Privacy Policy

1. INTRODUCTION

Damascus Projects & Services ("Damascus Projects," "we," "us," or "our," and "ourselves") respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, disclose, protect, and otherwise process personal data when you:

• visit our website;
• download or use the Damascus Projects application;
• create or maintain an account;
• subscribe to our services;
• participate in live video streams;
• communicate with other users;
• upload business information, presentations, videos, or other content;
• use our investor-business-owner introduction services;
• apply for or enquire about our visa financing programme;
• contact our support team; or
• otherwise interact with Damascus Projects.

This Privacy Policy is intended to comply with the Nigeria Data Protection Act 2023 (NDP Act) and other applicable data-protection laws and regulations.

The NDP Act requires personal data to be processed in a fair, lawful, and transparent manner and establishes rights for individuals whose personal data is processed.

By using Damascus Projects, you acknowledge that you have read and understood this Privacy Policy.

2. WHO WE ARE

Damascus Projects & Services is a technology and services company operating from Nigeria.

Our principal platform, Damascus Projects, is designed to facilitate introductions and communication between individuals, business owners, entrepreneurs, companies, institutions, and potential investors.

The platform may provide features including:

• investor and business-owner profiles;
• business/project presentations;
• video prototypes;
• live video streaming;
• investor live-streaming sessions;
• requests to join live sessions;
• private communications;
• messaging;
• notifications;
• subscriptions; and
• other tools designed to facilitate introductions and communication between users.

Damascus Projects does not make investment decisions on behalf of users merely because they use the platform. Users are responsible for their own decisions and interactions after an introduction has been made.

Our separate visa-financing program may provide financing to eligible applicants for certain costs associated with visa-related processes. Damascus Projects does not itself process visas, provide immigration services, or act as a recruitment agency unless expressly stated otherwise in a particular service.

3. INFORMATION WE COLLECT

Depending on how you use our services, we may collect the following categories of information.

3.1 Information You Provide Directly

When you register for an account, subscribe, contact us, or use our services, we may collect:

• full name;
• username;
• email address;
• telephone number;
• country of residence;
• nationality or other information where necessary for a particular service;
• profile photograph;
• date of birth or age information where necessary;
• business name;
• business description;
• business sector;
• business location;
• information about your project or business;
• information contained in your presentations or videos;
• investor preferences;
• communication preferences;
• subscription information;
• information submitted when requesting support; and
• other information you voluntarily provide.

We will seek to limit collection to information reasonably necessary for the purpose for which it is collected.

4. BUSINESS AND PROJECT INFORMATION

If you use Damascus Projects to present a business, project, or business idea, you may provide information such as:

• business descriptions;
• products and services;
• business plans;
• photographs;
• videos;
• financial or operational information;
• funding requirements;
• business location;
• business contact information; and
• other information you choose to make available through the platform.

You should carefully consider what information you publish publicly or make available to other users.

5. INFORMATION COLLECTED AUTOMATICALLY

When you access our website or application, we may automatically collect technical and usage information, including:

• IP address;
• device type;
• operating system;
• browser type;
• application version;
• device identifiers;
• approximate location information;
• login information;
• pages or features accessed;
• date and time of activity;
• referring website or application;
• network information;
• crash reports;
• performance information; and
• other technical information necessary to operate and secure our services.

We may use this information to maintain, secure, analyze, and improve our platform.

6. LIVE VIDEO, AUDIO, AND COMMUNICATION FEATURES

Damascus Projects may provide live-streaming, video, audio, chat, and communication features.

Depending on the feature used, information may include:

• your profile information;
• live video;
• audio;
• messages;
• comments;
• interaction with other users;
• participation in live sessions;
• recordings or other content where the relevant feature permits recording; and
• technical information associated with the communication.

Some information may be visible to other users when you voluntarily participate in a public or semi-public feature.

Users should therefore assume that information voluntarily presented during a public live stream or publicly accessible profile may be viewed by other users.

Where a particular live-streaming feature is recorded, we will provide appropriate notice where required by applicable law.

7. INFORMATION FROM OTHER USERS

We may receive information about you from other users.

For example, another user may:

• invite you to a live session;
• communicate with you;
• submit a complaint concerning an interaction with you;
• report content associated with your account; or
• provide information necessary to investigate suspected misuse of our platform.

We may process such information for safety, security, dispute resolution, compliance, and legitimate business purposes.

8. HOW WE USE PERSONAL DATA

We may use personal data for the following purposes:

A. Providing our services

To:

• create and manage accounts;
• provide access to platform features;
• facilitate introductions;
• enable communication between users;
• operate live-streaming services;
• display user profiles;
• provide notifications;
• administer subscriptions; and
• provide customer support.

B. Improving the platform

We may use information to:

• understand how users interact with our services;
• improve functionality;
• develop new features;
• troubleshoot technical problems;
• monitor performance; and
• improve user experience.

