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Official Policy Document • Version 1.0

CarbonEx Apps Data Privacy Policy

CarbonEx User App & CarbonEx Vendor App • Comprehensive disclosure of how CarbonEx Agro Trading Nig. Ltd. (RC2018158) collects, encrypts, processes, and safeguards personal and IoT telemetry data.

Effective: 01/01/2025Last Updated: 16/09/2026NDPA 2023 & GDPR Compliant

IoT Smart Stove Telemetry

Pressure, flow rate, and consumption streams monitored in real-time strictly for safety, refills, and emission offsets.

Zero Commercial Sale

CarbonEx never sells your personal identifiable data, location information, or cooking telemetry to advertisers or data brokers.

End-to-End Encryption

Secured with TLS 1.3 in transit and AES-256 at rest, protected by strict Firebase & Google Cloud IAM access controls.

User Data Sovereignty

Full statutory rights under the Nigeria Data Protection Act 2023 to inspect, rectify, port, or request deletion of your data.

1. INTRODUCTION

Overview & Principles

Summary: Scope of policy covering User App, Vendor App, IoT smart devices, and climate-finance infrastructure.

CarbonEx Agro Trading Nig. Ltd. ("CarbonEx", "we", "us", or "our") is committed to protecting the privacy, security, confidentiality and lawful use of personal data entrusted to us through the CarbonEx digital ecosystem.

This Data Privacy Policy ("Privacy Policy") explains how CarbonEx collects, receives, records, stores, uses, analyses, shares, protects, transfers, retains and otherwise processes personal data through:

  1. the CarbonEx User App;
  2. the CarbonEx Vendor App;
  3. CarbonEx websites and web-based services;
  4. CarbonEx smart energy and clean-cooking technologies;
  5. CarbonEx-enabled IoT devices, sensors and telemetry systems;
  6. CarbonEx digital wallets and payment infrastructure;
  7. CarbonEx climate-finance, carbon-credit and reward systems;
  8. CarbonEx logistics and energy-distribution systems;
  9. CarbonEx artificial intelligence ("AI"), analytics and forecasting systems; and
  10. related CarbonEx services, platforms, APIs, databases and technology infrastructure.

The CarbonEx Apps are designed to facilitate access to energy and clean-energy services while enabling digital payments, energy monitoring, emissions measurement, climate-finance participation, rewards, energy logistics and data-driven energy access.

Because CarbonEx operates technology that can connect a user's identity with energy transactions, energy consumption, location, payments, emissions information, rewards and digital wallets, we recognise that some of the information processed through our Apps can be particularly sensitive from a privacy and security perspective.

We therefore seek to apply the principles of lawful, fair, transparent, purpose-limited, proportionate, secure and accountable data processing.

This Privacy Policy applies to both individual users and businesses using the CarbonEx Apps, including households, customers, energy users, gas vendors, distributors, agents and other authorised participants in the CarbonEx ecosystem.

By creating an account, accessing or using the CarbonEx Apps, you acknowledge that you have been provided with this Privacy Policy. Where consent is required by applicable law, CarbonEx will obtain consent through an appropriate affirmative action.

2. ABOUT CARBONEX

Overview & Principles

Summary: Climate-finance and energy-technology platform functionalities for consumers and vendors.

CarbonEx Agro Trading Nig. Ltd. operates a climate-finance and energy-technology platform designed to connect energy access, clean cooking, digital payments, energy intelligence, emissions measurement and climate-finance mechanisms.

The CarbonEx ecosystem may enable users to:

  • purchase or request LPG and other supported energy products;
  • purchase electricity or other supported energy services;
  • make and receive digital payments;
  • monitor energy consumption;
  • receive real-time or near-real-time energy information;
  • monitor or estimate associated greenhouse-gas emissions;
  • participate in clean-energy and climate-finance programmes;
  • receive rewards, points, carbon-related benefits or digital assets;
  • maintain digital wallets;
  • interact with vendors and energy suppliers;
  • request or track energy deliveries and refills;
  • use location-enabled logistics services;
  • access personalised energy information;
  • receive energy-demand or affordability recommendations;
  • interact with CarbonEx's AI-powered energy and emissions intelligence systems; and
  • participate in future or existing tokenized energy, climate or reward ecosystems supported by CarbonEx.

