Cookie policy

1. What cookies are and why we use them

1.1 Definition

A "cookie" is a small text file placed on your device when you visit a website or use an application. Cookies allow a platform to recognise your device, remember your preferences, and understand how the platform is used. This Policy also covers functionally similar tracking technologies, including web beacons, pixel tags, local storage objects, software development kit (SDK) identifiers used within the Gathr mobile application, and any other tracking tool that performs a comparable function (collectively, "Tracking Tools").

1.2 Legal basis for this policy

This Policy is issued in accordance with:

The Nigeria Data Protection Act, 2023 (NDPA), in particular Sections 24 to 26 (principles of processing, lawful basis, and consent), Section 27 (provision of information to the data subject), and Section 35 (withdrawal of consent)
The Nigeria Data Protection Commission's General Application and Implementation Directive (GAID) 2025, in particular Article 18 (mandatory consent for specified processing activities, including direct marketing and cross-border transfer) and Article 19 (Consent to Cookies and Other Tracking Tools), which together require opt-in consent for all non-essential cookies and Tracking Tools
The Nigerian Communications Commission (NCC) Consumer Protection framework, to the extent it governs the confidentiality of subscriber and customer information transmitted over Nigerian telecommunications networks
Section 37 of the Constitution of the Federal Republic of Nigeria, which guarantees the right to privacy

1.3 Scope

This Policy applies to the Gathr website, mobile application, and any other digital property operated by Gathr Technologies Limited where cookies or Tracking Tools are deployed. It applies to organisers, donors, beneficiaries, and any visitor to the platform, whether or not they hold a registered account.

2. Categories of cookies we use

2.1 Strictly necessary cookies

These cookies are essential for the Services to function and cannot be switched off. They include cookies that maintain your login session, enable secure form submission, support fraud detection during a donation, and remember your cookie consent choices. In accordance with Article 19 of the GAID, strictly necessary cookies that do not process sensitive, financial, or otherwise private data may operate without your consent, as they are required to deliver the Services you have requested. Where a strictly necessary cookie does process financial or sensitive data, for example a fraud-prevention cookie used during payment processing, it is deployed on the lawful basis of contractual necessity and legal obligation under Section 25 of the NDPA, rather than consent.

2.2 Functional cookies

These cookies remember choices you make, such as your preferred currency display, campaign category filters, or language setting, to provide a more personalised experience. Functional cookies are not strictly necessary for the Services to operate and are deployed only with your consent.

2.3 Performance and analytics cookies

These cookies collect information about how visitors use the platform, including which pages are visited most frequently, how long a campaign page is viewed, and whether a donation flow was completed or abandoned. We use this information in aggregate and, where possible, pseudonymised form to improve the design and performance of the Services. Analytics cookies are deployed only with your consent.

2.4 Marketing and advertising cookies

Where Gathr or its marketing partners use cookies to measure the effectiveness of campaign promotion, social media sharing, or advertising placed on third-party platforms, these cookies may track your activity across sessions and, in some cases, across other websites. Marketing cookies are deployed only with your affirmative, opt-in consent, in accordance with Article 18(1) of the GAID's mandatory consent requirement for direct marketing activity, and you may withdraw that consent at any time as described in Module 5 below.

2.5 Third-party cookies

Certain cookies on the platform are placed by third parties, including Paystack Payments Limited (for payment processing and fraud prevention), analytics providers, and any social media plug-ins embedded in a campaign page for sharing purposes. These third parties act as independent data controllers for the cookies they place, and their use of your data is governed by their own privacy and cookie policies, which we encourage you to review. Gathr does not control the retention periods or downstream use of data collected by third-party cookies beyond the purpose for which they were integrated into the Services.

3. How we obtain your consent

3.1 The cookie notice

On your first visit to the Gathr website or application, you will be presented with a cookie notice that is clearly visible and does not require you to scroll to find it. The notice explains, in plain language, what categories of cookies are used, the purpose of each category, which third parties (if any) deploy them, and how you can accept, decline, or customise your preferences.