C. Safety and security

We may process information to:

• prevent fraud;
• detect abuse;
• investigate suspicious activity;
• protect users;
• enforce our Terms of Use;
• prevent unauthorized access;
• protect our systems; and
• investigate violations of our policies.

D. Legal and regulatory compliance

We may process and disclose information where necessary to:

• comply with applicable law;
• respond to lawful requests from competent authorities;
• establish, exercise, or defend legal claims;
• protect our legal rights;
• investigate suspected unlawful activity; or
• comply with regulatory requirements.

E. Communications and marketing

Where permitted by applicable law, we may use your contact information to send:

• service notifications;
• account-related communications;
• security alerts;
• information about changes to our services;
• newsletters;
• promotional information; and
• other communications relevant to Damascus Projects.

Where consent is required, we will seek appropriate consent.

You may unsubscribe from promotional communications at any time.

9. LAWFUL BASIS FOR PROCESSING

Depending on the circumstances, we may process personal data on one or more lawful bases recognized by applicable Nigerian data-protection law, including:

• your consent;
• performance of a contract or steps taken at your request before entering into a contract;
• compliance with a legal obligation;
• protection of vital interests where applicable;
• performance of a task carried out in the public interest where applicable; or
• legitimate interests, where permitted by law and where those interests are not overridden by your rights and freedoms.

The particular lawful basis may depend on the nature and circumstances of the processing.

10. USER-GENERATED CONTENT

When you upload, publish, stream, or otherwise provide content through Damascus Projects, you remain responsible for the content you provide.

Depending on the feature and your settings, content may be accessible to other users.

You should not upload personal information belonging to another person unless you have a lawful basis or appropriate permission to do so.

We may remove or restrict content that violates our Terms of Use, Community Guidelines, applicable law, or the rights of others.

11. INVESTOR AND BUSINESS-OWNER INTRODUCTIONS

Damascus Projects is designed to facilitate introductions between users.

If you create a profile or submit business/project information for the purpose of being introduced to another user, we may make relevant information available to that user.

For example, information may be made available to a potential investor where you have chosen to present your business or project through the platform.

Similarly, information about an investor may be made available to a business owner where the investor has chosen to participate in a relevant platform feature.

12. VISA FINANCING PROGRAMME

Damascus Projects may operate a separate visa-financing programme.

If you apply for or enquire about this programme, we may collect additional information necessary to assess and administer your application.

Such information may include:

• identity information;
• contact information;
• information relating to your proposed visa or travel process;
• education or employment information where relevant;
• financial information necessary to assess financing eligibility;
• information concerning repayment arrangements; and
• documents or information reasonably necessary to administer the programme.

We will only request information reasonably necessary for the relevant purpose.

Damascus Projects does not itself process immigration applications or visas merely because it provides financing. Where an independent visa, immigration, educational, or other service provider is involved, information may be shared with that provider where necessary and lawful to provide the requested service.

13. PAYMENTS

Where you make payments to Damascus Projects, payment information may be processed by our payment service providers.

Depending on the payment method used, we may receive information such as:

• payment status;
• transaction reference;
• amount paid;
• date of payment;
• payment method;
• billing information; and
• limited information relating to the payment transaction.

Where possible, sensitive payment-card information is processed directly by authorised payment processors rather than stored by Damascus Projects.

We may retain transaction information where required for accounting, legal, fraud-prevention, dispute-resolution or regulatory purposes.

14. COOKIES AND SIMILAR TECHNOLOGIES

Our website and application may use cookies, software development kits, pixels, local storage, and similar technologies.

These technologies may be used to:

• keep users signed in;
• remember preferences;
• improve website functionality;
• understand how our services are used;
• analyse performance;
• improve security; and
• support relevant communications or advertising where applicable.

Where required, we will provide appropriate cookie notices and choices.

You may be able to control cookies through your browser or device settings.

Disabling certain cookies may affect the functionality of some parts of our website.

15. SHARING PERSONAL DATA

We do not sell your personal data merely because you use Damascus Projects.

We may, however, disclose personal data where reasonably necessary to operate our services.

Recipients may include:

Service providers

Companies that provide services such as:

• cloud hosting;
• data storage;
• payment processing;
• analytics;
• communications;
• email delivery;
• customer support;
• cybersecurity;
• identity or fraud-prevention services;
• technical infrastructure; and
• application or website services.

Other users

Where necessary to provide the platform's introduction and communication functions, information that you choose to make available may be accessible to other users.

Professional advisers

We may disclose information to lawyers, auditors, accountants, insurers, and other professional advisers where reasonably necessary.

Government and regulatory authorities

We may disclose information where required or permitted by applicable law.

Business transactions

If Damascus Projects is involved in a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, personal data may be transferred as part of that transaction, subject to applicable legal requirements.

16. INTERNATIONAL DATA TRANSFERS

Because Damascus Projects may serve users internationally and may use service providers located outside Nigeria, personal data may be processed or stored outside Nigeria.