For vendors, the CarbonEx Vendor App may additionally facilitate:

  • customer and order management;
  • energy sales and fulfilment;
  • refill and delivery management;
  • vendor wallet management;
  • payment settlement;
  • transaction reconciliation;
  • energy-demand intelligence;
  • customer-service operations;
  • logistics coordination;
  • energy-consumption analytics;
  • carbon and emissions data generation;
  • operational performance monitoring; and
  • participation in CarbonEx's climate-finance and energy-data ecosystem.

3. DATA CONTROLLER

Overview & Principles

Summary: Corporate entity details, legal registration (RC: 2018158), and contact data.

For personal data processed through the CarbonEx Apps, CarbonEx Agro Trading Nig. Ltd. generally acts as the data controller where CarbonEx determines the purposes and means of processing personal data.

CarbonEx may also act as a data processor where it processes personal data strictly on behalf of another organisation under applicable contractual or legal arrangements.

CarbonEx Agro Trading Nig. Ltd.
Company Registration: RC2018158
Jurisdiction: Nigeria

Where CarbonEx appoints a Data Protection Officer, Data Protection Compliance Organisation or other designated privacy contact, the relevant contact details may be provided through the App, website or an updated version of this Privacy Policy.

4. OUR DATA PROTECTION PRINCIPLES

Overview & Principles

Summary: Seven core statutory principles under the Nigeria Data Protection Act (NDPA 2023).

CarbonEx seeks to process personal data in accordance with applicable data-protection law and the following principles:

4.1 Lawfulness, Fairness & Transparency

We process personal data on an appropriate lawful basis and explain clearly what information we collect, why we collect it, and how it is used.

4.2 Purpose Limitation

We collect and process information for specified, legitimate and disclosed purposes and seek not to use personal data for incompatible purposes.

4.3 Data Minimisation

We seek to collect information that is adequate, relevant and reasonably necessary for the service, transaction, security or operational purpose.

4.4 Accuracy

We seek to maintain accurate and reasonably up-to-date information and provide mechanisms for users to correct relevant personal information.

4.5 Storage Limitation

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, unless longer retention is required or permitted by law.

4.6 Security and Confidentiality

We apply appropriate technical, organisational and administrative safeguards designed to protect personal data against unauthorised access, alteration or loss.

4.7 Accountability

CarbonEx seeks to maintain appropriate governance, records, policies, access controls, security procedures and privacy practices demonstrating responsible data processing in alignment with the Nigeria Data Protection Commission (NDPC) under the Nigeria Data Protection Act 2023.

5. TYPES OF USERS COVERED BY THIS POLICY

Overview & Principles

Summary: Categories of individuals and entities interacting with the CarbonEx platform.

Depending on how you interact with CarbonEx, you may be:

  • 5.1 User App customerA household, individual or other energy consumer using the CarbonEx User App to purchase energy, monitor consumption, receive services, make payments or participate in CarbonEx's rewards and climate-finance ecosystem.
  • 5.2 Vendor App userAn LPG vendor, energy vendor, distributor, delivery partner, agent, merchant, operator or other authorised business user operating through the CarbonEx Vendor App.
  • 5.3 Connected-device userA person whose household, energy appliance, smart cookstove, meter, sensor or other connected energy device sends information into the CarbonEx ecosystem.
  • 5.4 Programme participantA person participating in a CarbonEx clean-energy, climate-finance, carbon-credit, subsidy, rewards, research, pilot, community or other programme.

6. INFORMATION WE COLLECT

Information Collected

Summary: Account identification fields, credentials, addresses, and purpose of collection.

The information CarbonEx collects depends on the services you use, the permissions you grant, the transactions you perform and the devices or energy technologies connected to your account.

