1. Introduction
NeoHouse Creative Technologies Ltd. ("NeoHouse," "Trybb," "we," "us," or "our") operates Trybb, a mobile and web application that combines social networking, user-generated content, communities ("Tribes"), events and ticketing, messaging, reputation scoring, and related features (collectively, the "Platform" or "Services"). This Privacy Policy explains what personal information we collect, how we use, share, retain, and protect it, and the rights and choices available to you.
This Policy applies to all users of Trybb worldwide, including users located in Nigeria, the European Economic Area, the United Kingdom, the United States, and other jurisdictions. Where local law imposes additional or different obligations, the section applicable to that jurisdiction shall govern for users in that jurisdiction, without limiting the general protections described elsewhere in this Policy.
By creating an account, accessing, or using Trybb, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, please do not use the Platform.
2. Company Information
Trybb is owned and operated by NeoHouse Creative Technologies Ltd., a company incorporated under the laws of the Federal Republic of Nigeria, with its registered office at Plot 145 Haz Ewendi Street, Kuje, Abuja. For all privacy-related matters, you may contact our Data Protection Officer / privacy team at hello@neohouse.tech.
3. Scope of This Policy
This Policy applies to personal information processed through the Trybb mobile applications, website, application programming interfaces, and any related services that link to this Policy. It does not apply to third-party websites, applications, or services that Trybb may link to, or to information collected by organizers, vendors, or other users independently of the Platform, whose own privacy practices are their own responsibility.
4. Definitions
- "Personal Information" means any information relating to an identified or identifiable natural person.
- "Processing" means any operation performed on personal information, including collection, storage, use, disclosure, or deletion.
- "User Content" means any content, including text, images, video, audio, reviews, and event listings, submitted by a user to the Platform.
- "Tribe" means a community or group feature within Trybb.
- "Reputation Score" means the trust or engagement score computed by Trybb based on user activity.
- "Data Controller" and "Data Processor" have the meanings given under applicable data protection law, including the NDPA and GDPR.
5. Categories of Personal Information We Collect
We collect the following broad categories of information, described in greater detail in the sections that follow: identity and contact data; account credentials; profile and biographical data; content you create or upload; social and community data; location data; device and technical data; usage and analytics data; communications and messages; event and ticketing data; payment and transaction data; and information from third parties.
5.1 Information You Provide to Us
When you register for or use Trybb, you may provide us with information such as your name, username, email address, phone number, date of birth, gender, profile photo, biography, interests, and any other information you choose to add to your profile. If you contact customer support, you may provide additional information relevant to your inquiry.
5.2 Information Collected Automatically
We automatically collect certain information when you use the Platform, including log data (IP address, browser type, operating system, referring URLs, pages viewed, and timestamps), crash reports, and diagnostic data.
5.3 Device Information
We collect device identifiers, hardware model, operating system version, unique device tokens used for push notifications, mobile network information, and app version.
5.4 Cookies and Similar Technologies
We and our service providers use cookies, SDKs, pixels, and similar tracking technologies to operate the Platform, remember preferences, authenticate users, and measure performance. Further detail is provided in our separate Cookie Policy, which forms part of this Privacy Policy by reference.
5.5 Analytics
We use analytics providers to understand how users interact with Trybb, including feature usage, session length, and navigation paths, in order to improve the Platform.
5.6 Location Information
With your permission, we collect precise or approximate location data to power features such as nearby events, local Tribes, and location-tagged content. You may disable location sharing at any time through your device settings, though this may limit certain features.
5.7 Event Information
When you create, attend, or express interest in an event, we collect event details, RSVP status, ticket type, and, where applicable, check-in data.
5.8 Messaging Data
We process the content and metadata of messages sent through Trybb's messaging features to deliver the service, detect spam and abuse, and enforce our Terms. We do not sell the content of private messages.
5.9 Uploaded Files, Images, and Video
Files, images, and videos you upload are stored on our servers or those of our cloud service providers and may include embedded metadata (such as EXIF data) unless removed by you or automatically stripped by the Platform.
