Privacy Policy
In accordance with the Nigeria Data Protection Act (NDPA) 2023, VL TECH LIMITED informs users (“the Users”) about the processing of their personal data, the lawful basis for such processing, the methods through which personal data may be collected, the purposes for which it is used, and the rights available to Users under applicable Nigerian data-protection laws.
IDENTIFICATION OF THE DATA CONTROLLER AND CONTACT DETAILS
Data Controller: VL TECH LIMITED (hereinafter, the “Company” or the “Controller”)
Registered Address: 33 Chief Hilary Street, Uyo, Uyo, Akwa Ibom state, Nigeria
Registration Status: Private limited liability company incorporated in Nigeria and registered with the Corporate Affairs Commission (CAC) under the Companies and Allied Matters Act 2020 (CAMA)
RC Number:8892252
Email: admin@recollyai.com
Support Contact: admin@recollyai.com
SCOPE, CONTEXT AND DEFINITIONS
This Privacy Policy outlines the practices of VL TECH LIMITED (hereinafter referred to as “the Controller,” “we,” “us,” or “our”) regarding the processing of personal data.
This Policy applies to personal data collected and processed across all our digital products, services, and communication channels. This includes, but is not limited to, Recolly AI, an AI-powered WhatsApp assistant designed to help Users set reminders, manage tasks, and receive automated notifications.
We process data through the following platforms and channels:
a) Recolly AI Services: All conversational, AI-enabled, and automated assistants currently operated by the Controller;
b) Web Properties: Websites, web applications, and online platforms owned or operated by us, including those used for accessing or managing Recolly AI;
c) Management Interfaces: Administrative dashboards, portals, or interfaces provided to Users, agents, or authorized personnel; and
d) Official Communication Channels: All official communication avenues used by us, including email, WhatsApp, SMS, telephone support, and online contact forms.
For the purposes of this Policy, a “User” refers to any natural person who accesses, interacts with, or communicates with VL TECH LIMITED via Recolly AI or any related digital service, platform, or channel.
PURPOSES OF DATA PROCESSING
The Company processes personal data for the following purposes:
1. Management of enquiries and pre-contractual relations
Responding to User requests, questions, or support needs.
2. Provision, Operation, and Support of Digital Services
The Controller processes personal data as necessary to deliver, maintain, and improve its digital products and services, including Recolly AI. This includes activities such as enabling core service functionality, facilitating user interactions, supporting automated or AI-driven features, ensuring accurate service performance, and providing technical or customer support when required.
3. Corporate communications
Sending updates regarding service improvements or relevant notices.
4. Statistical processing
Aggregated analysis to improve service quality and system performance.
5. Own commercial communications (subject to consent)
Newsletters, product updates, promotions, and marketing content.
6. Recruitment processes (if applicable)
Handling applicant data and evaluating candidates.
7. Regulatory compliance, security, and fraud prevention
Ensuring system integrity and fulfilling legal obligations.
PERSONAL DATA PROCESSED AND SOURCES OF DATA
Sources
The Controller may obtain personal data from various sources, including:
Information voluntarily provided by the User through any communication channel or platform operated by the Controller.
Data generated or captured automatically through the User’s interaction with the Controller’s digital services, including AI-enabled features.
Information produced, inferred, or derived as part of the operation, enhancement, or maintenance of the Controller’s services.
Technical data, system logs, and metadata made available by service providers, integration partners, or technology platforms used to deliver the Controller’s services.
Categories of Data (depending on interaction)
Identifying Data
Phone number (required for WhatsApp)
Name or display name
Contact Data
Email address (optional)
WhatsApp profile information
Message and Service Information
Information you provide through your interactions, such as messages and details needed to create or manage reminders, along with related system records used to deliver the service.
Technical & Connection Data
IP address (web or dashboard use)
Device/browser identifiers
Logs, timestamps, system metadata
WhatsApp message delivery metadata
Economic Data
Payment method details (processed by external PCI-compliant providers)
Subscription information
Optional Additional Data
User preferences
Any other information the User voluntarily provides
VL TECH LIMITED applies strict data minimization: only data necessary for service provision are collected.
LEGAL BASIS FOR PROCESSING
Purpose
Legal Basis
User contact and management
Pre-contractual measures / Legitimate interest
Service provision, maintenance, and support
Contract performance
Handling of rights, complaints, and claims
Legal obligation / Legitimate interest
Information and commercial communications
User consent
Regulatory compliance and fraud prevention
Legal obligation / Legitimate interest
Statistical processing (aggregated)
Legitimate interest
AI-based message interpretation
Contract performance
ARTIFICIAL INTELLIGENCE AND AUTOMATED DECISION-MAKING
The Controller may integrate third-party artificial intelligence technologies and services into its digital products and platforms. These technologies are leveraged for secure data processing, content analysis, the extraction or inference of relevant data points, output generation, and the delivery of automated or AI-assisted features across all our services.
No decisions are made solely through automated means that produce legal or significant effects on the User.
Users may at any time:
Request human intervention
Ask for explanations regarding AI interpretations
Challenge or correct AI-generated suggestions
AI usage complies with applicable data protection standards.
STATISTICAL PROCESSING
VL TECH LIMITED may process data in an aggregated and anonymized manner to:
Generate analytics
Improve service performance
Optimize system behavior
This processing excludes any personal or identifiable data.