6.1 Identity and account information

When you create or maintain a CarbonEx account, we may collect:

  • full name;
  • username;
  • account ID;
  • phone number;
  • email address;
  • password or authentication credentials;
  • date of birth where required for a particular service;
  • residential or business address;
  • profile photograph where voluntarily provided;
  • account type;
  • customer or vendor status;
  • referral information;
  • account preferences;
  • security settings; and
  • other information necessary to establish and maintain your account.

Why we collect this information:

  • create and manage your CarbonEx account;
  • authenticate you;
  • communicate with you;
  • provide energy services and process transactions;
  • associate energy transactions with the correct customer or vendor;
  • prevent fraud and unauthorised access;
  • provide customer support;
  • comply with legal and regulatory requirements; and
  • maintain the security and integrity of the CarbonEx ecosystem.

7. CONTACT INFORMATION

Information Collected

Summary: Phone numbers, emails, addresses, and operational contact channels.

We may collect telephone numbers, email addresses, delivery addresses, service addresses, business addresses, emergency or operational contact details where relevant, communication preferences, and contact information supplied in connection with an order or service.

We use this information to communicate about orders, gas refills, electricity purchases, payments, deliveries, account activity, service interruptions, security alerts, rewards, climate-finance programmes, and customer support.

8. LOCATION DATA

Information Collected

Summary: GPS, approximate location, routing, and location permission governance.

Because CarbonEx operates an energy-access and logistics platform, location information is an important component of our services.

Depending on permissions and configuration, CarbonEx may process: precise GPS location, approximate location, delivery location, household/service location, vendor location, transaction location, route/logistics location, location associated with an energy device or order, IP-derived approximate location, and geospatial infrastructure data.

Why location data is used:

  1. identify the service area associated with an account;
  2. facilitate gas delivery and refill logistics;
  3. connect customers with nearby vendors;
  4. support energy availability and distribution;
  5. estimate logistics requirements and monitor delivery progress;
  6. improve delivery routing and reduce operational costs;
  7. associate energy consumption with geographic locations;
  8. support emissions measurement and climate-impact calculations;
  9. identify local energy demand and forecast regional requirements;
  10. support fraud and transaction-security controls; and
  11. generate aggregated or anonymised energy-market intelligence.
Location Permissions: You may disable location permissions in your device settings. However, location-dependent features (delivery routing, nearby vendor assignment) may not function properly without location data. CarbonEx avoids collecting precise GPS coordinates when approximate location suffices.

9. ENERGY CONSUMPTION AND ENERGY USAGE DATA

Information Collected

Summary: LPG, electricity, kWh, timestamps, appliance readings, and consumption analytics.

Energy data is a fundamental component of the CarbonEx ecosystem. Depending on the service used, CarbonEx may collect or receive:

  • LPG consumption and estimates;
  • electricity consumption & purchase amounts;
  • electricity token or vending information;
  • energy quantity & kWh information;
  • gas quantity & refill quantity;
  • energy usage & purchase frequency;
  • energy consumption timestamps;
  • appliance or device readings;
  • smart cookstove information & meter data;
  • energy-demand patterns & duration;
  • consumption trends & affordability data; and
  • related telemetry streams.

Energy data enables CarbonEx to provide real-time energy monitoring, help users understand their consumption, optimize LPG refill logistics, calculate verified emissions, support carbon-credit processes, and power CarbonEx's energy intelligence systems.

10. SMART COOKSTOVE AND IOT TELEMETRY DATA

IoT & AI Intelligence

Summary: Device IDs, sensor readings, pressure, battery, flow rates, and safety alerts.

Where a CarbonEx-enabled smart cookstove, sensor, meter, energy device or other connected technology is used, CarbonEx receives machine-generated telemetry.

Telemetry Attributes Collected

Device ID, sensor ID, pressure measurements, energy measurements, consumption measurements, timestamps, device status, battery status, connectivity status, network information, signal strength, GPS information where enabled, device diagnostics, operating status, sensor readings, appliance activity, refill or usage events.

CarbonEx may combine telemetry with account, transaction and location information to monitor consumption, detect abnormal conditions, support preventative maintenance, detect leakage or fraud, validate climate-impact claims, and improve device reliability.

