1. Introduction
3 Moon Movement ("the App", "we", "us", or "our") is a civic engagement and constituency accountability platform designed to enable citizens to register, access constituency information, review public commitments, submit requests and complaints, and follow the progress of constituency projects and commitments.
We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, how long we retain it, who may have access to it, and the rights available to you.
2. Data Controller
Data Controller: 3 Moon Movement
Country: Nigeria
Privacy Contact: 3 Moon Movement Privacy Office
Privacy Email: 3mm@threemoonmining.com
General Contact: contact3mm@threemoonmining.com
Where third-party service providers process personal data on our behalf, they may act as data processors and will be required to process personal data in accordance with applicable instructions and safeguards.
3. Information We Collect
Depending on how you use the App, we collect:
- Account information: your name and phone number, which is also used to sign in with a one-time SMS code.
- Registration information: date of birth, residential address, Local Government Area, Ward and Polling Unit, and your occupation (government worker or self-employed).
- Voter information: your Voter Identification Number (VIN) and a photograph of your Permanent Voter Card (PVC). The App reads the polling-unit code, VIN and name printed on the card, on your phone and again on our server (using Google Cloud Vision), to confirm that you are registered in Oriade or Obokun and that your details match the card.
- Employment document: if you register as a government worker, a photograph of your government ID or employment document, used to verify your registration.
- Charter acknowledgement: a record that you accepted the Constituency Accountability Charter, and when.
- Complaints and requests: what you submit, including any description of a location and any photograph you choose to attach.
- Empowerment Programme information (only if you register for it): the part of the programme chosen, the amount indicated, how the support would help you, and your business or trade. For PTI Training, also your exam body (WAEC or NECO), exam year, exam number and a photograph of your result, used to confirm that you studied science and that the result is in your registered name.
- Payment details (only if requested from shortlisted programme participants): bank name, account number and account name.
- Support reports: problems you report to us, together with your app version and phone operating system, to help us fix them.
- Technical information: a notification token if you turn on notifications, and limited information required for security and operation of the App.
The App does not access your contacts, call logs, messages or precise location.
4. Why We Collect Your Information
We process personal data to create and manage accounts; register citizens on the constituency platform; associate registrations with the appropriate constituency; securely process voter identification and employment information where required for verification; provide constituency and accountability services; record acknowledgement of published commitments or a Constituency Accountability Charter; process complaints and requests; administer the Empowerment Programme; send notifications you have chosen to receive; maintain security and audit records; comply with legal obligations; and improve the reliability and functionality of the App.
5. Voter Identification and Employment Information
Your VIN, PVC image and, where applicable, government ID or employment document are treated as sensitive registration information. The App is not an election voting system and does not record your voting choice, voting intention, whom you voted for, or how you voted. Because 3 Moon Movement is a political movement, registering on the App may indicate your support for, or association with, the Movement. This is treated as sensitive personal data (political opinion) under the Nigeria Data Protection Act 2023. By registering, you consent to its processing for the purposes stated in this policy. We do not sell it, do not use it for advertising, and do not share it with anyone outside the Movement's authorised personnel unless the law requires it. This information is collected only for the legitimate purposes stated in the App and subject to applicable law. Each VIN may be registered to only one account. Access to these images is restricted to authorised personnel whose responsibilities require such access.
6. Digital Charter and Acknowledgement
The App may allow you to review and acknowledge a Constituency Accountability Charter containing published commitments, priorities or accountability objectives. Your acknowledgement or signature confirms that you have reviewed and accepted the terms presented to you. It does not constitute a record of your voting intention, a promise to vote for any candidate, or evidence of how you voted.
7. Empowerment Programme and Financial Information
The 3 Moon Empowerment Programme is a programme to be delivered if elected, subject to available constituency funds and the programme's published rules. Registering your interest is not a payment or a guarantee of payment, and it is not linked in any way to how you vote.
Payment details are requested only from shortlisted participants, only when we open payment-details collection, and they are kept separately from your registration. Bank details can be viewed only by our most senior administrators (Super Administrators) and are used only to verify and make programme payments. Once we have verified them, they cannot be changed without contacting us, to protect you against fraud.
8. Access to Information
Access to personal information is restricted according to role and operational necessity. Registration administrators, complaints administrators, project administrators, programme administrators and specifically authorised verification personnel may access only information necessary for their responsibilities. Super Administrators may have broader administrative privileges. Administrative actions, such as approving registrations or updating complaints, are recorded in audit logs.
