Privacy Policy

1. Introduction

BullBearMetrics (“BBM,” “we,” “us,” or “our”) provides a currency and commodity bias-scoring platform. This Privacy Policy explains how we collect, use, share, and protect your personal data when you visit our website or use our platform, and it is written to comply with the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act (NDPA) 2023.

By creating an account or otherwise using BullBearMetrics, you acknowledge that you have read and understood this policy.

2. Data We Collect

We may collect the following categories of personal data:

• Identity & contact data — name and email address
• Payment-related metadata — billing details and transaction records processed through our third-party payment processor; we do not store full card numbers ourselves
• Device & usage data — IP address, browser type, device information, pages visited, and how you interact with the platform
• Account activity — login history and support correspondence

3. Purpose of Data

We use your data to:

• Provide, maintain, and secure access to the platform
• Process subscription payments and manage billing
• Monitor and improve platform performance and analytics accuracy
• Communicate account updates, service notices, and (where you’ve opted in) product updates
• Detect, investigate, and prevent fraud, abuse, or security incidents
• Comply with applicable legal and regulatory obligations

4. Legal Basis (NDPR Compliance)

We process your personal data on one or more of the following legal bases:

• Consent — where you have actively agreed to a specific use of your data, such as marketing communications
• Contractual necessity — where processing is required to provide the platform you’ve subscribed to
• Legitimate interest — where processing is reasonably necessary for our business operations (e.g. security monitoring, service improvement) and does not override your rights and freedoms
• Legal obligation — where we’re required to process or retain data to comply with applicable law

5. Data Sharing

We do not sell your personal data.

We may share data with the following categories of third parties, each bound by their own data protection obligations:

• Payment processors (such as Flutterwave), to process subscription payments securely
• Hosting & infrastructure providers, to operate and secure the platform
• Analytics tools, to understand platform usage and improve performance
• Regulators or law enforcement, where required by law or to protect our legal rights

6. International Data Transfers

Some of the third-party providers listed above (including our hosting, analytics, and payment infrastructure) may process data outside Nigeria. Where this occurs, we take reasonable steps to ensure the receiving party maintains a standard of data protection consistent with the NDPR, such as relying on providers with recognised data protection certifications or contractual safeguards.

7. Cookies & Similar Technologies

We use cookies and similar technologies to keep you signed in, remember your preferences, and understand how the platform is used. You can control or disable cookies through your browser settings; note that some parts of the platform may not function correctly without them.

8. Data Security

We implement technical and organisational measures appropriate to the risk, including:

• Secure servers and infrastructure
• Encrypted connections (SSL/TLS) for data in transit
• Restricted, role-based access controls for internal systems

No system is completely secure, and we cannot guarantee absolute security of data transmitted over the internet.

9. Data Retention

We retain personal data only for as long as necessary to provide our services, comply with legal, tax, or regulatory obligations, resolve disputes, and enforce our agreements. When data is no longer needed for these purposes, we securely delete or anonymise it.

10. Your Rights (NDPR)

Subject to applicable law, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of your data, where applicable
• Withdraw consent at any time, where processing is based on consent
• Object to or restrict certain processing of your data
• Request a copy of your data in a portable format

To exercise any of these rights, contact us at [email protected]. We will respond within the timeframe required under the NDPR.

11. Children’s Privacy

BullBearMetrics is not directed at, and is not intended for use by, individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so we can remove it.

12. Complaints

If you believe your data protection rights have been violated, you can contact us directly at [email protected] so we can address your concern. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), the regulatory body responsible for enforcing the NDPR.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Material changes will be indicated by updating the “Effective date” at the top of this page. We encourage you to review this policy periodically.

14. Contact Us

For any questions about this Privacy Policy or how we handle your data, contact:

[email protected]