1. Who we are #
OPSIS is a digital advertising network for Nigeria. Businesses register the TVs they already own as advertising screens, advertisers buy those screens by state, city and local government area, and every play is verified before anybody is charged or paid.
OPSIS is operated by Limitlex Technologies Limited, a company registered in Nigeria (RC number [RC NUMBER]) with its registered address at [REGISTERED ADDRESS]. For the purposes of the Nigeria Data Protection Act 2023 (the NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR), Limitlex Technologies Limited is the data controller for the personal data described here.
This policy covers the OPSIS Owner app, the OPSIS Advertiser app, the advertiser web portal, the screen player that runs on registered TVs, and this website. It is written in plain language on purpose. If anything is unclear, write to us and we will explain it.
2. What we collect #
We collect only what the network needs to run. What that is depends on which side of it you are on.
If you are a location owner
- Your name, phone number and email address — to create your account, sign you in and reach you about your screens and your earnings.
- Your business name and, if you register as a business, your CAC registration number — so the network knows who owns which screens.
- Your bank account details (bank, account number and account name) — so we can pay you. We do not collect card details from owners.
- The address of each location you register, including the state, city and local government area — because that is how advertisers find and buy your screens.
- Details of each screen — a name, its position in the venue, its size and orientation, and the hours it is on.
- Device identifiers from the TVs you pair — a device ID the player generates, the player version, the make and model where the TV reports it, network type, storage and uptime. This is what lets us tell one screen from another and know whether it is online.
- Your identity verification result — verified, not verified, or needs review, together with a plain-language reason. See section 3 for what we deliberately do not receive.
- Payout records — every withdrawal you request, its amount, its reference and its status.
If you are an advertiser
- Your company or agency name and CAC registration (RC) number — an advertiser has to be a real business before anything it makes goes on a public screen.
- The name, phone number and work email of your contact person — to create the account, sign in and send receipts and campaign reports.
- Payment references — the reference, amount, date and status of every wallet top-up, and the last four digits and card type where a card was used. Card numbers themselves are handled entirely by Paystack and never reach us.
- Your campaigns and adverts — the files you upload, the screens and schedule you choose, the budget you set, and the record of every verified play you are charged for.
From screens
The player on a registered TV is a small web application. It reports only what is needed to prove an advert played and to keep the screen healthy:
- Play records — which advert, on which screen, when it started, whether it completed, and a proof ID generated on the device. Every one of these is checked before anybody is charged or paid.
- Heartbeats — a periodic “still here” with the player version, free storage, network type and, where the TV reports it, temperature and uptime.
Screens have no eyes and no ears. The player does not use a camera or a microphone, does not count or recognise faces, does not track phones in the room and does not capture anything about the people in front of the TV. We measure that an advert played, not who watched it.
From everybody
- Sign-in details — a password (stored only as a one-way hash) and, if you turn it on, a six-digit quick sign-in PIN that works only on a phone that has already signed in with your password.
- Push notification tokens, if you allow notifications, so we can tell you a screen went offline or a payout arrived.
- Basic technical data when you use the apps or this site — IP address, app version, device type and timestamps — in server logs, kept for security and to fix problems.
- Messages you send us — support requests, disputes and their attachments.
3. What we never store #
Some data is more dangerous to hold than it is useful. We have designed the network so that it never reaches us.
- Your BVN. Never stored, anywhere, in any form.
- Your NIN. Never stored, anywhere, in any form.
- Your ID documents, selfie and liveness video from identity verification.
Identity verification happens on a page hosted by our verification partner, Ninja. You type your identity number and take your selfie there, on their systems. Ninja checks the national registers and returns to us only the verdict — verified, not verified, or could not decide — with a short reason such as “the name on the account does not match the register”. The number you typed, the registry record and the images stay with Ninja and are handled under their own privacy terms. There is nothing OPSIS could do with a stored BVN except lose it, so we do not accept one.
If automated verification is ever unavailable and you choose to complete a manual review instead, you may be asked to upload a copy of an ID document, a selfie holding it, a proof of address or a CAC certificate. Those files are stored in a private area with no public address, are readable only by you and by the OPSIS reviewer handling your case, are replaced rather than accumulated (one file of each kind, the old one deleted when a new one is uploaded), and are deleted when your account is closed. We never ask for a BVN or NIN in this route either.
We also do not store full card numbers (Paystack does), do not store the raw response from any identity register, and do not use advertising trackers or sell data to anybody.
4. Why we use it #
Under the NDPA we may only process your personal data where we have a lawful basis. These are ours.
| What we do | What we use | Lawful basis |
|---|---|---|
| Run the marketplace: create your account, list screens, let advertisers find and buy them, play adverts, verify plays | Account details, location addresses, screen and device details, play records, heartbeats | Performance of our contract with you (the Terms of Service) |
| Pay owners: calculate earnings, settle them and send bank transfers | Play records, bank account details, payout records | Performance of our contract with you |
| Bill advertisers: charge the wallet for verified plays, issue receipts and reports | Play records, payment references, campaign details, contact email | Performance of our contract with you |
| Prevent fraud: confirm an owner is who they say they are before paying them, confirm an advertiser is a real business, detect a screen that reports plays it did not show, deduplicate play records | Identity verification result, RC number, device identifiers, proof IDs, technical logs | Our legitimate interest in running an honest network, and legal obligation where anti-money-laundering rules apply |
| Keep you informed: login codes, payout and screen alerts, receipts | Phone number, email, push token | Performance of our contract with you |
| Meet our legal duties: tax records, responding to a lawful request from a court or regulator, keeping records of adverts that aired | Financial records, campaign and play records, account details | Legal obligation |
| Keep the service secure and fix it when it breaks | Technical logs, device identifiers | Our legitimate interest in a service that works and is not abused |
We do not use your data to build a profile of you for advertising, and we do not make decisions about you by automated means that have a legal or similarly significant effect, with one exception: identity verification is automated. If it says no, you are shown why and can ask a person at OPSIS to look again (see section 7).
