Privacy Policy

Version 5.0 | Effective: September 2026 | Compliant with NDPA 2023

1. Introduction

SummerIsland Systems ("we", "us", "our") operates What's Up Trivia, a skill-based knowledge competition platform available on the web at play.whatsuptrivia.com.ng, on WhatsApp and on Telegram. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023.

2. Data Controller

Company: SummerIsland Systems
Email: hello@whatsuptrivia.com.ng
Location: Abuja, Nigeria

3. Information We Collect

3.1 Information You Provide

Phone number (WhatsApp accounts)
Telegram user ID and username (Telegram accounts)
Email address (web accounts). If you sign in with Google, we receive your name and email address from Google
Full name, username, and state or city
Your age, to confirm eligibility
How you heard about us, if you choose to tell us
Bank account details, for reward redemption
Challenge details you create: categories, start time, number of players, and any prize you sponsor
Reviews you submit
KYC documents (government ID, photo) when required

3.2 Information Collected Automatically

Device identifiers and fingerprints
Platform information (web, WhatsApp or Telegram)
Round session data, including your answers and response times
On the web: your IP address and browser details, recorded against your answers for integrity purposes
On the web: signals that indicate copying of question text or automated play, and whether a round is open on more than one device
Transaction and payment records
Website analytics data — see section 3.4

3.3 Photos

During a round you may be asked to take a photo to confirm that you are the person playing. We use it only to verify identity and prevent abuse. Separately, photos submitted as part of KYC verification are handled as KYC documents (section 7).

3.4 Website Analytics and Cookies

On our website (whatsuptrivia.com.ng) we use analytics tools to understand how visitors find and use the site. These tools set cookies and similar identifiers, and may collect your approximate location (country/city level), device and browser type, pages viewed, and the links you click.

We ask for your consent before any of this begins. When you first visit the site you are shown a notice with Accept and Decline options. If you decline, or if your browser sends a “Do Not Track” signal, no analytics tools are loaded at all — no cookie is set and no data is sent. Your choice is remembered on your device, and you can reverse it at any time by clearing your browser data for this site.

The tools we use for this are:

Google Analytics 4 (Google LLC) — website traffic and usage measurement. IP addresses are anonymised. Google’s privacy policy: policies.google.com/privacy
Meta Pixel (Meta Platforms, Inc.) — used only if and when we run advertising on Facebook or Instagram, to measure whether those adverts work. Meta’s privacy policy: facebook.com/privacy/policy

These tools are operated by companies outside Nigeria, so accepting analytics involves the transfer of this data abroad. We do not use them inside the game itself — playing on WhatsApp, Telegram or Web-play does not involve these third-party analytics tools.

3.5 The Web App on Your Device

The game at play.whatsuptrivia.com.ng stores a small amount of information on your own device to work properly: that you are signed in, your sound setting, and whether you have dismissed prompts such as "Add to home screen". It also keeps a copy of the app's own files so it opens quickly and can be installed to your home screen. None of this is used for advertising or shared with anyone.

If you allow notifications, your browser creates a notification address for your device, which we store so we can tell you when a live challenge lobby opens. Notifications are delivered through your browser's own push service (for example Google, Apple or Mozilla). The content of each notification is encrypted so that the push service cannot read it. You can turn notifications off at any time in your device or browser settings, and we delete a notification address as soon as it stops working.

4. How We Use Your Information

Provide and maintain the competition platform
Run challenges between players and deliver their results
Process payments, reward redemptions, challenge prizes and refunds
Verify identity and prevent platform abuse
Enforce our Terms of Service
Send platform-related messages and, where you allow them, notifications
Improve our services
Comply with legal obligations

5. Legal Basis for Processing (NDPA 2023)

Contract Performance: To provide the platform service
Consent: For website analytics, notifications and marketing communications
Legitimate Interest: For platform integrity and abuse prevention
Legal Obligation: For regulatory requirements

6. What Other People Can See

Result and victory cards show your username, your city and your result, and can be shared publicly
In a challenge, the other players see your username and score, and the final standings appear on the challenge's result card
Leaderboards show your username and ranking
Reviews you submit are published under the name you choose to show; verified reviews also show an approximate number of games you have played
Our live activity feed on the website shows usernames only, never real names

7. Data Sharing

We may share your information with:

Payment Processors: For secure payment processing
WhatsApp/Telegram: As messaging platforms
Google: If you choose to sign in with Google
Push services: Google, Apple or Mozilla deliver notifications you have allowed; they receive encrypted content only
Analytics Providers: Google (Analytics) and, where advertising is running, Meta — website usage data only, and only where you have consented (see section 3.4)
Cloud Providers: For data storage
Law Enforcement: When legally required

We do NOT sell your personal data to third parties.

8. Data Retention

Data Type	Retention Period
Account Data	Duration of account + 2 years
Round History	2 years
Transaction Records	7 years (tax compliance)
KYC Documents	5 years after verification
Round Audit Logs	7 days
Game Review (web, question by question)	72 hours
Notification Address	Until you turn notifications off or it stops working

9. Your Rights (NDPA 2023)

You have the right to:

Access: Request a copy of your personal data
Rectification: Correct inaccurate data
Erasure: Request deletion (subject to legal requirements)
Restriction: Limit how we process your data
Portability: Receive your data in a portable format
Objection: Object to certain processing activities

To exercise these rights, email: hello@whatsuptrivia.com.ng

10. Data Security

We implement appropriate security measures including encryption, secure payment processing, access controls, and regular security assessments.

11. Children's Privacy

What’s Up Trivia is a knowledge competition open to users aged 13 and above. We do not knowingly collect data from anyone under 13, and we will delete any such data promptly if we become aware of it.

For users aged 13 to 17 we apply additional care: we collect only what the competition requires, we do not use their data to build advertising profiles, and a parent or guardian may contact us at any time to review, correct or delete their child’s data, or to close the account. Requests of this kind go to hello@whatsuptrivia.com.ng and are actioned within 7 days. Users under 18 cannot sponsor a challenge prize.

Where the law of a user’s location requires parental consent for a person under 18 to use a service of this kind, that consent is the user’s responsibility to obtain before playing.

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify users of significant changes via our platforms.

13. Contact Us

Privacy Inquiries: hello@whatsuptrivia.com.ng
Phone: +2349160975128