Privacy Notice

Overview

At Makesales, operated by Papstra Services Limited ("Makesales," "we," "us," or "our"), we are committed to protecting your privacy and handling personal data responsibly This Privacy Notice explains how we collect, use, disclose and safeguard personal data when you interact with our platform, including our website (https://usemakesales.com), mobile application and services (collectively, the "Services") Our Services are a business operations management system designed to help entrepreneurs, merchants and businesses sell online, manage customers, track inventory and process payments.

This Privacy Notice applies to:

• Merchants: Individuals or businesses who register an account to use Makesales for selling products or services (e.g., via Social Commerce like WhatsApp, Instagram, Tik Tok, Website Builder, Invoicing, Payments, Inventory Management, or Analytics).
• Customers: Individuals who purchase from Merchants using Makesales tools (e.g., through a Merchant's online store, payment links, or invoices).

We process personal data in compliance with theNigeria Data Protection Act, 2023 (NDPA) and other applicable laws If you are a Merchant, you are responsible for ensuring your own compliance with data protection laws when handling Customer data collected through our Services Makesales acts as a data processor for Merchant-collected Customer data and as a data controller for data related to our direct interactions with you.

By using our Services, you consent to the practices described in this Privacy Notice If you do not agree, please do not use the Services.

Definitions

The following terms, when used in this Privacy Notice, have the meanings described below. Words in singular include the plural and vice versa.

• "CBN (Central Bank of Nigeria)" means the regulatory authority in Nigeria responsible for overseeing financial institutions, payment systems and monetary policies, including regulations that Makesales and its payment partners, "Monieswitch" and "Juju Payments", must comply with for payment processing and anti-money laundering measures.
• "Customer" refers to an individual who interacts with or purchases products or services from a Merchant using Makesales’ tools, such as through a Merchant’s online store, Social Commerce catalog, payment links, or invoices.
• "Effective Date" is the date on which this Privacy Notice, or any updated version, takes effect, as indicated at the top of this document (October 27, 2025, for the current version) Updates to this Notice will be posted on https://usemakesales.com with a new Effective Date.
• "KYC/AML (Know-Your-Customer/Anti-Money-Laundering)" means the processes and checks required by law to verify the identity of merchants and prevent illegal activities such as money laundering or fraud Makesales and its payment partners, Monieswitch and Juju Payments, conduct KYC/AML checks to ensure compliance with Central Bank of Nigeria regulations and other applicable law.
• "Merchant" refers to an individual or business that registers an account on the Makesales platform to sell products or services, utilizing tools such as Social Commerce, Website Builder, Invoicing, Payments, Inventory Management, or Analytics.
• "Services" means the Makesales platform, including the website (https://usemakesales.com), mobile application and related tools and features provided by Papstra Services Limited, such as Social Commerce, Website Builder, Invoicing, Payments (processed via Monieswitch and Juju Payments), Smart Inventory Management and Analytics, designed to help Merchants manage and grow their businesses.
• "Standard Contractual Clauses" means the legally binding agreements approved by relevant data protection authorities (e.g., under the EU’s General Data Protection Regulation) used by Makesales to ensure adequate safeguards for the transfer of personal data to countries outside Nigeria, where such transfers are necessary for Service delivery (e.g., to cloud providers in the US or EU).
• "User" refers to any individual or entity interacting with the Makesales platform, including Merchants, Customers and visitors browsing the website or mobile application without a registered account.

1. Information We Collect

We collect personal data necessary to provide our Services. The data we collect vary depending on your status (Merchant or Customer) and how you interact with Makesales.

1.1. For Merchants

• Account and Business Information: Full legal name, email address, phone number, government-issued ID, proof of address, business name, business certificate of incorporation, bank account details (for settlements) and tax identification number.
• Content and Business Data: Product listings, images, videos, logos, descriptions, inventory details and analytics inputs you upload or generate.
• Communications: Inquiries, support tickets, or feedback submitted via email, chat, or phone.

1.2. For Customers

• Transaction Information: Name, email address, phone number, delivery/billing address and order details provided during purchases from a Merchant's store, Social Commerce catalog, or invoice.
• Payment-Related Data: Limited details like payment confirmation status (full card or bank details are handled by our partner, Monieswitch and Juju Payments and not stored by Makesales).

1.3. All Users (Merchants and Customers).

• Usage and Technical Data: IP address, browser type, device information, operating system, pages visited, time spent on the Services and interaction logs (e.g., clicks, searches).
• Automatically Collected via Cookies/Tracking: Session data, preferences and analytics metrics to improve user experience

We do not collect sensitive personal data (e.g., health or biometric information) unless you voluntarily provide it in communications, in which case we handle it with extra care under NDPR guidelines

2. How We Use Your Information

We use personal data to deliver, improve and secure our Services, with specific applications for Merchants and Customers.

