Privacy notice
[Draft for counsel] This text is a draft. It is not legal text until counsel has approved it. Effective date: [to come].
1. Who we are
Legatee (legateetrust.com) connects people with notaries public in Nigeria for remote notarization. Legatee is the data controller for the personal data described in this notice, under the Nigeria Data Protection Act 2023.
Data protection officer: [Name and address: to come]
2. What we collect
- Your name, phone number and, if you give one, your email.
- Your location at the time of a session: a country and, in Nigeria, a State.
- The documents you upload, and the sealed documents that result.
- Identity check data: the result, scores, the type of ID, your NIN or ID number (encrypted), the name on your ID, the ID images and selfie, and, for a NIN, the photo on your NIN record.
- The recording of each session, with the signatures made in it.
- Payments, refunds and receipts.
- Messages with your notary.
- Security logs: sign-ins, codes and the audit log of what happened to your case.
- If you are a notary: your application and its documents, your payout account’s bank, name and last four digits, and your signing certificate.
3. Why, and on what basis
| Purpose | Lawful basis |
|---|---|
| Your account, bookings, payments and sessions | Contract |
| Recordings, act records and filings with the Chief Registrar | Legal obligation (Notaries Public Act 2023) |
| Face matching in an identity check | Your explicit consent (NDPA section 30) |
| Fraud prevention and security logs | Legitimate interest |
4. Identity checks and biometrics
Before you first book, and again once your last check is a year old, Smile ID, our identity partner, compares a live selfie with your NIN record and your photo ID, or with your passport. We ask for your explicit consent first, and you can withdraw it in the app at any time. Withdrawing it ends any check in progress and stops new ones; a finished check is kept as section 8 says.
5. Recordings
Every session is recorded, as the Notaries Public Act 2023 requires. The recording shows every participant and the document pages discussed. It is kept in write-once storage and filed with the Chief Registrar of the Supreme Court.
6. Who we share it with
Our processors, each under a written agreement: AWS (hosting and storage), LiveKit (video and recording), Smile ID (identity checks), Paystack (payments and payouts), Termii (text messages), our email provider, Expo (app notifications) and Sentry (error tracking, with personal data removed).
Your notary sees your name and document when reviewing your case, and your location and identity check, with its images, in the session. The Chief Registrar receives every sealed document and recording, with a record of the session: who took part, how each was identified (never the images), and when.
7. Transfers outside Nigeria
Legatee’s data is stored by AWS in Cape Town, South Africa, and some processors handle it in other countries. A transfer register records the legal basis for each.
8. How long we keep it
| Data | Kept for |
|---|---|
| Sealed documents, recordings, filings and act records | 7 years after the act |
| Working uploads and previews | 30 days after the case closes |
| ID images and selfies | 1 year after the check |
| Identity check results, without images | 7 years after the last linked act; otherwise 1 year after the account closes |
| Payments, refunds and payouts | 6 years |
| Messages | 7 years if the case produced an act; otherwise 1 year |
| Audit log | 7 years |
| Sign-in sessions | 30 days after they end |
| One-time codes | A day |
| Accounts with no acts | Deleted 1 year after closure |
9. Your rights
You can export your data and files from the app, and ask for your account to be deleted. Deletion respects the legal holds on acts and filings, and the app tells you what is kept and why. You can withdraw your consent to an identity check at any time.
10. Security
Data is encrypted in transit and at rest. NINs, ID numbers and phone numbers are encrypted field by field. Staff access is limited by role. Every change, and every staff read of a document, ID image or recording, is logged. We report a breach to the Nigeria Data Protection Commission within 72 hours, as the Act requires (section 40).
11. Changes
We will post changes to this notice here, with the date they take effect.