5. Who sees it #
We share personal data only with the companies that do a specific job for the network, only the data that job needs, and under contracts that hold them to at least the standard in this policy.
| Who | What they do | What they receive |
|---|---|---|
| Ninja | Identity verification for owners and business verification for advertisers | Your name and the fact that a verification was requested. You provide your identity number, selfie and liveness check to Ninja directly on their page; we receive only the verdict. |
| Paystack | Wallet top-ups by card and bank transfer; bank transfers to owners for payouts | Advertisers: email and amount, and your card details go to Paystack directly. Owners: bank, account number, account name and the payout amount. |
| Termii | Sends the text messages the network needs: login and password-reset codes, and alerts | Your phone number and the text of the message. |
| Resend | Sends password-reset codes by email where a text message cannot be sent | Your email address and the text of the message. |
| Google and Apple | Sign in with Google / Sign in with Apple, if you choose to use them | They tell us your name and email address after you approve it on their screen. We do not receive your Google or Apple password. |
| Expo | Delivers push notifications to the apps | A push token for your device and the text of each notification. |
| Our hosting and storage providers | Run the servers and the database, and store advert files | Everything in this policy, as the systems it runs on. Advert files are public because they are going on a wall; any identity documents from a manual review are in a private area with no public address. |
Some of these providers process data outside Nigeria. Where they do, we rely on the safeguards the NDPA permits, including contractual protections and the provider's own adequacy under recognised frameworks.
We may also disclose data where the law requires it: to the Nigeria Data Protection Commission, to a court, to the police or another authority with a lawful demand, or to establish or defend a legal claim. If OPSIS is ever sold or merged, your data goes with it under this policy, and we will tell you first.
Advertisers see the venue name, address, screen details and play counts of the screens they buy. They do not see an owner's name, phone number, email or bank details. Owners see which brand's advert played on their screen and what it earned. They do not see the advertiser's contact person or payment details.
6. How long we keep it #
- Your account
- For as long as it is open. When you close it, or it has been unused for two years and we have told you we are closing it, your profile is deleted or anonymised within 30 days, except as below.
- Financial records
- Six years after the transaction — top-ups, charges, earnings, payouts, receipts and the play records that justify them. Nigerian tax and company law requires this, so a deletion request cannot shorten it.
- Play records and heartbeats
- Twenty-four months, so that a dispute about a campaign can be answered from the evidence. Records tied to a financial transaction are kept for the six years above.
- Identity verification results
- For the life of the account plus six years, because the verdict is what justifies every payout we made.
- Documents from a manual review
- Deleted when replaced and when the account is closed.
- Login codes and sessions
- Login codes expire within minutes. Sessions expire on their own and are deleted when you sign out.
- Server logs
- Ninety days.
- Support messages and disputes
- Two years after the matter is closed.
7. Your rights #
The NDPA gives you rights over your personal data. To use any of them, email hello@limitlextechnologies.com from the address on your account, or from the app, tell us which right you are using and what you want. We answer within 30 days; if a request is complex we may take up to a further 30 days and will tell you why. There is no charge unless a request is plainly repetitive.
- Access. Ask what personal data we hold about you and receive a copy in a common, machine-readable format.
- Correction. Have anything inaccurate or incomplete fixed. Most account details you can change yourself in the app or portal.
- Deletion. Ask us to delete your data. We will, except what we are required by law to keep (see section 6) and what we need to resolve an open dispute or an outstanding balance.
- Restriction and objection. Ask us to stop, or limit, processing that rests on our legitimate interests, and tell us why. We will stop unless we can show a compelling reason not to.
- Portability. Receive the data you gave us in a format you can take elsewhere.
- Withdraw consent. Where we rely on your consent (push notifications, marketing messages), turn it off at any time in your device settings or the app. It does not affect what was done before.
- Human review. If an automated identity check says no, ask a person at OPSIS to look at it again.
- Complain. You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC). We would rather hear from you first, but you do not have to.
9. How we protect it #
Everything travels over HTTPS. Passwords and PINs are stored only as one-way hashes. Provider keys are held in an encrypted vault and never written to logs. Identity documents from a manual review, where they exist, are in storage that has no public address and is scoped to the person they belong to. Staff access is limited by role, and every admin action is recorded. Screens authenticate with a secret issued at pairing and can be disconnected by the owner at any time.
If a breach happens that is likely to put you at risk, we will tell the NDPC within 72 hours of learning of it and tell you without undue delay, as the NDPA requires.
10. Children #
OPSIS is for businesses and the adults who run them. You must be 18 or older to hold an account. We do not knowingly collect data from anybody under 18; if we learn we have, we delete it. Advertisers must not target content at children in a way the law or APCON rules prohibit.
11. Changes to this policy #
When we change this policy we update the date at the top and, for anything that matters to you, tell you in the app or by email at least 14 days before it takes effect. Continuing to use OPSIS after that date means you accept the new policy. Earlier versions are available on request.
12. Contact #
Limitlex Technologies Limited
RC [RC NUMBER]
[REGISTERED ADDRESS]
hello@limitlextechnologies.com
Write “Privacy” in the subject line and it reaches the person responsible for data protection.