Effective Date: March 22, 2026
1. Overview
MyLegacy Memorial Services ("we", "us", or "our") operates https://mylegacy.com.ng (the "Website"). This Privacy Policy explains how we collect, use, disclose, and protect personal data in accordance with the Nigeria Data Protection Act (NDPA/NDPR) and, where applicable, the General Data Protection Regulation (GDPR).

2. Data Roles (Controller / Processor)
• Data Controller: MyLegacy Memorial Services acts as a Data Controller for user accounts, transactions, and platform operations.
• Data Processor: Where funeral homes or partners submit data on behalf of families, we may act as a Data Processor on their behalf.
• Partners (Funeral Homes/Agencies): Act as independent Data Controllers for client data they collect and submit.

3. Data We Collect
We may collect the following categories of personal data:
• Identity Data: Name, email address, phone number;
• Memorial Content: Biographical details, tributes, images, and videos;
• Technical Data: IP address, browser type, device information, usage logs;
• Transaction Data: Payment-related details (processed via third-party providers);
• Uploaded Media: May contain embedded metadata (e.g., location data).

4. Purpose of Processing
We process personal data to:
• Provide, operate, and maintain the Services;
• Create and host memorial pages;
• Manage user-generated content;
• Communicate with users and partners;
• Monitor performance and improve functionality;
• Detect and prevent fraud, abuse, or unauthorized activity;
• Comply with legal and regulatory obligations.

5. Legal Basis for Processing
We rely on one or more of the following lawful bases:
• Consent;
• Performance of a contract;
• Compliance with legal obligations;
• Legitimate interests (e.g., service improvement, security, fraud prevention).

6. User-Generated Content and Responsibility
Content submitted to the platform is provided by users, families, or partners. You are responsible for ensuring that you have obtained all necessary consents (including next-of-kin authorization where applicable).
We do not independently verify the accuracy of submitted content.

7. Cookies and Tracking Technologies

We use cookies and similar technologies for essential functionality and analytics:
• Comment cookies (up to 1 year);
• Login/session cookies (2 days or up to 2 weeks if “Remember Me” is selected);
• Temporary cookies (browser compatibility);
• Editing cookies (expire after 1 day).
You may disable cookies via your browser settings, though some features may not function properly.

8. Embedded and Third-Party Content
Pages may include embedded content (e.g., videos, images). Third-party providers may collect data, use cookies, and track your interaction. We do not control these third parties.

9. Data Sharing and Disclosure
We do not sell personal data. We may share data with:
• Service providers (hosting, payments, analytics);
• Funeral home partners (where they are involved in service delivery);
• Legal or regulatory authorities where required by law;
• Affiliates or contractors supporting our Services.
All third parties are required to process data securely and lawfully.

10. International Data Transfers
Where personal data is transferred outside Nigeria, we ensure appropriate safeguards are in place in accordance with NDPA/NDPR and GDPR standards.

11. Data Retention
We retain personal data only as long as necessary for:
• Service delivery;
• Legal compliance;
• Dispute resolution.
Examples:
• Memorial content: retained for the duration of hosting plans;
• Account data: retained while active;
• Comments and metadata: may be retained indefinitely.

12. Data Security
We implement reasonable technical and organizational safeguards to protect personal data. However, no internet-based system is completely secure.

13. Your Rights
Subject to applicable law, you have the right to:
• Access your personal data;
• Correct inaccurate data;
• Request deletion (where applicable);
• Object to or restrict processing;
• Withdraw consent at any time;
• Request data portability.
Requests may be sent to: info@mylegacy.com.ng

14. Children’s Privacy
Our Services are not intended for individuals under 18. We do not knowingly collect data from minors.

15. Relationship with Terms of Service
This Privacy Policy should be read alongside our Terms of Service. In case of conflict regarding data handling, this Privacy Policy shall prevail.

16. Updates to this Policy
We may update this Privacy Policy periodically. The latest version will always be available on this page with the updated effective date.

17. Contact Information
MyLegacy Memorial Services
Website: https://mylegacy.com.ng
Email: info@mylegacy.com.ng
Phone: 09063235701