11. EMISSIONS AND CLIMATE-IMPACT DATA

Climate & Finance

Summary: CO2-equivalent reductions, baseline calculations, fuel displacement, and dMRV metrics.

CarbonEx calculates, estimates and monitors data relating to greenhouse-gas emissions and climate impact, including:

  • estimated CO₂ or CO₂-equivalent emissions and emissions avoided;
  • baseline energy use vs. post-intervention clean energy adoption;
  • fuel displacement (e.g. firewood, kerosene or charcoal displaced by clean LPG/electricity);
  • clean-cooking activity and energy efficiency metrics;
  • monitoring, reporting and verification ("MRV") and digital MRV ("dMRV") records; and
  • carbon-credit generation and verification status.

These calculations use transaction logs, smart cookstoves, meters, approved methodologies, and verified third-party technical standards to generate aggregated or pseudonymised climate data.

12. CARBON CREDITS AND CLIMATE-FINANCE DATA

Climate & Finance

Summary: Data submitted to authorized carbon registries, verification bodies, and partner entities.

CarbonEx may operate or participate in mechanisms through which verified energy and environmental activity contributes to climate-finance or carbon-credit programmes.

For these purposes, we process energy-use records, emissions-reduction estimates, project identifiers, household participation information, verification records, reward eligibility, and wallet identifiers.

CarbonEx may provide relevant information to authorised carbon registries, verification bodies, and climate-finance partners strictly where necessary to establish, verify, issue, administer, or report climate-related assets. Where environmental data is aggregated or anonymised, CarbonEx may use it for climate modelling and research.

13. PAYMENT INFORMATION

Climate & Finance

Summary: Payment gateways, mobile money, banks, and payment-card processing security.

CarbonEx Apps integrate with banks, payment gateways, mobile-money providers, card processors, and electricity-vending providers. We process payment amounts, transaction references, dates, currency, payment methods, payer/recipient info, wallet IDs, and transaction histories.

Payment-Card Credentials Handling:

Where a third-party payment provider processes card information, sensitive payment-card credentials are collected and processed directly by the certified payment provider rather than CarbonEx. CarbonEx does not unnecessarily store complete payment-card numbers, CVVs, or card PINs on our servers.

14. CARBONEX FIAT WALLETS

Climate & Finance

Summary: In-app wallets for deposits, gas refill purchases, electricity, and vendor settlement.

The CarbonEx Apps provide digital wallets used for energy-related transactions, including deposits, transfers, gas refill payments, electricity purchases, vendor settlement, promotional credits, and balances.

CarbonEx maintains separate wallet structures: customer wallets are configured for permitted energy transactions, while vendor wallets support settlements, transfers, or withdrawal functions in accordance with regulatory requirements.

15. WEB3 WALLETS AND TOKENIZED ASSETS

Climate & Finance

Summary: Blockchain networks, wallet addresses, off-chain PII protection, and immutability notices.

CarbonEx may integrate with Web3 wallets, blockchain networks, and tokenized digital assets for rewards, verification, and digital energy proofs.

Important Blockchain Privacy Consideration

Blockchain networks are inherently transparent, distributed, and immutable. CarbonEx seeks to avoid placing directly identifying personal information on public blockchains. We maintain sensitive personal data off-chain while using blockchain only for cryptographic hashes, identifiers, verification proofs, and transaction references.

Users should understand that blockchain wallet transactions are public and permanent, and CarbonEx cannot alter or delete records on third-party decentralized networks.

16. REWARDS, POINTS AND DIGITAL ASSETS

Climate & Finance

Summary: Clean-energy incentives, eligibility criteria, and administrative transaction processing.

CarbonEx operates reward mechanisms for clean-energy adoption, LPG refills, electricity efficiency, verified cooking, referrals, and carbon-credit activity. We process account records, transaction histories, and token/point balances to administer these programmes.

Nothing in this Privacy Policy constitutes an offer, guarantee or representation concerning the financial value or liquidity of any reward token or digital asset.

