Privacy Policy

Tobinrin operates a marketplace that connects independent service professionals ("Service Specialists") with customers ("Shoppers") who book in-person, virtual, or hybrid services. The controller of Personal Data processed on the Platform is [Tobinrin Legal Entity Name], a company registered in [Country of Incorporation] with registered office at [Registered Address]. Where a Service Specialist collects or processes Shopper Personal Data for their own purposes, that Service Specialist is an independent controller or joint controller as described in Section 8. This Policy does not apply to third-party websites or services linked from the Platform, each of which has its own privacy practices.

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Shopper" means a user who books services through the Platform.
• "Service Specialist" means an individual or organization offering services through the Platform.
• "Organization" means a business account under which one or more Service Specialists operate, including team members.
• "Content" means data, text, photos, reviews, messages, ratings, gallery items, or other materials submitted to the Platform.
• "Processing" has the meaning given in applicable data-protection laws.

We collect Personal Data that you submit when you:

• Register and set up an account — name, email address, password, role, and any profile details you add such as photo, date of birth, gender, biography, phone number, and address.
• Verify your identity — documents and information required to confirm your identity or, for Organizations, your business registration, processed through our verification partner.
• Create listings or an Organization profile — Organization and service details, including name, logo, website, social links, categories, service areas, availability, pricing, service descriptions, and media.
• Upload Content — images, portfolio items, and other files, along with limited technical metadata.
• Make or receive payments — billing information and the limited payment-method details our payment processor returns to us (such as card brand and the last four digits). We do not store full card numbers.
• Book or manage appointments — booking details, service location, notes, and cancellation reasons.
• Leave reviews, favourites, or ratings — ratings, written reviews, and any photos included.
• Communicate through the Platform — the content of your messages and their context.
• Contact support or submit reports — your enquiry, any attachments, and the content you have reported.
• Subscribe to optional newsletters — your email address.

When you use the Platform, we and our service providers automatically collect:

• Device and technical data — device type, operating system, browser, language, and time zone.
• Log and usage data — IP address, access times, pages viewed, features used, and referring URLs.
• Analytics and performance data — interaction events, session information, and error signals used to diagnose issues and improve the Platform.
• Security signals — information used to detect and prevent fraud, abuse, and unauthorized access.
• Session data — authentication cookies and tokens that keep you signed in.
• Approximate location — derived from your IP address and from any address you provide.

We may receive Personal Data about you from:

• Social login providers you choose to sign in with, which share basic account information with us.
• Payment processors, which provide transaction status, limited card information, settlement information, refund status, and risk signals.
• Identity-verification partners, which provide the outcome of verification checks.
• Messaging providers that facilitate verification of your phone number.
• Business partners and referrers — for example, if another user invites you to join their Organization.

A current list of our service providers is available on our Sub-processors page at [URL].

We use Personal Data to:

1. Operate the Platform — create and maintain accounts, authenticate users, match Shoppers with Service Specialists, surface listings, process bookings, enable messaging, and deliver notifications and service emails.
2. Process payments, payouts, refunds, and chargebacks through our payment processor.
3. Verify identity and prevent fraud, abuse, and misuse.
4. Provide customer support and respond to enquiries.
5. Moderate Content and enforce these policies, including investigating reports and restricting, suspending, or terminating accounts where necessary.
6. Improve the Platform by analyzing usage, testing features, and fixing issues.
7. Personalize your experience based on your stated interests and activity.
8. Send service and, where you have opted in, marketing communications.
9. Comply with law, exercise and defend legal rights, and protect the safety of users and the public.

Where applicable data-protection laws require a legal basis, we rely on:

• Performance of a contract — to service your account, process bookings, and fulfil our Terms.
• Legitimate interests — to operate, secure, improve, and promote the Platform, and to prevent fraud and abuse, balanced against your rights and freedoms.
• Legal obligation — to comply with applicable law, including tax, anti-money-laundering, and consumer-protection rules.
• Consent — for activities such as marketing, certain cookies, and processing of sensitive data where required. You may withdraw consent at any time.
• Vital interests and public interest — in limited circumstances where processing is necessary to protect life or serve a public-interest task.

When a Service Specialist uses the Platform to run their business, they act as an independent controller of the Personal Data they collect from Shoppers to deliver services, maintain service history, or comply with their own obligations. Service Specialists are responsible for complying with applicable data-protection laws in their relationship with Shoppers, including providing their own privacy notice where required and responding to Shoppers' rights requests. Tobinrin provides the tools to help Service Specialists meet those obligations but is not responsible for a Service Specialist's independent use of Personal Data outside the Platform.

We share Personal Data with:

• Other users of the Platform. Your public profile (name, photo, biography and, for Service Specialists, Organization details, listings, reviews, gallery items, and service areas) is visible to other users. When a booking is made, the Shopper and Service Specialist receive the limited Personal Data necessary to complete it.
• Service providers who help us operate the Platform, including payment processing, identity verification, hosting, storage, email delivery, analytics, security, customer support, and mapping. These providers act under written agreements that restrict how they may use Personal Data. A current list is available at [Sub-processors URL].
• Organizations and team members. If you join an Organization, its administrators may access Personal Data about your activity within the Organization.
• Authorities and legal parties when required by law or a valid legal process, or to enforce our rights, investigate fraud, protect user safety, or defend legal claims.
• Business transfers in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our business or assets, subject to safeguards consistent with this Policy.
• With your consent or at your direction.

We do not sell Personal Data.

To protect the Platform, we may require Service Specialists (and, in some cases, Shoppers) to complete identity or business-verification checks. This may involve submitting a government-issued identification document, a selfie for liveness detection, and — for Organizations — business-registration documents. Our verification partner processes this information on our behalf to confirm authenticity and return a verification result. Because these checks support our obligations under anti-money-laundering and similar laws, related records are retained for as long as those obligations require.