2.1. For Merchants

• Provide and manage your Account, including KYC/AML verification and access to tools like Website Builder, Invoicing and Analytics.
• Process payments and settlements via Monieswitch and Juju Payments.
• Generate business insights (e.g., sales trends, inventory alerts).
• Communicate updates, support responses, or promotional content (with consent).

2.2. For Customers

• Facilitate Transactions, such as confirming orders, sending payment links, or delivering invoices from Merchant.
• Enable Merchant-Customer interactions (e.g., order updates via Social Commerce).
• Resolve disputes or process refunds (coordinated with Merchants).

2.3. For All Users

• Enhance platform functionality and security (e.g., fraud detection, system monitoring).
• Analyze usage to improve Services.
• Comply with legal obligations (e.g., CBN regulations, tax reporting)

Legal bases under NDPA include contractual necessity (for Service delivery), consent (for marketing), legal obligations (for compliance) and legitimate interests (for security and analytics).

3. How We Share Your Information

We share personal data only as necessary and with parties bound by NDPA-compliant agreements. We do not sell your data.

• Service Providers: Monieswitch and Juju Payments (payments and settlements), third-party verification tools (KYC/AML), cloud hosts (data storage) and analytics partners.
• Third-Party Platforms: Meta (for Social Commerce; limited data like catalog shares).
• Merchants and Customers: As relevant, Merchants receive Customer transaction details for order fulfillment; Customers see Merchant contact info for support.
• Legal/Regulatory: Authorities (e.g., CBN, Nigerian Data Protection Commission) for compliance or investigation.
• Business Transfers: Successors in mergers/acquisitions, with notice where possible.

For Customers, Makesales shares data primarily with the relevant Merchant (as the data controller for purchase-related info) Merchants must obtain Customer consent for any further sharing.

4. Cookies and Tracking Technologies

We use cookies, web beacons and similar tools for

• Essential functions (e.g., login, session management).
• Analytics (e.g., usage patterns via integrated tools).
• Personalization (e.g., remembering preferences).

Merchants may encounter additional tracking in Analytics reports Customers see cookies on Merchant stores hosted by Makesales You can control cookies via browser setting Essential cookies cannot be disabled For details, contact us.

5. Data Security

We employ industry-standard measures, including

• Encryption (in transit and at rest).
• Access controls and firewalls.
• Regular audits and monitoring.

Merchants: Secure your Account with strong passwords and report breaches immediately Customers: Data security during Transactions is ensured via Monieswitch and Juju Payment's PCI-DSS compliance. No system is foolproof; we limit liability for breaches due to user negligence.

6. Data Retention

We securely delete or anonymize data when no longer needed. Specific retention periods are:

• Merchants: Account data retained while active for 90 days post-closure; Transaction records up to 7 years for legal compliance.
• Customers: Purchase data retained for the Merchant's business needs additional legal periods (e.g., 7 years for tax/audit).
• All Users: Anonymized usage data indefinitely for analytics; deleted upon request where possible.

7. Your Privacy Rights

Under NDPA, Merchants and Customers have rights including:

• Access: Obtain a copy of your data.
• Correction: Update inaccurate information.
• Deletion: Request erasure (subject to legal hold.)
• Objection/Restriction: Oppose or limit processing (e.g., marketing).
• Portability: Receive data in a usable format.
• Withdraw Consent: For consent-based processing.

Customers: Direct requests to the Merchant for purchase data; contact Makesales for platform-related data. Merchants: Exercise rights via your dashboard or support. Submit requests to support@usemakesales.com. We verify identity and respond within 30 days. Complaints can be escalated to the Nigerian Data Protection Commission.

8. International Data Transfers

Data may be transferred to servers outside Nigeria (e.g., cloud providers in the US or EU) using NDPR-approved safeguards like data processing agreements. For EU/UK users (if applicable), we use Standard Contractual Clauses.

9. Children's Privacy

Our Services are not directed at children under 18. We do not knowingly collect data from minors. If we discover such data, we delete it promptly. Merchants must ensure compliance when selling to minors.

10. Changes to This Privacy Notice

We may update this Notice to reflect Service changes or legal updates. Changes are posted on https://usemakesales.com with the new Effective Date. Material updates will be notified via email or dashboard. Continued use constitutes acceptance.

11. Contact Us

For privacy questions or rights exercises:

We respond promptly, prioritizing NDPA timelines. For Monieswitch and Juju Payments-related data, refer to their privacy policy.