17. GAS LOGISTICS AND DELIVERY INFORMATION

Information Collected

Summary: Order details, delivery addresses, dispatch status, and fulfillment communications.

When facilitating LPG or energy delivery, we process customer names, phone numbers, delivery addresses, coordinates, order details, refill history, driver/agent details, timestamps, proof-of-delivery records, and order communications to coordinate dispatch and optimize distribution.

18. VENDOR DATA

Information Collected

Summary: Business registration, identity verification, inventory, and settlement records.

The CarbonEx Vendor App collects vendor business names, addresses, phone numbers, registration certificates, identity verification credentials, representative details, settlement accounts, energy inventory, sales logs, and operational activity to operate our marketplace.

19. DEVICE AND TECHNICAL INFORMATION

IoT & AI Intelligence

Summary: Hardware models, OS versions, unique identifiers, IP addresses, and crash telemetry.

When you use CarbonEx Apps, we automatically receive device models, manufacturer info, OS version, app version, unique device identifiers, IP address, network details, language, time zone, crash logs, diagnostic information, and session authentication events.

This technical data is used to secure the Apps, detect malicious activity, troubleshoot errors, prevent fraud, and deliver reliable software updates.

20. APP ACTIVITY AND USAGE DATA

IoT & AI Intelligence

Summary: In-app navigation, screen views, feature interactions, and performance analytics.

We log screens viewed, features used, transactions initiated, session durations, login attempts, notification deliveries, settings changes, and support interactions to ensure platform health and optimize customer experience.

21. AI, MACHINE LEARNING AND AUTOMATED PROCESSING

IoT & AI Intelligence

Summary: Energy intelligence, predictive analytics, and automated decision-making safeguards.

CarbonEx uses artificial intelligence, machine learning, and statistical modeling to analyze energy demand, delivery patterns, refill behavior, device diagnostics, emissions, and anomaly detection.

Automated Decision-Making Safeguards:

Where automated systems materially influence decisions affecting an individual, CarbonEx complies with the NDPA provisions regarding automated profiling. Users have the right to request information, challenge decisions, and request human intervention. CarbonEx does not use AI to make decisions based on sensitive personal characteristics where unlawful or unnecessary.

22. ENERGY DEMAND FORECASTING

IoT & AI Intelligence

Summary: Regional supply planning, seasonal modeling, and inventory optimization.

CarbonEx analyzes historical and real-time purchases, consumption patterns, time of day, and seasonal trends to forecast regional LPG and electricity requirements, reduce stockouts, and improve affordability. Aggregated and pseudonymised data is prioritized over individual profiles.

23. ENERGY AND EMISSIONS INTELLIGENCE

IoT & AI Intelligence

Summary: Data synthesis linking account + transaction + telemetry + location + timestamps.

CarbonEx synthesizes multiple data layers to generate verified energy intelligence:

User account + energy transaction + device telemetry + location + timestamp + consumption information

This integrated model determines emissions avoided, refill urgency, and energy-access patterns that would be impossible to derive from transaction records alone.

24. HOW WE USE PERSONAL DATA

Usage & Sharing

Summary: 36 authorized operational, security, fulfillment, and legal processing purposes.

Subject to applicable law, CarbonEx processes personal data for 36 designated purposes:

  1. create and manage accounts;
  2. authenticate users;
  3. provide energy services;
  4. process payments;
  5. process gas and electricity purchases;
  6. manage wallets;
  7. facilitate vendor settlements;
  8. coordinate energy deliveries;
  9. monitor energy consumption;
  10. measure or estimate emissions;
  11. generate climate-impact information;
  12. administer rewards;
  13. administer climate-finance programmes;
  14. support carbon-credit activities;
  15. operate dMRV systems;
  16. operate connected devices;
  17. forecast energy demand;
  18. improve energy affordability and access;
  19. optimise logistics;
  20. detect fraud;
  21. prevent abuse;
  22. secure accounts;
  23. troubleshoot technical problems;
  24. provide customer support;
  25. analyse App performance;
  26. improve CarbonEx products;
  27. conduct research and development;
  28. generate aggregated energy-market intelligence;
  29. comply with applicable laws;
  30. respond to lawful requests from authorities;
  31. enforce contractual terms;
  32. protect CarbonEx, users and third parties;
  33. investigate security incidents;
  34. resolve disputes;
  35. maintain financial and transaction records; and
  36. perform other disclosed purposes permitted by law.

