This Privacy Policy explains how NovelDRAW Creative, through its Pàdé service ("Pàdé", "we", "us" or "our"), collects, uses, stores, shares and protects personal information when you use Pàdé.
Pàdé is operated by NovelDRAW Creative, Nigeria. Operational Office: 763, Abubakar Usman, Jabi, FCT, Abuja, Nigeria.
We take the privacy and security of information entrusted to Pàdé seriously.
1. Who This Policy Applies To
This Privacy Policy applies to:
- Event attendees;
- Ticket purchasers;
- Event Organisers;
- Event staff;
- visitors to Pàdé websites;
- registered users;
- individuals who communicate with Pàdé; and
- persons whose information is provided to Pàdé in connection with an Event.
Where Pàdé operates in Ghana, this Policy is also intended to operate consistently with applicable Ghanaian data-protection requirements.
2. Information We Collect
Depending on how you use Pàdé, we may collect the following categories of information.
2.1 Account Information — name; email address; telephone number; password credentials; and profile information.
2.2 Ticket Information — Event purchased; Ticket category; Ticket quantity; Ticket number; QR-code or admission identifier; purchase date; and transaction reference.
2.3 Payment Information — payments may be processed by third-party payment providers. Pàdé may receive payment status; transaction reference; amount; currency; payment method; masked account or card information; and payment-provider identifiers. We do not ordinarily need to store your full card number or card security code.
2.4 Event Organiser Information — legal name; organisation name; business information; contact details; identification information; tax-related information where required; bank or settlement information; Event information; and information required for verification.
2.5 Technical Information — IP address; browser type; device type; operating system; approximate location derived from technical information; pages viewed; referring pages; timestamps; error information; cookies; and similar technologies.
3. How We Use Information
We may use personal information to:
- create and manage accounts;
- process Ticket purchases;
- issue Tickets;
- verify admission;
- facilitate payments;
- process refunds;
- manage Event attendance;
- provide customer support;
- communicate Event changes;
- prevent fraud;
- detect suspicious transactions;
- administer organiser payouts;
- reconcile transactions;
- provide reports;
- improve Pàdé;
- maintain Platform security;
- comply with legal obligations; and
- enforce our agreements.
4. Lawful Grounds for Processing
Depending on the applicable jurisdiction and circumstances, Pàdé may process personal information because:
- it is necessary to perform a contract;
- you have provided consent;
- processing is necessary to comply with a legal obligation;
- processing is necessary to protect legitimate interests;
- processing is necessary to prevent fraud or protect Platform security; or
- another lawful basis applies.
Where consent is the appropriate legal basis, you may withdraw consent subject to legal and operational limitations.
5. Event Organiser Access to Data
When you purchase a Ticket, certain information may be made available to the Event Organiser where necessary to:
- verify your Ticket;
- manage attendance;
- contact you concerning the Event;
- administer refunds;
- provide Event-related services; or
- comply with legal obligations.
Event Organisers are responsible for handling personal information they receive through Pàdé lawfully.
6. Payment Providers
Pàdé may use authorised or appropriately regulated payment providers to process transactions.
Your payment information may therefore be processed by those providers under their own privacy notices and security controls.
Pàdé may receive transaction information necessary to confirm payment; issue Tickets; reconcile transactions; process refunds; manage disputes; and administer payouts.
7. Information Sharing
We may share information with:
- Event Organisers;
- payment processors;
- banks and financial institutions;
- Ticket verification providers;
- cloud hosting providers;
- communications providers;
- analytics providers;
- fraud-prevention services;
- professional advisers;
- auditors;
- regulators;
- law-enforcement authorities where legally required; and
- companies involved in a merger, acquisition or restructuring.
Pàdé does not sell personal information merely as a source of advertising revenue.
8. International Transfers
Some technology and service providers used by Pàdé may operate outside Nigeria or Ghana.
Where personal information is transferred across borders, Pàdé will take reasonable steps to ensure that the transfer is conducted in accordance with applicable data-protection requirements.
