Privacy Policy.

1. Who we are

Waka Smart is operated by SpaceBeacon Nigeria Ltd. ("SpaceBeacon", "we", "us" or "our") and is powered by MTN Nigeria. For the personal data described in this policy, SpaceBeacon Nigeria Ltd. is the data controller. That means we decide how and why your data is used, and we are responsible for protecting it.

This policy explains how we handle personal data when you use the Waka Smart apps, the Waka AI assistant and wakasmartai.com (the "Service"). It follows:

• the Nigeria Data Protection Act 2023 ("NDPA");
• the Nigeria Data Protection Commission's General Application and Implementation Directive 2025 ("GAID");
• the consumer information protection requirements of the Nigerian Communications Commission (Consumer Code of Practice) Regulations 2024.

Read it together with our Terms of Use.

2. What we collect

We do not ask for sensitive personal data, such as health, religion, ethnicity or biometric data. We also do not use your voice to identify you. Motion sensors are used on your device only, to steady the map heading. That data is not sent to us.

3. How we use your data

• To provide the Service: showing your day at a glance, syncing calendars, planning routes, giving turn-by-turn directions and finding places near you.
• To send alerts you rely on: "leave now" times, reminders, and traffic and weather warnings, by push notification.
• To run the Waka AI assistant: understanding your requests and acting on them.
• To run business features: publishing listings and offers, and managing appointments.
• To manage your account and subscription: checking purchases, and handling cancellations and refunds.
• To support you: answering questions, handling complaints and fixing problems.
• To keep the Service safe and working: preventing fraud and misuse, fixing errors and improving performance.
• To meet our legal duties: complying with Nigerian law and with lawful requests from regulators and authorities.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you.

4. Our lawful bases

Under section 25 of the NDPA, we only process personal data where we have a lawful basis:

• Contract: to provide the Service you signed up for, including your account, schedule, navigation, alerts and subscriptions.
• Consent: for location, microphone and voice processing, calendar access, camera and photos, and marketing. You can withdraw consent at any time. Doing so does not affect processing that already took place.
• Legitimate interests: to keep the Service secure, prevent fraud, and understand how features are used so we can improve them. Where we rely on this, we have weighed our interests against your rights.
• Legal obligation: where Nigerian law requires us to keep or disclose information.

5. Voice and the Waka AI assistant

The first time you use the voice assistant, the app asks for your consent before any audio leaves your device. You can withdraw it later in Settings.

When you speak to Waka, your audio is streamed securely to our voice service. It uses the Microsoft Azure OpenAI Service to understand your request and reply. Under Microsoft's terms, your requests are not used to train Microsoft's or OpenAI's models.

We do not store recordings of your voice. We keep only the result of your request, such as an event you asked Waka to create. The AI can make mistakes, so check important details before you rely on them.

6. Location

Waka Smart uses your precise location to calculate travel times, give directions and tell you when to leave. If you allow background location, the app can keep navigation running and keep departure alerts accurate while it is not on screen.

You can change location access to "while using", or turn it off, in your device settings at any time. Navigation and departure alerts will stop working without it. We don't sell your location or share it with advertisers.

7. Who we share your data with

We share personal data only where needed, and only under a written agreement that requires the recipient to protect it:

• Hosting and AI: Microsoft Azure hosts our servers, databases and push notifications, and the Azure OpenAI Service powers the Waka AI assistant.
• Maps, traffic and weather: providers that turn a location into routes, traffic and weather information for you.
• Sign-in and calendars: Google and Microsoft, when you choose to sign in with them or connect their calendars.
• App stores: Google Play and the Apple App Store, which process subscription payments. Google's Firebase Cloud Messaging delivers notifications to Android devices.
• MTN Nigeria: as our partner, only where needed to provide or support the Service, and never for its own marketing without your consent.
• Businesses you choose to deal with: for example, your name and appointment time when you book with a business through Waka Smart.
• Authorities: regulators, law enforcement or courts, where Nigerian law requires it.
• A new owner: if our business is reorganised or sold, subject to this policy.

We do not sell personal data, and we do not share it for third-party advertising.

8. Transfers outside Nigeria

Our servers are hosted by Microsoft Azure in data centres in Canada and the United States, so your data is transferred outside Nigeria. Some of our service providers may also process data in other countries.

We make these transfers only as permitted under Part VIII of the NDPA and the GAID. We rely on contractual safeguards, such as data processing agreements and standard contractual clauses, which require the recipient to protect your data to a standard at least equal to the NDPA. Where needed, we also rely on the transfer being necessary to provide the Service you asked for. You can ask us for more information about these safeguards.

9. How long we keep your data

10. Security and data breaches

We protect your data with encryption in transit (HTTPS/TLS) and at rest, access controls, strong authentication, and monitoring. Only people who need access to your data to do their job can see it.

If a personal data breach is likely to put your rights and freedoms at risk, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of it. If the risk to you is high, we will also tell you without undue delay. We'll explain what happened and what you can do.

11. Your rights

Under the NDPA, you have the right to:

• be informed about how we use your data, as this policy does;
• access your data and get a copy of it;
• correct data that is wrong or incomplete;
• delete your data where we no longer have a reason to keep it;
• restrict how we use your data in certain cases;
• object to processing based on legitimate interests, and to direct marketing at any time;
• data portability, which means receiving your data in a common, machine-readable format or having it sent to another provider;
• withdraw consent at any time, in the app or device settings or by contacting us;
• not be subject to decisions based solely on automated processing that significantly affect you;
• complain to the Nigeria Data Protection Commission.

To use any of these rights, email support@spacebeacon.com or use Settings → Help center in the app. This includes asking us to close your account and delete your data. It is free. We may ask you to confirm your identity first. We'll acknowledge your request within 96 hours and respond fully within 30 days. If a request is complex, we will tell you if we need longer, and why.

12. Children

Waka Smart is intended for people aged 18 and over. Under section 31 of the NDPA, we only process personal data of a child under 18 with the consent of a parent or legal guardian. If you believe a child has given us personal data without that consent, contact us and we will delete it.

13. Marketing

We send marketing messages only if you have agreed to receive them. Every message includes a free way to opt out, and you can also change your choice in the app. You can manage promotional SMS on your line through your network's Do-Not-Disturb service by dialling 2442. Service messages, such as departure alerts and account notices, are part of the Service and are not marketing.

14. This website

wakasmartai.com does not use advertising or tracking cookies, and has no sign-up form. Our hosting provider, Microsoft Azure, keeps standard server logs, such as IP address and pages requested, to deliver and secure the site. The site loads fonts from Google Fonts, which receives your IP address when you visit.

15. Changes to this policy

We will update this policy if our practices or the law change. If a change is significant, we will tell you in the app or by email at least 30 days before it takes effect. Where the law requires it, we will ask for your consent again. The "Effective" date at the top always shows the current version.

16. Contact and complaints

If you have questions or concerns about your data, contact our Data Protection Officer:

• Company: SpaceBeacon Nigeria Ltd., powered by MTN Nigeria
• Email: support@spacebeacon.com (subject: "Data protection")
• Phone: 0706 963 6098
• In the app: Settings → Help center

If you're not satisfied with our response, you have the right to complain to the Nigeria Data Protection Commission at ndpc.gov.ng. For complaints about telecommunications services, you can contact the Nigerian Communications Commission on its free line 622 or at consumer.ncc.gov.ng.