DATA RETENTION PERIODS
Data Category
Retention Period
Service provision data
Retained only as needed for service provision and subsequently minimized or deleted
Subscription/account data
As long as the User maintains an active account
Customer support messages
Up to 24 months
Anonymized analytics
Indefinitely
Legal and compliance records
As required by applicable law
Users may request deletion of their data at any time, subject to legal retention requirements.
DATA DISCLOSURE TO THIRD PARTIES
VL TECH LIMITED does not disclose data to third parties unless:
Required for service provision
Required by law
Based on User consent
Necessary to protect vital interests or legitimate rights
Data Processors
The Controller may rely on processors who act under documented instructions:
Cloud hosting and storage providers
WhatsApp Business API providers
AI model providers (e.g., OpenAI)
Payment processors
Customer support and communication tools
Security, analytics, and monitoring services
All processors are bound by confidentiality and data protection agreements.
Third-Party Disclosures
We may disclose your personal data to specific third parties and service providers to facilitate our operations and provide the services you request. These disclosures are made strictly in accordance with applicable data protection laws and for legitimate business purposes.
Categories of recipients include:
Financial Processors: Payment service providers and financial institutions involved in billing and transaction processing.
Regulatory & Public Authorities: Government bodies and law enforcement agencies, when disclosure is legally required or necessary to comply with a legal obligation or court order.
Communication Platforms: Messaging infrastructure providers, such as WhatsApp Ireland Limited and Meta Platforms, Inc., which enable the delivery of our conversational services. See Whatsapp Privacy Policy
Technology Providers: AI and machine learning providers. See ChatGPT privacy policy
International Data Transfers
When the provision or use of VL TECH LIMITED’s services involves communication channels, infrastructure, or third-party providers located outside the Federal Republic of Nigeria, the Controller ensures that any transfer of personal data fully complies with the Nigeria Data Protection Act 2023 (NDPA) and any applicable subsidiary legislation.
Such transfers may occur when external service providers (including messaging platforms or cloud technology partners) process or route data through jurisdictions outside Nigeria. In these specific cases, VL TECH LIMITED implements appropriate safeguards recognized under Nigerian data protection law. These safeguards may include:
Adequacy Decisions: Transfers to jurisdictions deemed adequate by the Nigeria Data Protection Commission (NDPC).
Appropriate Safeguards: The implementation of robust data transfer agreements, such as Standard Contractual Clauses (SCCs), or other approved mechanisms that ensure an adequate level of protection for Users’ personal data.
Users may consult the publicly available privacy and data-transfer policies of third-party platforms they choose to interact with through our services. The use of such external communication channels is voluntary, and Users may opt out or discontinue their use at any time.
Use of WhatsApp involves transfers according to WhatsApp’s own privacy policies.
DUTY OF CONFIDENTIALITY AND SECURITY
We treat all information provided by Users with strict confidentiality and employ robust technical and organizational security measures to prevent unauthorized access, loss, or misuse of personal data. The Controller periodically reviews its providers and maintains stringent internal access controls to ensure proper information protection and data integrity.
Security Disclaimer and Limitation of Liability:
Despite our diligent efforts and the implementation of substantial security measures, the absolute security of data transmitted over the internet or stored electronically cannot be guaranteed. The User acknowledges that they interact with our services and third-party platforms at their own risk.
VL TECH LIMITED disclaims liability for:
Losses resulting from factors outside our direct control, including third-party platform failures (e.g., WhatsApp outages).
Unauthorized access or data breaches resulting from the User’s misuse of the service or failure to maintain the security of their own devices and credentials.
In the event of a high-risk data incident or breach, affected Users and relevant authorities will be notified in accordance with applicable data protection laws.
USER WARRANTIES WHEN PROVIDING DATA
Users declare that:
All personal data provided are true, accurate, and up to date
They are at least 18 years old
They have lawful rights to provide data of third parties (if applicable)
They will not submit excessive or sensitive data unless expressly required
Users are solely responsible for incorrect, incomplete, or false information.
USER RIGHTS
Users have the following rights in relation to their personal data:
Access – to be informed of what personal data is being processed and how it is used.
Rectification – to correct or update any inaccurate or incomplete data.
Erasure – to request deletion of personal data when it is no longer necessary or where processing is unlawful.
Restriction – to limit or suspend the processing of personal data in certain circumstances.
Data Portability – to receive a copy of their personal data in a structured, commonly used, and machine-readable format, or request its transfer to another controller.
Objection – to challenge or oppose processing based on legitimate interests, except where otherwise permitted by law.
Withdrawal of Consent – to withdraw consent for any optional processing, including marketing communications, at any time, without affecting the lawfulness of prior processing.
Requests may be submitted to:
VL TECH LIMITED
Email: admin@recollyai.com
The Controller will respond within the legally required timeframe (typically one month).
COOKIES AND SIMILAR TECHNOLOGIES
The Website or dashboard may use cookies or analogous technologies to:
Enable essential functionality
Analyze browsing behavior
Improve User experience
Detailed information is available in the Cookies Policy.
CHANGES TO THIS PRIVACY POLICY
VL TECH LIMITED may modify this Privacy Policy when deemed necessary.
Updates will be published through the Website or notified to Users through appropriate channels.
Continued use of the service after updates implies acceptance of the revised Policy unless express consent is required.
Last update: 15 November 2025.
