Important note: This document has been adapted for worldwide product launch consistency from Nigeria-focused source documents. It should be reviewed by qualified counsel before being treated as final legal advice or a final binding policy. 

1. About this Policy 

PidginGPT is a product of MIO Global Holdings. For purposes of this Privacy Policy, “PidginGPT”, “we”, “us”, or “our” refers to MIO Global Holdings and its affiliates, subsidiaries, regional operating entities, service providers, successors, and assigns involved in providing the Platform. In Nigeria, certain operations, payment processing, support, or local compliance activities may be managed through PidginGPT Technologies. 

This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, and the rights you may have when you use www.pidgingpt.com, our web application/PWA, application programming interfaces, and related services (the “Platform”). 

This Policy is designed for a worldwide audience and should be interpreted together with applicable privacy and data-protection laws, including, where applicable, Nigerian Data Protection Law, GDPR/UK GDPR, PIPEDA, US state privacy laws, and other applicable privacy laws. 

2. Who This Policy Applies To 

This Policy applies to all users of the Platform. The Platform is intended for users aged eighteen (18) or older, or the age of majority in their jurisdiction, whichever is higher. We do not knowingly collect personal data from anyone under eighteen. If you believe a minor has provided personal data, contact hello@pidgingpt.com. 

3. Personal Data We Collect 

3.1 Data you provide to us 

• Account data, such as name, email address, password credentials, and registration details; 

• Profile data, such as language preferences, product preferences, and optional information you provide; 

• Billing data, such as billing name and address, transaction history, subscription status, and limited card metadata received from payment processors; 

• User Input and content, such as prompts, text, files, and other content you submit for processing; 

• Communications, such as messages to support, feedback, forms, survey responses, and partnership enquiries. 

  
  

3.2 Data we collect automatically 

• Device and technical data, such as IP address, device identifiers, browser type, operating system, language settings, and crash logs; 

• Usage data, such as pages and features accessed, queries made, session duration, interaction events, referral source, and approximate location derived from IP address; 

• Cookies and similar technologies, as described in Section 8. 

3.3 Data we receive from third parties 

• Third-party sign-in providers, if you choose to use them; 

• Payment processors, such as Stripe, Paystack, or other authorised processors, which may provide transaction-status information, fraud signals, and limited card metadata; 

• Service providers and fraud-prevention partners that help operate, secure, or improve the Platform. 

4. How and Why We Use Personal Data 

• Providing the Platform: to create and manage Accounts, deliver AI-powered features, process User Input, and provide AI Output; 

• Billing and subscription management: to process payments, manage subscriptions, prevent fraud, handle cancellations, refunds, and chargebacks; 

• Communications: to respond to enquiries, send service notices, security alerts, billing notices, policy updates, and marketing communications where permitted;

• Personalisation: to remember settings, preferences, and product choices; 

• Safety, security, and fraud prevention: to monitor for and respond to abuse, fraud, security incidents, and Terms violations; 

• Analytics and improvement: to understand Platform usage, improve reliability, and develop features; 

• AI model evaluation and improvement: to evaluate quality, improve performance, and develop safeguards, subject to Section 6; 

• Legal and compliance: to comply with Applicable Law, respond to lawful requests, and enforce our Terms. 

5. Legal Bases for Processing 

Where Applicable Law requires a legal basis for processing, we rely on one or more of the following: performance of a contract, legitimate interests, legal obligation, consent, and in rare cases vital interests. You may withdraw consent where we rely on consent, without affecting processing already carried out. 

6. AI Model Training and Improvement 

PidginGPT operates an artificial-intelligence service. To run the Platform, we process User Input and AI Output to generate responses, monitor for abuse, secure the Platform, and improve quality. 

• We do not sell User Input or AI Output. 

• We do not share User Input or AI Output with third parties for the purpose of training their own models, except where clearly disclosed and permitted by Applicable Law. 

• Where we use User Input or AI Output to improve, evaluate, or fine-tune our systems, we apply technical and organisational safeguards designed to minimise personally identifiable information and restrict internal access. 

• Where required by law or where we offer it, you may have the ability to opt out of having User Input or AI Output used to improve our AI systems through Account controls or by contacting hello@pidgingpt.com. 

• We do not use User Input or AI Output to make solely automated decisions that produce legal or similarly significant effects concerning you. If this changes, we will update this Policy. 

7. Sharing and Disclosure of Personal Data 

We do not sell personal data. We share personal data only where reasonably necessary, including with: 

• Service providers and processors, such as hosting providers, payment processors, email providers, support tools, analytics providers, and security vendors; 

• AI infrastructure providers and inference partners that help deliver AI features under confidentiality and data-protection obligations; 

• Affiliates and regional entities, including MIO Global Holdings and, where applicable for Nigeria operations, PidginGPT Technologies; 

• Legal and safety recipients, where disclosure is necessary to comply with law, a court order, lawful request, or to protect rights, property, safety, and security; 

• Business transfer recipients in connection with mergers, acquisitions, financing, reorganisation, or sale of assets; 

• Third parties where you consent or direct us to share information. 

8. Cookies and Similar Technologies 

We and our service providers may use cookies, pixels, SDKs, and similar technologies to operate the Platform, remember preferences, analyse usage, and, where permitted, measure marketing effectiveness. Where required by law, we request consent before using non-essential cookies. You can manage cookies through browser settings or Platform controls where available. 

9. International Data Transfers 

PidginGPT operates internationally. Personal data may be transferred to, stored, and processed in countries other than your country of residence, including Nigeria, Canada, the United States, the United Kingdom, the European Economic Area, and other countries where our service providers operate. Where required, we use appropriate safeguards such as standard contractual clauses, recognised transfer mechanisms, and technical and organisational measures. 

10. Data Retention 

We retain personal data only for as long as necessary for the purposes described in this Policy or as required by Applicable Law. As general guidance: 

• Account data is retained for the life of the Account and for a reasonable period after closure, then deleted or anonymised; 

• Billing and transaction data may be retained for tax, accounting, anti-fraud, and legal purposes; 

• User Input and AI Output may be retained for operational debugging, abuse monitoring, safety, improvement, or legal compliance, subject to product settings and legal requirements; 

• Support communications may be retained to manage support history and legal obligations; 

• Marketing data is retained until consent is withdrawn or objection is made where applicable. 

11. Data Security 

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. Measures may include encryption in transit and at rest, access controls, logging, monitoring, secure development practices, and security testing. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. 

12. Your Rights 

Subject to Applicable Law, you may have rights to access, rectify, delete, restrict, port, object to processing, withdraw consent, and complain to a supervisory authority. To exercise rights, contact hello@pidgingpt.com. We may need to verify your identity before responding. 

13. Third-Party Services and Links 

The Platform may contain links to or integrations with third-party websites, applications, or services. We are not responsible for the privacy practices of third parties. Please review their privacy notices before providing personal data. 

14. Changes to this Policy 

We may update this Privacy Policy from time to time. Where changes are material, we will notify users by email, in-Platform notice, or prominent website notice where required by Applicable Law. The “Last Updated” date indicates the most recent update. 

15. Contact Us and Data Protection Requests 

For questions, complaints, or requests about this Policy or personal data, contact hello@pidgingpt.com. PidginGPT is a product of MIO Global Holdings. In Nigeria, certain operations, payment processing, support, or local compliance activities may be managed through PidginGPT Technologies. If you are not satisfied with our response, you may contact the Nigeria Data Protection Commission, the UK Information Commissioner’s Office, the Office of the Privacy Commissioner of Canada, a US state privacy authority, or another local data-protection authority applicable to you.