1. Who We Are
Luuk Marketplace Limited ("Luuk", "we", "our", or "us") is a company registered in the Federal Republic of Nigeria. We operate the Luuk app and website at luuk.com.ng — a video-first marketplace connecting buyers and sellers across Nigeria.
Luuk is the data controller responsible for your personal information collected through our platform. Our Data Protection Officer (DPO) can be reached at privacy@luuk.com.ng.
2. What We Collect
Information you give us
- Account details: full name, email address, phone number, and profile photo when you register.
- Seller information: business name, bank account details (for payouts), government-issued ID (for seller verification), and product listings including video content.
- Transaction data: purchase history, negotiation records, payment amounts, and delivery confirmations.
- Communications: messages sent through in-app chat, support tickets, and dispute evidence you submit.
Information we collect automatically
- Device data: device type, operating system, app version, and a unique device identifier.
- Usage data: which videos you watch, for how long, what you search for, and how you navigate the app. This powers coin rewards and feed personalisation.
- Location data: approximate city-level location to show you local sellers and enable cash-on-delivery. We do not track precise GPS without your explicit permission.
- Log data: IP address, timestamps, and error logs for security and debugging purposes.
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On video listings: Videos you post as a seller are public content — visible to all Luuk users. Do not include sensitive personal information in your product videos.
3. How We Use Your Information
We use your data only for legitimate purposes directly related to operating the marketplace:
- Running the marketplace: Processing transactions, releasing escrow payments, and facilitating buyer-seller communication.
- Personalisation: Tailoring your video feed to products you're likely to want based on your watch history and interactions.
- Coin rewards: Tracking your video watch time to calculate and credit Luuk coin earnings.
- Safety & fraud prevention: Detecting fake accounts, fraudulent listings, and suspicious transaction patterns.
- Dispute resolution: Reviewing evidence submitted by both parties to make fair rulings on buyer-seller disputes.
- Communications: Sending order updates, payment confirmations, and (with your consent) promotional notifications about weekend sales and new features.
- Legal compliance: Meeting our obligations under Nigerian law, including tax reporting and fraud investigation cooperation with authorities.
We do not use your data to build advertising profiles for third-party advertisers. We do not sell, rent, or trade your personal information.
4. Who We Share Your Information With
We share your data only where necessary to operate the platform:
- Payment processors: Your payment details are processed by licensed Nigerian payment service providers (PSPs) regulated by the Central Bank of Nigeria. We do not store full card numbers.
- Logistics partners: Sellers' and buyers' delivery addresses are shared with the logistics partner handling a specific order. Only the information required for that delivery is shared.
- Sellers (when you buy): Your delivery address and first name are shared with the seller to fulfil your order. Your phone number is shared only if you choose to enable direct contact.
- Buyers (when you sell): Your seller name and city are visible to buyers. Your full address and bank details are never visible to buyers.
- Legal authorities: We disclose information to Nigerian law enforcement or regulatory bodies only when compelled by valid legal process or to prevent fraud and serious harm.
- Cloud infrastructure: We use reputable cloud service providers to host the Luuk platform. These providers process data on our behalf under strict data processing agreements.
No data is transferred outside Nigeria or the African continent without appropriate safeguards in place.
5. Cookies & Tracking Technologies
The Luuk website (luuk.com.ng) uses a small number of cookies:
- Essential cookies: Required for the website to function — session management and security tokens. Cannot be disabled.
- Analytics cookies: We use privacy-respecting analytics to understand how visitors use our website (page visits, time on page). No cross-site tracking. You can opt out via your browser settings.
- Preference cookies: Remembering your language and display preferences.
The Luuk app does not use browser cookies. App-side analytics are anonymised and aggregated.
6. Your Rights Under the NDPA 2023
As a Nigerian data subject, you have the following rights:
- Right to access: Request a copy of all personal data we hold about you.
- Right to rectification: Correct inaccurate or incomplete information in your profile.
- Right to erasure: Request deletion of your account and associated data. Some data may be retained for legal compliance (e.g. transaction records for tax purposes).
- Right to data portability: Receive your data in a structured, machine-readable format.
- Right to object: Object to processing your data for marketing communications at any time. Opt out in the app under Settings → Notifications.
- Right to withdraw consent: Where processing is based on consent (e.g. location access), you may withdraw consent at any time via app permissions settings.
To exercise any of these rights, email privacy@luuk.com.ng or use the in-app "Privacy Controls" section. We respond within 30 days.
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If you believe we have handled your data unlawfully, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.
7. Data Security
We take security seriously because your money and your identity are on the line:
- All data in transit is encrypted using TLS 1.2 or higher.
- Sensitive data at rest (bank details, ID documents) is encrypted using AES-256.
- Seller bank account numbers are tokenised — we store a reference, not the raw number.
- Access to production data is restricted to essential team members and logged.
- We conduct regular security reviews and penetration tests.
In the event of a data breach that is likely to result in risk to your rights, we will notify you and the NDPC within 72 hours of becoming aware, as required by law.
8. How Long We Keep Your Data
- Account data: Retained while your account is active. Deleted within 30 days of an account deletion request, except where retention is legally required.
- Transaction records: Retained for 7 years for tax and regulatory compliance under Nigerian law.
- Support communications: Retained for 2 years to help resolve recurring issues and improve our service.
- Video listings: Deleted when you remove the listing or close your seller account.
- Device and usage logs: Retained for up to 12 months then automatically purged.
9. Children's Privacy
The Luuk platform is not directed at persons under the age of 18. We do not knowingly collect personal information from anyone under 18. If you believe a child has created an account on Luuk, please contact us immediately at privacy@luuk.com.ng and we will delete the account promptly.
10. Changes to This Policy
We update this policy when our practices change or when the law requires it. When we make material changes, we will notify you via in-app notification and email at least 14 days before the change takes effect. The "Last updated" date at the top of this page reflects the most recent revision.
Continued use of Luuk after a policy update constitutes acceptance of the revised terms.