26. WHEN WE SHARE PERSONAL DATA

Usage & Sharing

Summary: Authorized disclosure to verified partners, logistics, cloud hosts, and regulators.

CarbonEx does not treat personal data as a commodity to be freely sold.

We disclose data strictly as necessary to: payment processors, banks, mobile-money operators, electricity utilities, LPG suppliers, verified delivery partners, cloud hosting providers (Google Cloud / Firebase), cybersecurity auditors, IoT connectivity operators, carbon registries, legal advisers, and government authorities when lawfully mandated.

27. CUSTOMER-VENDOR DATA SHARING

Usage & Sharing

Summary: Bilateral data exchanges required for last-mile delivery and cylinder refills.

When an order is placed, vendors receive necessary delivery details: customer name, address, phone number, order quantity, and fulfillment notes. Customers receive vendor identification to confirm authentic deliveries.

28. THIRD-PARTY SERVICE PROVIDERS

Usage & Sharing

Summary: Contractual data protection obligations for cloud, database, SMS, and analytics partners.

We utilize trusted third-party providers for hosting, SMS, notifications, mapping, and AI computing. All providers are bound by confidentiality, data protection agreements, and security standards.

29. INTERNATIONAL DATA TRANSFERS

Usage & Sharing

Summary: Cross-border data transfers, adequacy mechanisms, and encryption safeguards.

Where cloud infrastructure or service providers operate outside Nigeria, CarbonEx applies adequacy mechanisms, standard contractual clauses, encryption, and pseudonymisation consistent with the NDPA 2023.

30. BLOCKCHAIN AND DECENTRALISED NETWORKS

Climate & Finance

Summary: Public ledger permanence and limiting on-chain data to non-identifiable hashes.

Decentralized ledgers cannot be modified once written. CarbonEx minimizes on-chain exposure by storing all identifiable customer profiles off-chain, using blockchains strictly for token balances and cryptographic verification proofs.

31. DATA AGGREGATION, PSEUDONYMISATION AND ANONYMISATION

Security & Retention

Summary: Distinction between pseudonymised personal data and irreversibly anonymised data.

Pseudonymised data: Identifiers are replaced with cryptographic tokens, reducing direct association while allowing authorised internal linking.

Anonymised data: Irreversibly stripped of identifying links. Anonymised statistics may be published for climate research, energy demand forecasting, and industry reporting.

32. MARKETING AND COMMUNICATIONS

Usage & Sharing

Summary: Service-critical alerts vs. optional promotional messages with opt-out choices.

Service notifications (transactions, safety alerts, delivery confirmations) are mandatory for account operation. Optional marketing messages can be unsubscribed from at any time via in-app settings or email links.

33. COOKIES AND SIMILAR TECHNOLOGIES

IoT & AI Intelligence

Summary: Session tokens, mobile SDKs, device telemetry sockets, and preference storage.

We use essential cookies and SDKs for authentication, session stability, real-time WebSocket connections, and security monitoring. Non-essential cookies may be managed through browser settings.

34. CHILDREN'S PRIVACY

User Rights & Legal

Summary: Policy prohibiting unlawful collection from minors and parental notification process.

CarbonEx services are intended for adults legally competent to transact energy contracts. We do not knowingly collect personal information from children. If a parent believes data has been submitted unlawfully, contact carbonexafrica@gmail.com.

35. DATA SECURITY

Security & Retention

Summary: TLS 1.3 encryption in transit, AES at rest, least-privilege RBAC, and vulnerability audits.

CarbonEx implements robust multi-tier security safeguards:

TLS / SSL encryption in transit
AES-256 database encryption at rest
Role-Based Access Control (RBAC)
Continuous security telemetry & logging

36. ACCOUNT SECURITY

Security & Retention

Summary: User password confidentiality, session management, and credential protection.