Where personal data is transferred internationally, we will take reasonable steps to ensure that the transfer is carried out in accordance with applicable Nigerian data-protection requirements and appropriate safeguards.

17. DATA SECURITY

We take reasonable technical and organizational measures designed to protect personal data against:

• unauthorised access;
• unlawful processing;
• accidental loss;
• destruction;
• alteration;
• disclosure; and
• other forms of misuse.

Security measures may include access controls, authentication, encryption where appropriate, monitoring, secure infrastructure, and internal procedures.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your account credentials and should notify us promptly if you believe your account has been compromised.

18. DATA RETENTION

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• provide our services;
• maintain account records;
• comply with legal obligations;
• resolve disputes;
• enforce agreements;
• prevent fraud and abuse;
• maintain security; and
• establish, exercise, or defend legal claims.

When personal data is no longer reasonably required, we will take appropriate steps to delete, anonymize, or otherwise securely dispose of it, subject to applicable legal or regulatory requirements.

19. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and any relevant limitations, you may have rights including:

• the right to be informed about how your personal data is processed;
• the right to request access to personal data we hold about you;
• the right to request correction of inaccurate or incomplete information;
• the right to request deletion of personal data in appropriate circumstances;
• the right to request restriction of certain processing;
• the right to object to certain processing;
• the right to withdraw consent where processing is based on consent;
• the right to data portability where applicable;
• the right to lodge a complaint concerning the processing of your personal data; and
• rights relating to certain automated decision-making or profiling where applicable.

These rights are not absolute and may be subject to lawful exceptions.

20. HOW TO EXERCISE YOUR RIGHTS

To exercise your privacy rights or make a privacy-related request, contact us using the details provided below.

We may need to verify your identity before completing certain requests in order to protect your information from unauthorized access.

We will endeavor to respond to valid requests within the period required by applicable law.

If you are dissatisfied with our response, you may have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another competent data-protection authority, as applicable.

21. CHILDREN'S PRIVACY

Our services are not intended to encourage children to provide personal information without appropriate legal authority or parental/guardian involvement where required.

Where applicable law requires parental or guardian consent for the processing of a child's personal data, we will take appropriate steps to obtain or verify such consent.

If you believe that a child has provided personal data to us in circumstances where such collection was not appropriate, please contact us.

22. THIRD-PARTY WEBSITES AND SERVICES

Our website or application may contain links to websites, applications, or services operated by third parties.

We are not responsible for the privacy practices of third-party websites or services.

You should review the privacy policies of third parties before providing them with personal information.

23. THIRD-PARTY SERVICE PROVIDERS

Some functions of our platform may depend on third-party technology providers.

These providers may process personal data on our behalf and may be subject to contractual, technical, and organizational requirements designed to protect personal data.

We will take reasonable steps to select service providers that provide appropriate safeguards for personal data.

24. ACCOUNT CLOSURE AND DELETION

You may request closure or deletion of your account, subject to applicable law and legitimate retention requirements.

Closing your account may not immediately result in the deletion of all information where we are legally required or otherwise permitted to retain certain records.

Information that you have previously made available to other users may also have been viewed, copied, or otherwise retained by those users independently of Damascus Projects.

25. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• changes in our services;
• changes in technology;
• changes in applicable law;
• regulatory guidance; or
• changes in our data-processing practices.

When we make material changes, we may provide notice through our website, application, email, or other appropriate means.

The "Last Updated" date at the beginning of this Privacy Policy indicates when the policy was most recently revised.

26. DATA BREACHES

We maintain procedures designed to identify, assess, and respond to personal-data security incidents.

Where a personal-data breach occurs, we will take appropriate steps in accordance with applicable law, including assessing the breach and making notifications to regulators and/or affected individuals where legally required.

27. ACCOUNTABILITY

Damascus Projects is committed to implementing privacy and data-protection principles in the design, development, and operation of its services.

We will take reasonable measures to ensure that employees, contractors, and service providers who handle personal data understand their responsibilities concerning confidentiality and data protection.

Where required by applicable law, Damascus Projects will designate or engage an appropriate Data Protection Officer or other qualified privacy professional.

28. CONTACT US

For questions, complaints, requests, or concerns concerning this Privacy Policy or the processing of your personal data, please contact:

29. REGULATORY AUTHORITY

The relevant Nigerian data-protection regulator is the:

Nigeria Data Protection Commission (NDPC)

Damascus Projects recognizes the importance of the Nigerian data-protection framework and its role in protecting the privacy rights of individuals.

30. ACCEPTANCE

By using the Damascus Projects website, application, or services, you acknowledge that you have had the opportunity to review this Privacy Policy.

Where applicable law requires consent for a particular processing activity, we will seek that consent separately or through an appropriate mechanism.

This Privacy Policy should be read together with our:

• Terms of Use
• Cookie Policy
• Community Guidelines
• Acceptable Use Policy
• Business Listing Rules
• Video Content Rules
• Complaint Policy
• Subscription and Refund Policy

Last Updated: 16th November 2025
Damascus Projects & Services