Privacy Policy

1. Scope of this Policy

This Privacy Policy applies to personal data processed through 360 websites, applications, dashboards, communication tools and related services.

It applies to users including individuals, workers, customers, sellers, service providers, businesses, creators, partners and users of specialised 360 tools.

2. Information We Collect

Depending on how you use 360, we may collect the following categories of personal information.

Account information

• Name;
• Username;
• Email address;
• Phone number;
• Country;
• Account type;
• Password information stored in protected form; and
• Account preferences.

Profile information

• Profile photograph or avatar;
• Location;
• Profession, trade or business role;
• Skills and services;
• Business or personal description;
• WhatsApp contact where provided; and
• Other information you choose to add to your profile.

Business information

• Business name and contact information;
• Products and services;
• Business location;
• Business descriptions;
• Brand logo;
• Registration or verification documents;
• Government identification where verification requires it; and
• Business operational information entered into 360 tools.

Transaction information

• Transaction amounts;
• Transaction parties;
• Product or service details;
• Payment status;
• Escrow status;
• Transaction timestamps;
• Refund or dispute information; and
• Payment references and related metadata.

Communications

When you use 360 messaging or support features, we may process messages, attachments, sender and recipient details, timestamps and related communication metadata.

Technical and usage information

• IP address;
• Device and browser information;
• Login and security events;
• Pages and features used;
• App activity;
• Cookie information; and
• Diagnostic or error information.

3. How We Collect Information

We may collect information directly from you when you:

• Create or update an account;
• Create a personal or business profile;
• List a product or service;
• Upload documents or content;
• Send or receive messages;
• Make or receive a transaction;
• Use Smart Escrow;
• Apply for verification;
• Submit a support request;
• Use business or work tools; or
• Participate in monetization features.

We may also collect certain technical information automatically when you access the website or app.

Some information may be received from payment providers or other service providers where required to complete a service you requested.

4. How We Use Your Information

We may use personal information to:

• Create and maintain your account;
• Provide 360 services and features;
• Show relevant people, businesses and services;
• Support location-based discovery;
• Enable messaging and communications;
• Process transactions and escrow activity;
• Manage products, services and business tools;
• Provide work, gig and opportunity features;
• Operate creator and monetization services;
• Verify businesses or accounts;
• Provide customer support;
• Prevent fraud and misuse;
• Protect users and the platform;
• Improve performance and user experience;
• Meet legal and regulatory obligations; and
• Communicate important service information.

5. Lawful Basis for Processing

Where required by applicable data-protection law, 360 processes personal information using recognised lawful bases.

These may include:

• Contract: where processing is necessary to provide a service you requested.
• Consent: where you have given permission for a particular use of your information.
• Legitimate interests: where necessary for appropriate platform operations, security, fraud prevention or service improvement, subject to your rights.
• Legal obligations: where we must process information to comply with applicable law or lawful regulatory requirements.

6. Payments and Smart Escrow

Payments made through 360 may be processed by third-party payment providers such as Paystack.

The payment provider may collect or process information required to authorize and complete payments.

360 may receive transaction-related information such as payment references, amounts, status, payer or recipient information and settlement information.

Smart Escrow

When Smart Escrow is used, we may retain information necessary to administer the transaction, including transaction parties, amounts, status, communication relevant to a dispute and evidence provided during dispute resolution.

7. Location Information

360 may use location information you provide, such as your city or base of operations, to enable location-based discovery and show people, services, businesses, opportunities or content relevant to your area.

Some device-based location features may require additional permission from your device or browser.

You may be able to update your location through your account settings.

8. Messages and Communications

360 provides communication tools that allow users to contact one another and communicate with support.

We may process message content and related metadata in order to deliver messages, maintain communication functionality, investigate reports, resolve disputes, prevent abuse and protect users.

Users should avoid sending highly sensitive information through chat unless it is necessary for the relevant transaction or service.

9. Business and Verification Information

Certain business features may require additional information to establish or verify the identity of a business or person acting for that business.

This information may include:

• Business identity information;
• CAC or business-registration documents;
• Government-issued identification;
• Business address;
• Business contact information; and
• Supporting verification documents.

Verification information is used for purposes such as account verification, fraud prevention, compliance and protection of the 360 community.

10. When We Share Information

We may share personal information where reasonably necessary to operate 360.

Other users

Information you make part of your profile, business listing, product listing or service offering may be visible to other users.

Payment and service providers

We may share information with providers that support payments, hosting, communications, analytics, security, email delivery and other technical services.

Legal and regulatory requirements

We may disclose information where required by applicable law, court order, regulatory requirement or another valid legal process.

Safety and fraud prevention

Information may be shared where reasonably necessary to detect or prevent fraud, abuse, security threats or harm to users.

Business changes

If 360 undergoes a merger, acquisition, reorganisation or transfer of part of its business, relevant information may be transferred subject to applicable privacy safeguards.

11. Cookies and Analytics

360 websites may use cookies or similar technologies to keep users signed in, remember preferences, maintain security, understand platform usage and improve services.

Some cookies may be necessary for the website to operate correctly. Other cookies or analytics tools may depend on your preferences or applicable consent requirements.

You can also manage certain cookie settings through your browser.

12. How Long We Keep Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including providing services, maintaining transaction records, resolving disputes, preventing fraud and meeting legal obligations.

Different categories of information may have different retention periods.

Information may be retained for longer where necessary for legal, regulatory, accounting, security, fraud-prevention or dispute-resolution purposes.

13. Data Security

360 uses reasonable technical and organisational measures intended to protect personal information against unauthorised access, disclosure, alteration, loss or misuse.

These protections may include access controls, authentication, restricted administrative access, system monitoring and other security measures.

No online platform can guarantee absolute security. Users should therefore protect their passwords, devices and login credentials.

14. International Data Transfers

Some service providers used to operate 360 may process or store information outside Nigeria.

Where personal data is transferred internationally, 360 will take steps required by applicable law to ensure an appropriate level of protection or other lawful transfer safeguards.

15. Your Privacy Rights

Subject to applicable law and any permitted limitations, you may have rights relating to your personal data.

To exercise a privacy right, contact: support@360.com.ng .

We may need to verify your identity before acting on certain privacy requests.

16. Account Deletion

You may request deletion of your 360 account through the available account-deletion feature or by contacting support.

When a valid deletion request is processed, personal profile information associated with the account will be deleted or anonymised within the applicable deletion period.

360 currently aims to complete account deletion requests within 90 days.

Limited records may be retained where necessary for:

• Legal or regulatory obligations;
• Fraud and security investigations;
• Transaction and accounting records;
• Dispute resolution; or
• Protection of legal rights.

Minimal system or security logs may also remain for a limited period before deletion.

You can access the account deletion page here: Request Account Deletion .

17. Third-Party Websites and Services

360 may contain links to websites, applications or services operated by third parties.

Their privacy practices are governed by their own policies. We encourage users to review those policies before providing personal information to third parties.

18. Changes to this Privacy Policy

We may update this Privacy Policy as 360 develops, our services change or applicable legal requirements change.

The most current version will be published on this page with the date of the latest update.

Where appropriate, material changes may also be communicated through the website, app, email or another reasonable method.