9. Data Retention
We retain information for as long as reasonably necessary for:
- providing the Services;
- maintaining transaction records;
- resolving disputes;
- preventing fraud;
- satisfying accounting requirements;
- complying with legal obligations;
- enforcing agreements; and
- protecting our legitimate business interests.
When information is no longer required, we may securely delete, anonymise or otherwise dispose of it.
10. Cookies
Pàdé may use cookies and similar technologies to keep users signed in; remember preferences; understand Platform usage; improve performance; maintain security; and measure marketing effectiveness.
You may be able to control cookies through your browser settings. Disabling certain cookies may affect Platform functionality.
11. Data Security
Pàdé uses reasonable technical and organisational measures designed to protect personal information against unauthorised access; loss; alteration; disclosure; destruction; and misuse.
No internet-based system can be guaranteed to be completely secure.
You should protect your password and notify us immediately if you believe your account has been compromised.
12. Data Breaches
Where Pàdé becomes aware of a personal-data breach, we will assess the incident and take steps required by applicable law, including notifying relevant regulators or affected individuals where legally required.
13. Your Privacy Rights
Depending on the jurisdiction applicable to you, you may have rights including:
- access to personal information;
- correction of inaccurate information;
- deletion or erasure where legally available;
- restriction of processing;
- objection to certain processing;
- withdrawal of consent;
- data portability where applicable; and
- the right to complain to the relevant data-protection authority.
These rights may be subject to lawful limitations.
14. Nigeria
For users and processing activities subject to Nigerian law, Pàdé will operate with regard to the Nigeria Data Protection Act 2023 and applicable regulations, guidance and requirements of the relevant data-protection authority.
Where required, Pàdé will provide appropriate mechanisms for exercising data-subject rights and handling privacy complaints.
15. Ghana
For users and processing activities subject to Ghanaian law, Pàdé will operate with regard to the Data Protection Act, 2012 (Act 843) and applicable requirements of Ghana's Data Protection Commission.
16. Children
Pàdé is not designed to knowingly collect unnecessary personal information from children.
Where an Event is intended for children, the Event Organiser is responsible for ensuring that appropriate parental, guardian and consent requirements are met.
Where Pàdé becomes aware that information has been collected unlawfully from a child, we may take steps to delete the information where appropriate.
17. Marketing Communications
Where permitted by law, Pàdé may send transaction confirmations; Ticket information; Event updates; security notifications; service announcements; and promotional communications.
You may opt out of non-essential marketing communications.
You cannot opt out of essential transactional or security communications necessary to provide the Services.
18. Third-Party Links
Pàdé may contain links to websites or services operated by third parties.
We are not responsible for the privacy practices of those third parties.
You should review their privacy notices before providing information to them.
19. Event Photography and Media
Events may be photographed, filmed or livestreamed by Event Organisers or authorised third parties.
The Event Organiser is responsible for providing appropriate notices and obtaining permissions where required.
Where Pàdé independently collects imagery for its own promotional purposes, it will do so in accordance with applicable law and its legitimate operational practices.
20. Changes to This Privacy Policy
Pàdé may update this Privacy Policy when the Platform changes; new services are introduced; legal requirements change; technology changes; or our privacy practices change.
The revised version will indicate its updated date. Where required by law, we will provide additional notice or obtain consent.
21. Privacy Complaints
If you believe Pàdé has mishandled your personal information, contact us first so that we can investigate and attempt to resolve the matter.
Pàdé Privacy Team, NovelDRAW Creative, 763, Abubakar Usman, Jabi, FCT, Abuja, Nigeria.
Privacy Email: privacy@letspade.com
Where applicable, you may also contact the relevant national data-protection authority.
22. Contact Information
Pàdé — a service product of NovelDRAW Creative, Nigeria.
Operational Office: 763, Abubakar Usman, Jabi, FCT, Abuja, Nigeria.
General: hello@letspade.com
Support: support@letspade.com
Privacy: privacy@letspade.com
Legal: legal@letspade.com