Users are responsible for safeguarding login credentials. Enable biometric authentication, maintain strong unique passwords, and alert CarbonEx immediately if unauthorized access is suspected.

37. DATA BREACHES AND SECURITY INCIDENTS

Security & Retention

Summary: Eight-step structured breach containment, investigation, and regulatory notification.

In the event of a confirmed breach, CarbonEx initiates its structured incident response: containment, forensic investigation, evidence preservation, impact assessment, regulatory notification to NDPC, communication to affected individuals, and remediation.

38. DATA RETENTION

Security & Retention

Summary: Retention schedules across account lifecycles, financial compliance, and climate MRV.

Account data is retained while active. Financial and transaction logs are retained for statutory accounting and tax compliance periods. Emissions data is maintained for the duration required by carbon credit registries. Once obsolete, data is securely erased or irreversibly anonymized.

39. DATA SUBJECT RIGHTS

User Rights & Legal

Summary: Ten statutory rights under NDPA 2023 / GDPR: access, rectification, erasure, and portability.

You possess statutory rights under applicable privacy legislation:

39.1 Right to be Informed: Transparent notice on data usage.
39.2 Right of Access: Request copies of personal data held.
39.3 Right to Rectification: Correct outdated or inaccurate info.
39.4 Right to Object: Object to processing for direct marketing.
39.5 Right to Restriction: Limit processing under dispute.
39.6 Right to Data Portability: Receive data in structured format.
39.7 Right to Erasure: Request deletion where permitted.
39.8 Right to Withdraw Consent: Revoke prior consent.
39.9 Rights on Automated Decisions: Request human review.
39.10 Right to Lodge Complaint: File with supervisory bodies.

40. HOW TO EXERCISE YOUR RIGHTS

User Rights & Legal

Summary: Application submission to carbonexafrica@gmail.com with 30-day response target.

Submit formal data protection requests to carbonexafrica@gmail.com.

Required Details for Verification:
  • Full name & registered email/phone number;
  • Nature of request (access, rectification, deletion, portability);
  • Identity verification information to prevent unauthorized disclosure.

CarbonEx responds to valid requests within statutory timelines (NDPC 30-day target).

41. WITHHOLDING INFORMATION

User Rights & Legal

Summary: Operational consequences of withholding required delivery or telemetry data.

Providing certain information is mandatory to operate energy services. Withholding location prevents physical gas deliveries; disabling device telemetry impairs automatic refill tracking and leak detection.

43. OPEN BANKING, MOBILE MONEY AND PAYMENT INTEGRATIONS

Climate & Finance

Summary: Secure financial API communications, transaction reconciliation, and authentication.

Information necessary to initiate, authenticate, and reconcile energy payments is exchanged with banking and mobile money APIs under secure encryption standards.

44. ELECTRICITY AND ENERGY-SERVICE INTEGRATIONS

Climate & Finance

Summary: Data sharing with electricity distribution companies (DisCos) and meter vending APIs.

Meter numbers, energy purchase units, and verification codes are exchanged with licensed utilities to vending electricity tokens and verify grid service availability.

45. CARBONEX DIGITAL MRV (dMRV)

Climate & Finance

Summary: Cryptographic monitoring, reporting, and verification for carbon credits.

Our digital MRV infrastructure combines energy consumption data, IoT sensor logs, and timestamped transactions to create tamper-evident environmental audit trails while preserving personal privacy off-chain.

46. RESEARCH, ANALYTICS AND PRODUCT DEVELOPMENT

IoT & AI Intelligence

Summary: Advancing clean cooking technology, energy access models, and platform safety.

We analyze aggregated usage trends to engineer improved smart cookstoves, optimize supply chain routes, and advance sustainable energy access across emerging markets.

47. FRAUD PREVENTION AND SECURITY ANALYTICS

Security & Retention

Summary: Automated risk scoring to identify compromised accounts, delivery fraud, and tampering.

