Data Privacy Notice

Nigeria Data Protection Act 2023 and NDPR-aligned notice | Effective date: 1 October 2026

This notice explains how PawaPlay Digital Limited processes personal data for Lagos Power Connect. It is designed to support compliance with the Nigeria Data Protection Act 2023 and, where applicable, the Nigeria Data Protection Regulation (NDPR).

1. Data controller

PawaPlay Digital Limited is the data controller for personal data collected through LagosPowerConnect.ng and authorised Programme registration channels.

2. Personal data we collect

We may collect full name, mobile number, address or community, LGA, CDA or ward, electricity provider, meter number, meter type, customer-account information, household or small-business details, verification responses, communications and programme fulfilment records.

3. Why we use your data

We process data to receive and assess registrations; verify identity, location and meter details; identify duplicate or fraudulent applications; select and contact beneficiaries; deliver support; maintain audit, security and delivery records; respond to complaints; and comply with lawful obligations.

4. Lawful basis

Processing is undertaken on the basis of consent, performance of a Programme-related request initiated by the data subject, legitimate interests in operating a secure and fair social-support initiative, and compliance with applicable legal obligations. Where consent is relied upon, it may be withdrawn, although this may prevent us from processing an application or delivering support.

5. Sharing and transfers

We share data only where necessary with authorised Programme personnel, vetted service providers, community-verification representatives, electricity-service providers, auditors, funders and public authorities where required by law. Any cross-border transfer will be made only where a lawful protection mechanism is in place.

6. Security and retention

We apply reasonable administrative, technical and organisational safeguards, including access controls, need-to-know permissions, audit records and secure handling practices. Data is retained only for as long as necessary for the Programme, lawful reporting, dispute resolution, fraud prevention and record-keeping obligations, after which it will be deleted, anonymised or securely archived as appropriate.

7. Your rights

Subject to applicable law, you may request access to, correction of, deletion of, restriction of or objection to processing of your personal data; request portability where applicable; withdraw consent; and complain to the Nigeria Data Protection Commission. Requests should be sent through the official Lagos Power Connect contact channel.

8. Children and sensitive information

The Programme is not designed to collect children's data. Do not submit another person's data without authority. Do not submit sensitive information unless it is specifically requested and necessary for verification.

9. Updates

We may update this Notice to reflect changes in law, technology or Programme operations. The current version will be published on LagosPowerConnect.ng.