5.10 Reviews
When you submit a review of an event, vendor, organizer, or another user, we collect the review content, rating, and associated metadata such as the date and the transaction or interaction it relates to.
5.11 Reputation Scores
We compute a Reputation Score based on factors such as account history, verified activity, community feedback, and compliance with our Terms. The methodology may be updated from time to time and is described at a high level in Section 17 (Automated Decision-Making) below.
5.12 Tribes and Community Data
Your membership in, posts within, and interactions with Tribes are collected to operate community features and, where a Tribe is public, may be visible to other users or the public.
5.13 Contacts
If you choose to use a "find friends" or contact-sync feature, we may, with your permission, access and process contact information from your device's address book solely to help you find people you may know on Trybb. We do not use this data for any other purpose and you may revoke this permission at any time.
5.14 Payment Information
Where Trybb offers ticketing, vendor sales, tipping, or subscription features, payment card and bank details are collected and processed by our third-party payment processors. Trybb does not store full payment card numbers on its own servers; we retain only limited transaction metadata (such as amount, date, and status) necessary for order history and support.
5.15 Marketing Preferences
We record your marketing communication preferences, including opt-ins and opt-outs, so that we can honor your choices.
6. Legal Bases for Processing
Where the GDPR, UK GDPR, or similar law applies, we rely on one or more of the following legal bases to process personal information: performance of a contract with you; compliance with a legal obligation; our legitimate interests (such as securing the Platform, preventing fraud, and improving our Services), provided these interests are not overridden by your rights; your consent, where required, such as for certain marketing communications, precise location, or contact syncing; and, in limited circumstances, protection of vital interests.
Under the Nigeria Data Protection Act 2023 ("NDPA"), we process personal information on the basis of consent, contractual necessity, legal obligation, legitimate interest, or as otherwise permitted under the NDPA and guidance issued by the Nigeria Data Protection Commission ("NDPC").
7. How We Use Your Information
We use the personal information described above to:
- Create, maintain, and secure your account;
- Provide, operate, and improve the Platform's features, including Tribes, events, ticketing, messaging, and reputation scoring;
- Process transactions and send related confirmations;
- Personalize content, recommendations, and search results;
- Communicate with you about updates, security alerts, and administrative messages;
- Send marketing communications where you have opted in or as otherwise permitted by law;
- Detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms;
- Comply with legal obligations and respond to lawful requests from public authorities;
- Conduct analytics, research, and product development; and
- Enforce our Terms of Service and other policies.
8. Data Retention
We retain personal information for as long as necessary to fulfil the purposes described in this Policy, including to provide the Platform, comply with legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. Retention periods vary by data category; for example, transaction records may be retained for the period required by applicable financial regulations, while account data is generally retained for the life of the account plus a reasonable period thereafter to address potential claims. Upon expiry of the applicable retention period, we securely delete or anonymize the information.
9. Security Measures
We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction, informed by recognized frameworks such as ISO/IEC 27001, without representing that we hold formal certification unless separately stated. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Encryption
We use industry-standard encryption, such as TLS/SSL, to protect data in transit, and encrypt sensitive data at rest where appropriate, including payment-related tokens handled by our payment processors.
11. Cross-Border and International Transfers
Because Trybb operates internationally, your information may be transferred to, stored, and processed in countries other than your country of residence, including Nigeria and countries where our service providers operate. Where we transfer personal information out of the European Economic Area, the United Kingdom, or other jurisdictions with restrictions on cross-border transfers, we rely on recognized transfer mechanisms, such as Standard Contractual Clauses, adequacy decisions, or equivalent safeguards recognized under the NDPA and NDPC guidance.
12. Third-Party Services and Data Processors
We engage third-party service providers to help us operate Trybb, including cloud hosting providers, payment processors, analytics providers, customer support tools, push notification services, and communication providers. These providers act as data processors on our behalf and are contractually required to use personal information only as instructed by us and to maintain appropriate security measures.