9. Protection of Identity Document Images
PVC and government ID images uploaded to the App are intended for authorised administrative review only. They are not available through public file links, cannot be downloaded from our administration system, and are displayed with the viewing administrator's name and the time stamped across them. Only Super Administrators, and administrators they specifically authorise, can view them.
10. Data Storage and Security
We use appropriate technical and organisational safeguards including authentication controls, role-based access control, access restrictions, secure cloud infrastructure, encryption in transit, secure database rules, administrative audit logs and secure handling of uploaded documents. Photographs are compressed on your phone before upload. No electronic system can guarantee absolute security, but we will take reasonable measures appropriate to the nature and sensitivity of the information processed.
The optional App Lock uses your phone's own screen lock, fingerprint or face recognition. This is handled entirely by your phone; we never receive or store your fingerprint, face data or phone PIN.
11. Third-Party Service Providers
The App uses Google Firebase (Google LLC) for sign-in by SMS, database services, file storage, server functions and notifications. These providers process personal data on our behalf where necessary to provide the App, subject to appropriate safeguards. We do not sell your personal data, and we do not use it for advertising.
12. Data Retention
We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, satisfy applicable legal or regulatory obligations, resolve disputes, maintain security, or enforce applicable agreements. Voter-document images may be deleted when no longer necessary for their stated purpose, subject to legal or legitimate record-keeping requirements.
13. Deleting Your Account
You can delete your account at any time in the App: open Profile and tap Delete Account. If you cannot use the App, you can request deletion at three-moon.web.app/delete-account.
When your account is deleted, we delete your profile and registration details, your VIN record, your voter's card and government ID images, any payment details, and your login. Complaints and requests you submitted are kept as constituency records with your name and phone number removed. If you were shortlisted for the Empowerment Programme, the programme register keeps your name and VIN as a record of the programme.
14. Your Privacy Rights
Subject to applicable law and lawful limitations, you may have the right to be informed about processing; request access; request correction; request deletion or erasure where appropriate; object to certain processing; request restriction; request data portability where applicable; withdraw consent where processing is based on consent; and lodge a complaint with the relevant data-protection authority.
15. Exercising Your Rights
To exercise your privacy rights, contact the 3 Moon Movement Privacy Office at 3mm@threemoonmining.com. You may also write to 3 Moon Movement Privacy Office, Nigeria. We may need to verify your identity before processing certain requests.
16. Withdrawal of Consent
Where processing is based on your consent, you may withdraw consent by contacting the 3 Moon Movement Privacy Office. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Information may still be retained where required by law or another lawful basis applies. You can turn notifications off at any time in the App under Profile, Notifications.
17. Age Requirement and Children's Privacy
The App is intended only for people aged 18 and over, the voting age in Nigeria. Registration requires a date of birth showing that you are at least 18. We do not knowingly collect personal information from anyone under 18; if we learn that we have, we will delete it.
18. Cookies and Similar Technologies
The App may use technical identifiers and similar technologies necessary to maintain authentication sessions, secure accounts, remember relevant preferences, detect suspicious activity and maintain reliable operation. Optional analytics technologies will be subject to appropriate notice and consent where required.
19. Data Breaches
If we become aware of a personal-data breach, we will assess the incident and take appropriate steps to contain, investigate and remediate it. Where notification to affected individuals or a regulatory authority is required by applicable law, we will make such notification within the applicable timeframe.
20. Where Your Data Is Stored and International Transfers
Your data is stored with Google Cloud in its Johannesburg, South Africa region, the closest available to Nigeria. Some technology providers used by the App may also process information in other countries. Where personal data is transferred outside Nigeria, 3 Moon Movement will take reasonable steps to ensure that the transfer is carried out in accordance with applicable Nigerian data-protection requirements and appropriate safeguards.
21. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to the App, our data-processing practices, applicable law, technology or security requirements. When material changes are made, appropriate notice will be provided through the App or another suitable communication channel.
22. Contact Us
3 Moon Movement Privacy Office
Nigeria
Privacy: 3mm@threemoonmining.com
General: contact3mm@threemoonmining.com
For privacy questions, data-subject requests, complaints, or security concerns relating to personal information processed through the App, please contact the Privacy Office.
23. Complaints to the Data Protection Authority
If you believe that your privacy rights have been violated and your concern has not been adequately resolved, you may have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), the regulatory authority responsible for data protection in Nigeria.
24. Governing Framework
This Privacy Policy is intended to operate consistently with applicable Nigerian data-protection and privacy laws, including the Nigeria Data Protection Act 2023, together with applicable regulations, guidance and lawful requirements issued by relevant Nigerian authorities.