Privacy Policy

Last updated: January 3, 2026

Smart Path & Associate ("we," "our," or "us") operates the ProcureChain application (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. This Privacy Policy is compliant with the Nigeria Data Protection Regulation (NDPR) 2019.

1. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). This includes, but is not limited to:

• Email address
• Full Name
• Company Name and Business Registration Information (for vendors)
• Tax Identification Number (for vendors)
• Contact Information (Phone number, address)
• Financial information for procurement and payment processing

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

2. Lawful Basis for Processing

We process your Personal Data based on the following lawful grounds as provided under the NDPR:

• Consent: You have given clear consent for us to process your personal data for a specific purpose.
• Contract: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
• Legal Obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
• Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

3. Use of Data

Smart Path & Associate uses the collected data for various purposes:

• To provide and maintain our Service
• To manage your account and your relationship with us, including onboarding and compliance checks
• To facilitate procurement processes, including tenders, RFQs, contract management, and payments
• To notify you about changes to our Service
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service and prevent fraud
• To comply with legal and regulatory obligations

4. Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

5. Data Transfer and Storage

Your information, including Personal Data, is stored and processed on secure cloud servers. As a company operating in Nigeria, we are committed to ensuring that all Personal Data is stored in compliance with the NDPR, which may include storage within Nigeria or in another jurisdiction that ensures an adequate level of protection for the rights and freedoms of data subjects.

6. Your Data Protection Rights Under NDPR

You have the following data protection rights:

• The right to access, update or to delete the information we have on you.
• The right of rectification.
• The right to object to our processing of your Personal Data.
• The right of restriction.
• The right to data portability.
• The right to withdraw consent at any time.

If you wish to exercise any of these rights, please contact our Data Protection Officer.

7. Security of Data

The security of your data is important to us. We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

8. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

9. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer at: