following rights:

• Access: obtain a copy of Personal Data we hold about you.
• Correct: request correction of inaccurate or incomplete data.
• Erase: request deletion of Personal Data where lawful.
• Restrict: request restriction of processing.
• Object: object to processing in certain circumstances.
• Portability: request transfer of Personal Data in a structured format.
• Complain: lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise your rights contact: dpo@seimediatechnologies.com

10. Children & Minors

We treat persons under 18 as children under the NDPA. We do not knowingly collect Personal Data from children without verifiable parental consent and appropriate safeguards.

11. Cookies & Advertising

We and our partners use cookies and similar technologies for functionality, analytics and advertising. You can manage cookie preferences via the app settings and cookie banner.

12. Third-party Links

The Service may contain links to third-party websites. We are not responsible for the privacy practices of those sites.

13. Breach Notification

In the event of a personal data breach likely to result in risk to rights and freedoms we will notify affected individuals and the NDPC as required by law.

14. Changes to this Policy

We may update this Privacy Policy. We will post the revised policy with the updated "Last updated" date. Material changes will be notified where required.

15. Contact

Data Protection Officer: dpo@seimediatechnologies.com

For privacy enquiries, complaints or to exercise your rights, contact the DPO. You may also lodge a complaint with the Nigeria Data Protection Commission (NDPC).