This Privacy Policy describes how Dumbledore Tech Limited (“we”, “us”, or “our”) collects, uses, shares, and protects personal information in connection with our products and services, including but not limited to:

• Dumebi – our personal finance AI chatbot available via WhatsApp and other channels.
• SupportBuddy AI – our AI-powered customer support and automation platform for businesses.

By accessing or using any of our products, you agree to the terms of this Privacy Policy. If you do not agree, you must not use our services.

1. SCOPE OF THIS POLICY

This Policy applies to all users of Dumbledore Tech products worldwide. It governs all data collected through:

• Our websites, applications, and mobile/web platforms.
• Messaging platforms such as WhatsApp, Instagram, Messenger, Telegram (for SupportBuddy AI), and others.
• API integrations and third-party platforms connected to our services.

2. INFORMATION WE COLLECT

We may collect the following categories of information depending on the product and services you use:

2.1 Personal Identification Information

• Full name, phone number, email address, date of birth.
• For Dumebi: Bank Verification Number (BVN), government-issued identification, proof of address.
• For SupportBuddy AI business clients: Company name, registration number, business address.

2.2 Financial & Transaction Data

• Linked bank account or payment method details.
• Transaction history, amounts, recipients (Dumebi).
• Payment records for subscription plans (SupportBuddy AI).

2.3 Business & Customer Data (SupportBuddy AI)

• End-customer names, contact details, and conversation logs processed through the platform.
• Business-specific API data, including customer orders, product inventory, booking schedules, or survey responses.

2.4 Technical & Device Data

• Device type, operating system, browser type, IP address.
• Messaging platform account metadata.
• API usage logs.

2.5 Usage & Interaction Data

• Conversations with AI bots.
• Preferences, settings, and feedback.
• Support requests and helpdesk tickets.

2.6 Third-party Data

• Information provided by banks, payment processors, and integration partners for identity verification, fraud prevention, or service delivery.

3. HOW WE COLLECT INFORMATION

We collect data:

• Directly from you during registration, subscription, or service use.
• Automatically from your device, browser, or integrated platforms.
• From third parties including financial institutions, integration partners, and service providers.

4. HOW WE USE YOUR INFORMATION

We process your information to:

1. Deliver and improve our products and services.
2. Process transactions, payments, and billing.
3. Customize AI interactions and recommendations.
4. Enable integrations with third-party services (e.g., payment gateways, CRM tools).
5. Detect and prevent fraud, money laundering, and unauthorized transactions.
6. Comply with legal, regulatory, and contractual obligations.
7. Provide customer support and respond to inquiries.
8. Conduct analytics and service improvement.

5. AI DATA PROCESSING

• Our AI models process your text, voice, or media inputs to generate responses and recommendations.
• Conversations may be stored temporarily for service delivery, debugging, and improvement.
• For SupportBuddy AI: Business clients are responsible for obtaining consent from their customers before sharing data with the platform.
• For Dumebi: Personal financial data is handled in line with CBN customer data standards.
• We do not sell chat transcripts to third parties.

6. SHARING OF INFORMATION

We may share data:

• With financial institutions (for Dumebi transactions).
• With integration partners (for SupportBuddy AI functions like booking, CRM, order management).
• With regulators such as CBN, NDIC, or NDPR authorities where applicable.
• With service providers for hosting, analytics, fraud detection, and verification.
• When required by law or in response to lawful requests.
• In business transfers such as mergers or acquisitions.

7. COOKIES & TRACKING

• Our websites and web dashboards may use cookies to enhance user experience.
• You can disable cookies via browser settings, but some features may not function properly.

8. DATA STORAGE & SECURITY

• Data is stored on secure servers with encryption at rest and in transit.
• Access is limited to authorized personnel bound by confidentiality obligations.
• While we take all reasonable measures, no system is 100% secure.

9. DATA RETENTION

• Dumebi: Personal and transaction data retained for at least 5 years to comply with CBN regulations.
• SupportBuddy AI: End-customer conversation data retained as per the business client's account settings or legal requirements.
• Other data is retained only as long as necessary for the purposes outlined in this Policy.

10. USER RIGHTS (NDPR & APPLICABLE LAWS)

You have the right to:

• Access your personal data.
• Request correction of inaccurate data.
• Request deletion (subject to legal requirements).
• Object to certain processing.
• Withdraw consent at any time.
• Request data portability.

Requests should be submitted via the contact details in Section 14.

11. CHILDREN'S PRIVACY

We do not knowingly collect data from individuals under 16 without parental or guardian consent.

12. INTERNATIONAL DATA TRANSFERS

If your data is transferred outside Nigeria, we ensure adequate protection measures in compliance with NDPR.

13. DATA BREACH NOTIFICATION

If a breach occurs that may cause significant harm, we will notify affected users and relevant authorities in accordance with NDPR requirements.

14. CONTACT INFORMATION

For privacy-related questions or requests:

Dumbledore Tech Limited
Email: kunle@dumbledoretech.com Phone: +234 706 647 5316 Address: House 6, 442 Crescent Citec Villa, 4th Avenue Gwarinpa, Abuja, Nigeria