Privacy Policy

1. Who We Are

SmartBallot is a digital election management platform designed to enable transparent, secure, and efficient online voting. Our services are used by student bodies, civic organizations, and electoral groups across various countries.

Our operations and data processing activities are governed by:

• Nigerian Data Protection Regulation (NDPR)
• Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)
• United States Federal and State Privacy Laws (e.g., CCPA, COPPA)
• United Kingdom General Data Protection Regulation (UK GDPR)
• European Union GDPR (where applicable)

Other relevant international laws

2. Information We Collect

We collect the following types of information:

1. Personal Information
   • Full name
   • Phone number
   • Email address
   • Institutional ID (e.g., student ID, voter ID)
   • Gender or age (where required by law)
   • Photo or profile picture (if uploaded)

1. Usage Data
   • IP address
   • Device type
   • Browser type and version
   • App usage patterns
   • Voting history (non-identifiable and anonymized where appropriate)

1. Location Information
   • Only with your explicit consent
   • Used to verify location-based access or eligibility (e.g., for school-specific voting)

1. Content Information
   • Messages, comments, or posts shared within the app
   • Uploaded documents (e.g., campaign manifestos, candidate credentials)

3. How We Use Your Information

We use your data to:

• Verify and authenticate user identities
• Facilitate secure and transparent voting processes
• Prevent fraud, double voting, and impersonation
• Improve user experience and app performance
• Communicate updates, notices, or support

Comply with legal obligations and audit requirements

4. Legal Basis for Processing

We process your data based on:

• Consent – when you register, vote, or use app features
• Contractual necessity – to provide you the services you requested
• Legal obligations – such as audit logs or reporting
• Legitimate interests – such as improving app security and integrity

5. How We Share Your Information

We do not sell your personal information. We may share data with:

• Election administrators or school authorities (with consent)
• Service providers – e.g., cloud hosting, analytics, or messaging platforms (bound by confidentiality agreements)
• Legal or government authorities – when required by law or valid court order

Other users – only when you make your information public (e.g., as a candidate)

6. Cross-Border Data Transfers

If you are located outside Nigeria or Canada, your information may be transferred to, stored in, or processed in countries where SmartBallot or its service providers operate. We ensure appropriate safeguards are in place, such as:

• Data processing agreements (DPAs)
• Standard Contractual Clauses (SCCs)

Encryption and security protocols

7. Data Retention

We retain your information for as long as necessary:

• To fulfill the purposes outlined in this policy
• To comply with legal and audit requirements
• To resolve disputes or enforce agreements

You may request deletion of your personal data at any time by contacting us (see Section 13).

8. Your Rights

Depending on your location, you may have the following rights:

To exercise your rights, email us at privacy@smartballotapp.com

9. Children’s Privacy

SmartBallot is not intended for users under the age of 13 (or equivalent minimum age in your jurisdiction). If we learn that we have collected personal information from a child without proper consent, we will delete it promptly.

10. Data Security

We implement robust security measures:

• End-to-end encryption of votes and messages
• Secure socket layer (SSL) protocols
• Multi-factor authentication (where applicable)

Regular vulnerability scans and audits

11. Third-Party Links

Our platform may contain links to third-party sites. We are not responsible for the privacy practices or content of those websites.

12. Changes to This Privacy Policy

We may update this Privacy Policy occasionally to reflect legal, technical, or operational changes. If significant changes occur, we will notify users through the app or via email.

13. Contact Us

For privacy inquiries, complaints, or requests:

Email: privacy@smartballotapp.com

Address: Toronto, Canada.

14. Jurisdiction-Specific Disclosures

Nigeria (NDPR)

We comply with NDPR as regulated by the Nigeria Data Protection Bureau (NDPB).

Canada (PIPEDA)

Canadian users may file complaints with the Office of the Privacy Commissioner of Canada (OPC).

USA (CCPA, COPPA)

California residents may opt out of data sharing and request data deletion.

United Kingdom (UK GDPR)

UK users may contact the Information Commissioner’s Office (ICO) for unresolved complaints.