13. Data Sharing
We may share personal information:
- with other users, to the extent you choose to make information public (such as your profile, posts, reviews, and Tribe activity);
- with event organizers and vendors, to the extent necessary to fulfil a ticket purchase or transaction;
- with our service providers described above;
- with professional advisers such as auditors and lawyers;
- in connection with a merger, acquisition, financing, or sale of assets; and
- where required to comply with law.
We do not sell personal information to third parties for their own independent marketing purposes.
14. Government and Law Enforcement Requests
We may disclose personal information in response to valid legal process, such as a court order, subpoena, or lawful request from a competent authority, or where we believe in good faith that disclosure is necessary to protect the rights, property, or safety of NeoHouse, our users, or the public. Where permitted by law, we will attempt to notify the affected user before disclosure. Further detail is set out in our separate Law Enforcement & Government Requests Policy.
15. Your Rights
Subject to applicable law, you may have the right to:
- access the personal information we hold about you;
- request correction of inaccurate information;
- request deletion of your information;
- object to or restrict certain processing;
- request portability of your information; and
- withdraw consent at any time where processing is based on consent.
To exercise these rights, contact us at hello@neohouse.tech. We may need to verify your identity before actioning a request.
15.1 Rights Under the GDPR / UK GDPR
If you are located in the European Economic Area or the United Kingdom, you have the rights described in Section 15 above, as well as the right to lodge a complaint with your local data protection supervisory authority.
15.2 Rights Under the NDPA
If you are located in Nigeria, you have rights under the Nigeria Data Protection Act 2023, including the right to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, and the right to object, and you may lodge a complaint with the Nigeria Data Protection Commission.
15.3 Rights Under the CCPA/CPRA
If you are a California resident, you have the right to know what personal information we collect, use, disclose, and sell (we do not sell personal information as defined by the CCPA); the right to request deletion; the right to correct inaccurate information; and the right to non-discrimination for exercising your privacy rights. You may designate an authorized agent to submit requests on your behalf.
16. Children's Privacy
Trybb is not directed to children under the age of 13 (or the applicable minimum age in your jurisdiction, which may be higher, such as 16 in certain contexts under the GDPR or as specified under the NDPA for processing based on consent). We do not knowingly collect personal information from children below the applicable minimum age. If we learn that we have collected such information, we will take steps to delete it. Parents or guardians who believe their child has provided personal information to us should contact us at hello@neohouse.tech. Further detail is set out in our separate Child Safety Policy.
17. Automated Decision-Making and AI Processing
Trybb may use automated processing, including algorithms and artificial intelligence, to power features such as content recommendations, spam and fraud detection, content moderation, and Reputation Scores. Where such processing produces legal or similarly significant effects on you, you have the right to request human review, to express your point of view, and to contest the decision, in accordance with applicable law. Further detail is provided in our separate AI and Automated Decision-Making Disclosure.
18. Breach Notification
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify affected users and, where required, the relevant supervisory authority (such as the NDPC or an EEA supervisory authority) without undue delay and in accordance with applicable law.
19. Do Not Track and Similar Signals
Some browsers transmit "Do Not Track" signals. Because there is no accepted industry standard for responding to such signals, Trybb does not currently respond to them, but you can control tracking technologies through the mechanisms described in our Cookie Policy and your device settings.
20. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated Policy with a revised "Effective Date" and, where changes are material, provide additional notice, such as an in-app notification or email. Your continued use of Trybb after the effective date of an update constitutes acceptance of the revised Policy.
21. Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:
NeoHouse Creative Technologies Ltd. Plot 145 Haz Ewendi Street, Kuje, Abuja, Nigeria Email: hello@neohouse.tech
For product support, contact: support@trybb.app
If you are not satisfied with our response, you may have the right to lodge a complaint with the Nigeria Data Protection Commission, your local EEA/UK supervisory authority, or other applicable regulator.