3.2 Standard of consent

In accordance with Article 19 of the GAID and Section 26 of the NDPA, consent to non-essential cookies must be freely given, specific, informed, and unambiguous. Accordingly:

We do not use pre-ticked boxes or default "accept all" selections
Continued browsing, scrolling, or inactivity is not treated as consent
You are given a genuine and equally prominent option to decline non-essential cookies as you are to accept them
You may accept or decline categories of cookies individually rather than on an all-or-nothing basis, where technically feasible

3.3 Children

Because the Services are restricted to persons who are at least eighteen (18) years of age under Module 1.2 of the Terms of Service, we do not knowingly seek cookie consent from a child as defined under the NDPA and the Child Rights Act. If we become aware that consent has been given by a person under the age of eighteen, we will disregard that consent and take reasonable steps to stop non-essential tracking of that individual's device.

4. What we use cookie data for

Consistent with the purposes of processing described in the Privacy Policy, we use cookie and Tracking Tool data to:

Keep you securely logged in to your account
Detect and prevent fraudulent donations, account takeover attempts, and suspicious transaction patterns described in Module 3.3 of the Terms of Service
Remember your campaign browsing and donation preferences
Understand aggregate usage patterns to improve platform design, campaign discovery, and load performance
Measure the effectiveness of campaign sharing and, where you have consented, marketing communications
Comply with our record-keeping obligations under the Money Laundering (Prevention and Prohibition) Act, 2022 and applicable CBN guidelines, where a cookie forms part of the audit trail for a financial transaction

We do not use cookies to build a profile of your health status, political opinion, religious belief, or other sensitive personal data category defined under Section 30 of the NDPA, save where you have voluntarily disclosed such information within public campaign content that you choose to view or share.

5. Managing and withdrawing your consent

5.1 In-platform cookie preference centre

You may review and change your cookie preferences at any time through the cookie preference centre accessible from the footer of the Gathr website or the settings menu of the Gathr mobile application.

5.2 Withdrawal of consent

In accordance with Section 35 of the NDPA, you may withdraw your consent to any non-essential cookie category at any time, and the process for withdrawing consent is as simple as the process for giving it. Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal, and does not affect strictly necessary cookies required to operate the Services.

5.3 Browser and device controls

In addition to the in-platform preference centre, most browsers and mobile operating systems allow you to block or delete cookies through their own settings. Please note that blocking strictly necessary cookies through your browser or device settings, rather than through our preference centre, may prevent you from logging in, completing a donation, or using certain features of the Services, and Gathr is not responsible for any degradation in functionality that results from browser-level cookie blocking.

5.4 Do not track signals

Because there is no uniform industry or Nigerian regulatory standard for responding to "Do Not Track" browser signals, the Services do not currently respond to such signals. We encourage you to use the cookie preference centre described in Clause 5.1 to express your preferences directly.

6. Data retention for cookie data

Cookie data is retained only for as long as necessary for the purpose for which it was collected, consistent with the retention principles set out in the Privacy Policy. Session cookies expire when you close your browser or application. Persistent cookies remain on your device for the period disclosed in the cookie preference centre at the time consent was given, after which they expire automatically or are refreshed only upon renewed consent.

7. Cross-border transfer of cookie data

Where a cookie or Tracking Tool transmits data to a third-party analytics or marketing provider located outside Nigeria, such transfer is carried out in accordance with the cross-border transfer safeguards described in Module 10 of the Privacy Policy and Part VIII of the NDPA, including reliance, where applicable, on your explicit consent as one of the permissible bases under Article 18(1) of the GAID for a transfer to a jurisdiction without an NDPC adequacy determination.

8. Changes to this policy

We may update this Cookie Policy from time to time to reflect changes in the cookies and Tracking Tools we use, or in applicable law or regulatory guidance issued by the NDPC. Material changes will be communicated through an updated cookie notice or the notification channels described in Module 1.4 and 7.5 of the Terms of Service. Where a change introduces a new category of non-essential cookie, we will seek fresh consent before that category is activated for existing users.

9. Contact us

For any question regarding this Cookie Policy, or to exercise a right described in Module 5, contact our Data Protection Officer at privacy@gathrhq.com .

You may also lodge a complaint directly with the Nigeria Data Protection Commission (NDPC) at No.12 Dr. Clement Isong Street, Asokoro, Abuja, Nigeria, or by email at info@ndpc.gov.ng.

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