Legal Document

Privacy Policy

๐Ÿ“… Effective: 1 January 2026 ๐Ÿ“ Jurisdiction: Federal Republic of Nigeria ๐Ÿข CunkPay ยท Afraah Tech Hub
Introduction

Welcome to CunkPay, a micro-task marketplace operated by Afraah Tech Hub ("we", "us", "our"), based in Funtua, Federal Republic of Nigeria. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our platform at cunkpay.com.ng (the "Platform").

By creating an account or using CunkPay in any way, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the Platform.

This policy applies to all users of CunkPay โ€” Workers, Advertisers, and Admins. It covers data collected through our website and any services provided through the Platform.
Data We Collect

We collect only the data necessary to operate the Platform and provide our services. We do not collect data beyond what is listed below.

Data TypeWhat We CollectWhen Collected
IdentityFull nameAt registration
ContactEmail address, phone numberAt registration
AccountRole (Worker/Advertiser), account status, registration dateAt registration
FinancialWallet balances, transaction history, deposit and withdrawal recordsDuring platform use
Bank DetailsBank name, account number, account name (for withdrawals only)When requesting a withdrawal
Proof ContentImages uploaded as task proof, text submitted as task proofWhen submitting task proof
Task DataTasks created by Advertisers including title, description, reward, proof typeWhen creating tasks
Usage DataFirebase authentication logs, access timestampsAutomatically during use

We do not collect payment card numbers, BVN, NIN, passwords in readable form, or any biometric data.

How We Use Your Data

We use your data solely to operate and improve the CunkPay platform. Specifically:

  • To create and manage your account and verify your identity
  • To process wallet transactions โ€” deposits, task payments, and withdrawals
  • To enable Advertisers to post tasks and Workers to submit proof
  • To allow Admin to verify deposits and process withdrawals
  • To maintain the immutable transaction ledger for financial transparency
  • To display your proof images and text to the Advertiser who posted the task
  • To investigate and resolve disputes between Workers and Advertisers
  • To send account-related communications (e.g. deposit approved, proof reviewed)
  • To detect and prevent fraud or platform abuse
We do not use your data for advertising, profiling, or any purpose unrelated to operating the Platform.
Data Sharing

We do not sell, rent, or trade your personal data to any third party. Your data is shared only in the following limited circumstances:

  • With Advertisers: When you submit task proof as a Worker, the Advertiser who posted the task can view your proof image or text and your display name.
  • With Admin: Platform administrators can access all account and transaction data as necessary to operate the Platform, approve deposits, and process withdrawals.
  • With Firebase (Google): Authentication and database services are provided by Google Firebase. Your data is stored on Firebase servers subject to Google's data processing terms.
  • With Cloudinary: Proof images uploaded to the Platform are stored on Cloudinary's servers. By uploading an image, you agree to Cloudinary's terms of service.
  • Legal requirements: We may disclose your data if required by Nigerian law, a court order, or a lawful request by a government authority.
Storage & Security

Your data is stored on Google Firebase servers in the europe-west1 (Belgium) region. Firebase provides industry-standard encryption in transit (TLS) and at rest.

Proof images are stored on Cloudinary's global CDN and served over HTTPS.

Passwords are managed entirely by Firebase Authentication โ€” we never store your password in readable form.

The transaction ledger is stored as an append-only collection in Firestore with security rules that prevent any record from being updated or deleted โ€” including by platform administrators. This ensures the financial integrity of your history.

While we implement reasonable security measures, no internet service can guarantee absolute security. You are responsible for keeping your account credentials confidential.
Your Rights

Under the Nigeria Data Protection Act (NDPA) 2023 and related regulations, you have the following rights regarding your personal data:

  • Right to access: Request a copy of the personal data we hold about you.
  • Right to rectification: Correct inaccurate data โ€” you can update your name and phone number directly from your account settings.
  • Right to erasure: Request deletion of your account and personal data. Note: transaction ledger entries cannot be deleted as they form part of an immutable financial record.
  • Right to object: Object to processing of your data where no legitimate basis exists.
  • Right to data portability: Request your data in a machine-readable format.

To exercise any of these rights, contact us at info@cunkpay.com.ng. We will respond within 30 days.

Cookies

CunkPay uses minimal cookies necessary to operate the Platform. Specifically:

  • Authentication cookies: Firebase sets cookies to maintain your signed-in session. These are essential and cannot be disabled while using the Platform.
  • No advertising cookies: We do not use advertising cookies, tracking pixels, or third-party analytics cookies.

You can clear cookies at any time from your browser settings, which will sign you out of CunkPay.

Third-Party Services

CunkPay uses the following third-party services to operate. Each has its own privacy policy:

ServicePurposeProvider
Firebase AuthenticationUser sign-in and session managementGoogle LLC
FirestoreDatabase storage for accounts, tasks, transactionsGoogle LLC
CloudinaryStorage and delivery of proof imagesCloudinary Ltd
Google FontsTypography (Space Grotesk, Inter)Google LLC
AfeesHostWebsite hostingAfeesHost Ltd

We have no control over how these providers handle data beyond their published terms. We encourage you to review their privacy policies.

Children's Privacy

CunkPay is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has created an account on our Platform, please contact us at info@cunkpay.com.ng and we will delete the account promptly.

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date at the top of this page. If changes are material, we will notify registered users via the email address on their account.

Continued use of CunkPay after changes are posted constitutes your acceptance of the updated policy.

Contact Us

For any privacy-related questions, data requests, or concerns, contact us:

CunkPay Data Enquiries
Operated by Afraah Tech Hub ยท Funtua, Nigeria
Email: info@cunkpay.com.ng
Support: support@cunkpay.com.ng