Privacy Policy

1. Who we are

TooTooGood is a digital-deals discovery and transaction-facilitation service operated by [FULL LEGAL NAME], trading as “TooTooGood”. Our principal address is [ADDRESS] and our CAC registration number is [RC/BN NUMBER]. For privacy questions or requests, contact [PRIVACY EMAIL] or [DPO/PRIVACY LEAD].

2. What this policy covers

TooTooGood curates offers for software and digital products supplied by third parties. Depending on the offer, we may collect preliminary checkout details, coordinate fulfilment, facilitate an escrow transaction, or redirect you to an external provider. Third parties such as PayOak, Brevo, WhatsApp or a product vendor may process data under their own policies.

3. Information we collect

• Contact and checkout details, such as your email address, name and optional or required WhatsApp number.
• Order information, including the selected deal, displayed price, transaction reference, status, fulfilment, refund or dispute records available to us.
• Consent records for email or WhatsApp marketing.
• Messages, support requests, complaints and other communications.
• Technical information such as IP address, browser, device, referring page, security logs, cookie identifiers and diagnostics.
• Payment status and transaction references returned by PayOak. TooTooGood does not intend to receive complete card details, bank credentials, BVNs or identity documents submitted directly to PayOak; this must be confirmed against the live integration.

4. Why we use information

We use personal data to administer requested checkouts, facilitate payment and fulfilment, send order or security messages, provide support, prevent fraud, maintain required accounting and dispute records, and improve the website. Promotional email and WhatsApp messages are sent only under the lawful basis documented for that channel, normally consent. A purchase is not conditional on consent to unrelated marketing.

5. Email and WhatsApp choices

If you opt in, Brevo may be used to send deal alerts and manage subscription records. Marketing emails include an unsubscribe method. WhatsApp marketing requires a separate choice; providing a phone number for fulfilment does not by itself authorise marketing. You may withdraw WhatsApp consent by replying STOP or contacting [PRIVACY EMAIL].

6. Providers and disclosures

Information may be shared where necessary with PayOak or Stonebridge Technologies Limited, Brevo, our WordPress host and administrators, security and backup providers, relevant product vendors, and professional advisers or authorities where legally required. We do not sell personal data.

7. International processing

Some providers may process data outside Nigeria. Where applicable, TooTooGood will document and use a transfer basis and safeguards permitted by the Nigeria Data Protection Act 2023 and applicable guidance.

8. Cookies and fonts

The final policy and cookie notice must match the website’s actual network behaviour. Strictly necessary, preference, analytics and advertising cookies should be listed with their purposes and lifetimes. If Google Fonts is remotely loaded, Google receives technical request data; self-hosting is preferred to reduce third-party disclosure.

9. Retention

We retain data only for a documented period reasonably required for fulfilment, accounting, fraud prevention, disputes, legal claims, consent evidence and suppression records. Final periods must be confirmed for abandoned checkouts, completed orders, support cases, security logs, marketing contacts and backups.

10. Security and incidents

We use proportionate technical and organisational measures, which should include HTTPS, role-based access, administrator multi-factor authentication, updates, backups, logging and processor due diligence. No internet service can guarantee absolute security. We maintain procedures for investigating and reporting qualifying personal-data incidents.

11. Your rights

Subject to applicable conditions, you may request access, correction, deletion, restriction, objection, withdrawal of consent, portability, information about transfers, and review of certain solely automated decisions. Contact [PRIVACY EMAIL]. You may also complain to the Nigeria Data Protection Commission and, where applicable, the Federal Competition and Consumer Protection Commission.

12. Children

TooTooGood is intended for persons aged 18 and over. We do not knowingly solicit purchases or marketing consent from children.

13. Changes and contact

Material changes will be communicated through an appropriate notice. Controller: [LEGAL OPERATOR] · Address: [ADDRESS] · Email: [EMAIL].

Official references

• Nigeria Data Protection Act 2023
• NDPC General Application and Implementation Directive 2025
• FCCPC consumer rights