Automated heuristics monitor for abnormal transactions, sensor manipulation, and account takeover attempts to protect users and maintain marketplace trust.

48. ENERGY AFFORDABILITY AND ACCESS

Overview & Principles

Summary: Designing community energy subsidies, micro-refill models, and affordability programs.

CarbonEx leverages aggregated energy data to structure targeted clean-cooking subsidies, affordable micro-payment plans, and equitable energy distribution models.

49. DATA OWNERSHIP AND INTELLECTUAL PROPERTY

User Rights & Legal

Summary: User sovereignty over personal data vs. CarbonEx proprietary algorithms and models.

Your personal data remains protected under statutory privacy rights. CarbonEx retains exclusive intellectual property in its algorithms, software code, data schemas, and aggregated models.

50. YOUR RESPONSIBILITIES WHEN USING CARBONEX

User Rights & Legal

Summary: Accuracy, truthfulness, and lawful authorization of data submitted.

Users must ensure all information submitted is accurate, complete, current, and lawful. If submitting information on behalf of another individual or household member, ensure proper authorization.

51. CHANGES TO THIS PRIVACY POLICY

User Rights & Legal

Summary: Policy versioning, revision notifications, and tracking of updates.

CarbonEx updates this policy periodically to reflect evolving technology and statutory regulations. Material modifications will be highlighted through the App, website, or direct notification.

52. GOVERNING DATA-PROTECTION FRAMEWORK

User Rights & Legal

Summary: Nigeria Data Protection Act 2023 (NDPA), NDPC regulatory mandates, and GDPR.

This policy is governed by the Nigeria Data Protection Act 2023 administered by the Nigeria Data Protection Commission (NDPC). Where international users or cross-border processing occurs, CarbonEx complies with GDPR and applicable regional standards.

53. REGULATORY COMPLAINTS

User Rights & Legal

Summary: Procedures for internal resolution and filing complaints with the NDPC.

We encourage users to reach out to CarbonEx first so issues can be resolved promptly. You also have the right to lodge a complaint directly with the Nigeria Data Protection Commission (NDPC).

54. CONTACT CARBONEX

Overview & Principles

Summary: Official corporate channels, registration RC2018158, and privacy inquiry desk.

CarbonEx Agro Trading Nig. Ltd.
Registration:RC: 2018158
Jurisdiction:Federal Republic of Nigeria
Corporate Email:info@carbonex.africa

When contacting us, please state clearly: "Attention: Data Privacy / Data Subject Request".

55. IMPORTANT PRIVACY NOTICE

Overview & Principles

Summary: End-to-end interconnected energy lifecycle chain notice.

CarbonEx services involve interconnected processing essential to connecting people with clean energy:

Identity → Account → Payment → Energy Purchase → Energy Consumption → Location → Logistics → Emissions → Climate Impact → Rewards → Wallets → Tokenized Assets.

Because these components are interconnected, restricting certain categories (e.g. location or sensor telemetry) may limit the availability of corresponding real-time features. CarbonEx processes only information reasonably necessary for each service.

56. OUR COMMITMENT

Overview & Principles

Summary: Our pledge: Transitioning to clean energy without surrendering control over personal data.

CarbonEx believes that the transition to cleaner, more affordable and more accessible energy should not require people to surrender control over their personal information.

Our objective is to build privacy directly into the CarbonEx ecosystem alongside energy access, clean cooking, digital payments, smart energy, IoT, emissions measurement, climate finance, carbon markets, digital MRV, AI, energy logistics, and tokenized environmental assets.

Effective Date: 01/01/2025Last Updated: 16/09/2026Version 1.0 (Official Document)

CarbonEx Agro Trading Nig. Ltd.

Incorporated under Nigerian Company Law • RC: 2018158

This document constitutes the official Data Privacy Policy governing the CarbonEx digital ecosystem as of September 16, 2026. For questions, statutory rights requests, or regulatory filings, contact our Data Protection Compliance desk at carbonexafrica@gmail.com or visit our headquarters at AUSTInspire, African University of Science and Technology, Abuja, Nigeria.