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User Data Rights

User Data Rights

Effective Date: August 6, 2026

Last Updated: August 6, 2026

Service Provider: EasyCity Systems Ltd.

1. Introduction

This User Data Rights document explains your rights regarding your personal data collected and processed by Zolar (the "Platform"), operated by EasyCity Systems Ltd. ("we", "us", or "our").

These rights are provided under the General Data Protection Regulation (GDPR), the Nigeria Data Protection Regulation (NDPR), and other applicable data protection laws.

Your Data Rights

You have comprehensive rights over your personal data. This document explains those rights and how to exercise them.

2. Right to Access

2.1 What You Can Access

You have the right to access:

  • Confirmation of whether we process your personal data
  • A copy of your personal data we hold
  • The purposes of processing
  • The categories of personal data processed
  • The recipients of your personal data
  • The retention period for your personal data

2.2 How to Request Access

To request access to your data:

  • Submit a written request to privacy@easycitysystems.com.ng
  • Provide sufficient information to identify yourself
  • Specify the data you wish to access
  • We will respond within 30 days of receipt

3. Right to Rectification

2.1 What You Can Rectify

You have the right to request rectification of:

  • Inaccurate personal data
  • Incomplete personal data
  • Outdated personal data

3.2 How to Request Rectification

To request rectification:

  • Submit a written request to privacy@easycitysystems.com.ng
  • Specify the data to be rectified
  • Provide the correct information
  • We will respond within 30 days of receipt

4. Right to Erasure (Right to be Forgotten)

4.1 When You Can Request Erasure

You may request erasure of your personal data if:

  • The personal data is no longer necessary for the purposes for which it was collected
  • You withdraw consent and there is no other lawful basis for processing
  • You object to processing and there are no overriding legitimate grounds
  • The personal data has been processed unlawfully
  • The personal data must be erased to comply with legal obligation

4.2 Limitations on Erasure

We may not be able to erase your data if:

  • We need to retain it for legal obligations
  • We need it for the establishment, exercise, or defense of legal claims
  • We need it for public interest purposes
  • We need it for archiving purposes in the public interest

4.3 How to Request Erasure

To request erasure:

  • Submit a written request to privacy@easycitysystems.com.ng
  • Specify the data to be erased
  • Provide the reason for your request
  • We will respond within 30 days of receipt

5. Right to Restrict Processing

5.1 When You Can Request Restriction

You may request restriction of processing if:

  • You contest the accuracy of the personal data
  • Processing is unlawful but you oppose erasure
  • We no longer need the data but you need it for legal claims
  • You have objected to processing pending verification

5.2 Effect of Restriction

When processing is restricted:

  • We will store the data but not process it
  • We may process it with your consent
  • We may process it for legal claims
  • We may process it for protection of others' rights

6. Right to Data Portability

6.1 What You Can Port

You have the right to receive:

  • Your personal data in a structured, commonly used format
  • Your personal data transferred directly to another controller where technically feasible

6.2 When This Right Applies

This right applies when:

  • Processing is based on consent or contract
  • Processing is carried out by automated means

6.3 How to Request Portability

To request data portability:

  • Submit a written request to privacy@easycitysystems.com.ng
  • Specify the format you prefer
  • Specify the destination if requesting direct transfer
  • We will respond within 30 days of receipt

7. Right to Object

7.1 When You Can Object

You may object to processing based on:

  • Legitimate interests
  • Direct marketing
  • Processing for scientific or historical research

7.2 Effect of Objection

When you object:

  • We will stop processing unless we have compelling legitimate grounds
  • We will stop processing for direct marketing
  • We will inform you of your right to object before processing

8. Right to Withdraw Consent

8.1 Withdrawing Consent

You may withdraw consent at any time:

  • Through your account settings
  • By contacting privacy@easycitysystems.com.ng
  • By using opt-out mechanisms in our communications

8.2 Effect of Withdrawal

When you withdraw consent:

  • We will stop processing based on that consent
  • This does not affect lawfulness of processing before withdrawal
  • We may still process based on other lawful grounds

9. Right to Information

9.1 Right to be Informed

You have the right to be informed about:

  • The purposes of processing
  • The legal basis for processing
  • The recipients of your personal data
  • Your rights regarding your personal data
  • The existence of automated decision-making

9.2 Privacy Notices

We provide this information through:

  • Our Privacy Policy
  • Cookie consent notices
  • Collection notices at point of collection
  • Service-specific notices

10. Right to Lodge a Complaint

10.1 Supervisory Authorities

You have the right to lodge a complaint with:

  • The data protection authority in your country of residence
  • The data protection authority in our country of establishment
  • Any data protection authority where you believe your rights have been violated

10.2 Contact Information

Relevant supervisory authorities include:

  • Nigeria: Nigeria Data Protection Bureau (NDPB)
  • European Union: Your national data protection authority
  • South Africa: Information Regulator
  • Kenya: Office of the Data Protection Commissioner
  • Ghana: Data Protection Commission

11. Automated Decision-Making

11.1 Automated Processing

We may use automated processing for:

  • Fraud detection and prevention
  • Service personalization
  • Energy usage analysis

11.2 Your Rights

You have the right to:

  • Not be subject to decisions based solely on automated processing
  • Express your point of view
  • Obtain human intervention
  • Challenge the decision

12. How to Exercise Your Rights

12.1 Request Process

To exercise your rights:

  • Submit a written request to privacy@easycitysystems.com.ng
  • Provide sufficient information to identify yourself
  • Specify the right you wish to exercise
  • Provide any additional information relevant to your request

12.2 Response Time

We will respond to your request:

  • Within 30 days of receipt
  • May extend by an additional 60 days for complex requests
  • Will notify you of any extensions

12.3 Verification

We may request additional information to:

  • Verify your identity
  • Confirm your authority to make the request
  • Process your request accurately

13. Third-Party Rights

13.1 Requests on Behalf of Others

You may request data on behalf of another person if:

  • You have written authorization from that person
  • You are the legal guardian of a minor
  • You have power of attorney
  • You are an authorized representative

13.2 Deceased Persons

Requests regarding deceased persons:

  • May be made by authorized representatives
  • May be made by family members in certain circumstances
  • Are subject to applicable laws

14. Updates to This Document

14.1 Right to Modify

We reserve the right to modify this document to reflect changes in data protection laws or our practices. Changes will be effective immediately upon posting to the Platform.

14.2 Notification

We will notify you of material changes by:

  • Updating the "Effective Date"
  • Posting a notice on the Platform
  • Emailing you if you have an account

15. Contact Information

15.1 Data Rights Inquiries

For data rights inquiries, contact us at:

  • Email: privacy@easycitysystems.com.ng
  • Phone: [To be provided]
  • Address: EasyCity Systems Ltd., [Full Address to be provided]

16. Related Policies

This document should be read together with our:

17. Acknowledgment

By using Zolar, you acknowledge that you have read, understood, and agreed to this User Data Rights document. You acknowledge that you have comprehensive rights over your personal data as described in this document.