Legal
Data Processing Agreement
Details about how user data is processed and handled in compliance with privacy regulations.
Last updated Jun 2026
Data Processing Agreement (DPA)
Effective Date: 26th June, 2026. This Data Processing Agreement ("Agreement") forms part of the Terms of Service between Substak Limited ("Data Controller") and Users of Don't4get ("Data Subject" or "User"). This Agreement governs the processing of personal data in connection with the Don't4get application ("Service").
1. Definitions
Personal Data means any information relating to an identified or identifiable individual using the Service. Data Controller means Substak Limited, which determines the purposes and means of processing personal data. Data Processor means third-party service providers engaged by Substak Limited to process data on its behalf (e.g., cloud hosting, analytics, notification services). Processing means any operation performed on personal data, including storage, retrieval, transmission, or deletion.
2. Scope of Processing
Substak Limited processes personal data strictly for the purpose of operating the Don't4get application, including: creating and managing user accounts, storing and delivering reminders, sending notifications and alerts, maintaining system performance and security, providing customer support, and debugging, analytics, and service improvement.
3. Categories of Data Processed
Depending on usage, the following categories may be processed: identity data (name, email, phone number if provided), account credentials (hashed authentication data), reminder content (titles, notes, schedules), device and technical data (OS, device model, IP address), usage and analytics data (feature interactions, timestamps), and notification delivery data. We do not intentionally process sensitive special categories of data.
4. Purpose of Processing
Data is processed solely for: providing core app functionality, delivering scheduled reminders and notifications, maintaining service stability and security, improving performance and user experience, and complying with legal obligations. No processing occurs for unrelated commercial resale purposes.
5. Legal Basis for Processing
Processing is carried out under the following lawful bases: contractual necessity (to deliver the core Service), legitimate interest (for security, fraud prevention, and service improvement), consent (where required for optional features such as analytics or marketing), and legal obligation (compliance with applicable laws and regulations).
6. Data Processor Engagement
Substak Limited may engage third-party processors including cloud hosting providers (e.g., AWS, Google Cloud, Firebase), push notification services (e.g., FCM, APNs), analytics providers (for performance monitoring), and error tracking and debugging tools. All processors are required to process data only under documented instructions, maintain strict confidentiality, implement appropriate security measures, and not use personal data for independent purposes.
7. International Data Transfers
Personal data may be transferred outside the User's country of residence. Where such transfers occur, Substak Limited ensures appropriate safeguards including standard contractual clauses or equivalent mechanisms, use of reputable global infrastructure providers, and security and encryption standards aligned with NDPR and GDPR principles.
8. Security Measures
Substak Limited implements appropriate technical and organizational measures, including encryption in transit (TLS/HTTPS), secure database storage, access control and authentication systems, role-based internal access restrictions, and regular monitoring and security updates. Despite these measures, absolute security cannot be guaranteed.
9. Data Retention
Personal data is retained only as long as necessary: active accounts are retained during service usage; deleted accounts are removed within 30–90 days; reminder data is deleted upon account deletion or prolonged inactivity; and logs and analytics are retained for up to 90 days for operational purposes. After retention periods, data is securely deleted or anonymized.
10. Data Subject Rights
Users have the right to: access personal data, request correction of inaccurate data, request deletion of data, request data portability, withdraw consent (where applicable), and object to certain processing activities. Requests can be submitted to hellosubstak@gmail.com. Identity verification may be required before processing requests.
11. Confidentiality
All personnel and processors handling personal data are bound by confidentiality obligations and are restricted from unauthorized disclosure or use.
12. Sub-Processing
Substak Limited may engage sub-processors. We ensure that sub-processors are subject to equivalent data protection obligations, users are informed of material changes where required, and sub-processors do not process data beyond defined purposes.
13. Data Breach Notification
In the event of a personal data breach, Substak Limited will investigate promptly, take steps to mitigate harm, notify affected users where legally required, and notify relevant authorities where applicable (e.g., NDPR compliance requirements).
14. Liability
To the maximum extent permitted by law, Substak Limited is not liable for indirect or consequential damages, and liability is limited to direct damages arising from proven negligence or breach of this Agreement. Users are responsible for maintaining account security.
15. Termination of Processing
Upon termination of the Service or account deletion, processing of personal data will cease, data will be deleted or anonymized unless retention is legally required, and backup data will be purged within a reasonable technical timeframe.
16. Governing Law
This Agreement is governed by the laws of the Federal Republic of Nigeria.
17. Amendments
Substak Limited may update this Agreement periodically. Updated versions will be published in the App or website, and continued use of the Service constitutes acceptance.
18. Contact
For all data protection inquiries: Email: hellosubstak@gmail.com. Company: Substak Limited. Country: Nigeria.