Payments are handled through our payment processor. We do not store full card numbers or card-security codes. Our processor provides us with limited information such as card brand, the last four digits, expiry, and a token we can use to charge the same payment method for future transactions, refunds, and no-show fees. Service Specialists who receive payouts provide bank or mobile-money details, which are transmitted to our processor to enable settlement. Our processor's use of your data is governed by its own terms and privacy policy.

The Platform uses location data to help Shoppers find nearby Service Specialists and to help Service Specialists define where they deliver services. This includes addresses and coordinates you provide, service areas defined by Service Specialists, and approximate location derived from your IP address. We do not continuously track your precise device location. You can edit or remove the addresses you have provided from within your profile.

• In-app messaging. Messages you send on the Platform are stored by us and are visible to the sender, the recipient, and, where necessary, our support and moderation teams. Messages may also be disclosed where required to comply with law or to enforce our Terms.
• Service emails. We send booking confirmations, reminders, cancellations, refund notices, invoices, password resets, and verification messages. You cannot opt out of these while you have an active account.
• Marketing communications. We send these only where you have opted in. You can unsubscribe at any time using the link in any marketing email.
• Verification messages. We may send text or messaging-app codes to verify your phone number.
• Push notifications. If you enable them, we may send notifications relating to bookings, messages, and other Platform events. You can disable them in your browser or device settings.

We use cookies, local storage, and similar technologies to keep you signed in, remember your preferences, measure and improve Platform performance, and detect fraud and abuse. Where consent is required by law, we will ask for it the first time you visit the Platform and you can change your choices at any time. You can also manage or block cookies in your browser, but some parts of the Platform may not work properly if you do.

We use analytics and error-monitoring tools to understand how the Platform is used and to diagnose problems. These tools process pseudonymous identifiers, session information, device and browser details, interaction events, and technical error information. We configure these tools to minimize the collection of sensitive information. Where consent is required, you may opt out of non-essential analytics through our cookie-management interface, and we will honour applicable browser-level privacy signals where required by law.

Your Personal Data may be processed in countries other than the one in which you are located, including countries whose data-protection laws differ from yours. Where required by law, we use appropriate safeguards such as Standard Contractual Clauses, recognized adequacy decisions, or equivalent mechanisms to protect Personal Data during cross-border transfers. You can request a copy of the relevant safeguard by contacting us at privacy@tobinrin.com.

We retain Personal Data only for as long as necessary for the purposes described in this Policy, taking into account the nature of the data, the purposes for which it is processed, and the legal or regulatory periods during which we are required or permitted to keep it. In general:

• Account and profile data — kept while your account is active and for a reasonable period afterwards to handle disputes, enforce our Terms, and comply with law.
• Transaction, tax, and identity-verification records — kept for the periods required by applicable tax, accounting, and anti-money-laundering laws, which are typically several years.
• Messages and booking records — kept for the duration of the relationship and a reasonable period afterwards.
• Analytics and error data — kept for limited periods, in aggregated or pseudonymized form where possible.

When retention periods expire, we delete or anonymize the data.

Depending on where you live, you may have rights to:

• Access a copy of the Personal Data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion, subject to legal retention requirements.
• Restrict or object to certain processing.
• Receive your data in a portable format.
• Withdraw any consent you have given.
• Complain to a data-protection authority in your country.

To exercise any of these rights, contact us at privacy@tobinrin.com. We will respond within the timeframes required by applicable law and may need to verify your identity before acting on your request.

We use administrative, technical, and organizational measures designed to protect Personal Data, including encryption in transit, encryption of sensitive data at rest, access controls, monitoring, industry-standard password storage, optional two-factor authentication, and regular security reviews. No system can be guaranteed to be perfectly secure. If we become aware of a breach affecting your Personal Data, we will notify you and any relevant authority as required by applicable law.

The Platform is not directed at children. You must be at least eighteen (18) years old, or the age of majority in your jurisdiction, whichever is higher, to use the Platform. We do not knowingly collect Personal Data from anyone under that age. If you believe a child has provided us with Personal Data, please contact us at privacy@tobinrin.com, and we will take steps to delete it.

Service Specialist profiles, listings, reviews, ratings, and gallery items are public by default and may be indexed by search engines and viewed by anyone, whether signed in or not. Please consider carefully what you include in anything you post publicly. Once Content has been made public, it may be cached, copied, or reposted by third parties outside our control. You can edit or delete Content you have submitted, but we cannot guarantee removal from third-party caches or archives.

We use automated tools for activities such as fraud detection, rate limiting, identity-verification scoring, and personalized discovery. We do not use solely automated decisions that produce legal or similarly significant effects on you without human review. Where an automated decision would have such an effect, you have the right to request human review.

We may update this Policy from time to time. When we make material changes, we will update the effective date above and, where appropriate, notify you through the Platform or by email. Your continued use of the Platform after the changes take effect constitutes acceptance of the revised Policy.

• Nigeria. We comply with the Nigeria Data Protection Act and related regulations.
• EU/EEA and UK. Where the GDPR or UK GDPR applies, we rely on the legal bases described in Section 7 and you may exercise the rights described in Section 18.
• Kenya, Ghana, South Africa, Egypt, and other countries. Users in these jurisdictions may exercise the rights afforded by their local data-protection laws and may lodge complaints with the relevant authority.

If you have questions, concerns, or complaints about this Policy or our handling of your Personal Data, please contact us:

• Email: privacy@tobinrin.com
• General Support: bloom@tobinrin.com