Privacy Policy

1. Who we are and our role

Figo AI Labs is the data controller for personal data we collect through this website, our sales and support activities, our newsletter, and the administration of customer accounts.

When businesses (our “Customers”) deploy FigoChat, MailPilot, FigoHR, FigoVerify, FigoEvents, FigoLearn or our APIs to serve their own customers, employees or candidates, we process that data on the Customer’s behalf as a data processor. In that case, the Customer’s own privacy notice applies, and requests about that data should go to the Customer first. See Data we process for our Customers below.

2. Information we collect

Information you give us

• Enquiries. When you use the “Talk to us” form or contact us, we collect your name, company, work email address, the services you are interested in, and anything you choose to tell us in your message.
• FigoChat conversations. When you chat with the FigoChat assistant on our website, we collect the messages you send, the responses generated, and related metadata such as timestamps and session identifiers.
• Newsletter. If you subscribe, we collect your email address and your subscription preferences.
• Customer accounts and billing. If your organisation becomes a Customer, we collect the business contact details, user account information, billing details and communications needed to provide and manage the Services.
• Events and professional services. Information you share with us in meetings, workshops, consulting engagements and support requests.

Information collected automatically

• Device and log data, such as your IP address, browser type, operating system, referring page, pages viewed, and the date and time of your visit.
• Cookies and similar technologies, as described in the Cookies section below.

Information from third parties

• Security providers, such as Cloudflare Turnstile, which helps us confirm that form submissions come from real people and not automated bots.
• Business partners and public sources, such as professional networking profiles and company websites, to understand the organisations we work with.

Please do not share passwords, card or bank account details, government identification numbers, or health information with us through the website or the FigoChat assistant.

3. How we use your information and our lawful bases

We use personal data only where we have a lawful basis to do so under the NDPA and other applicable law:

• To respond to enquiries and provide demos, and to take steps at your request before entering into a contract (contract and legitimate interests).
• To provide, operate, support and bill for the Services under our agreements with Customers (contract).
• To run the FigoChat assistant on our website, answer your questions and, where you ask, hand your conversation to our team (consent and legitimate interests).
• To send newsletters and marketing about our products and events, which you can opt out of at any time (consent, or legitimate interests for existing business contacts).
• To secure our website and Services, prevent fraud, spam and abuse, and diagnose technical problems (legitimate interests).
• To improve our website and Services, including understanding how visitors use them (legitimate interests or consent, where the law requires it).
• To comply with the law, respond to lawful requests from authorities, and establish, exercise or defend legal claims (legal obligation and legitimate interests).

Where we rely on consent, you may withdraw it at any time. Withdrawing consent does not affect processing that took place before you withdrew it.

4. Artificial intelligence and automated processing

The FigoChat assistant and our products use AI models, some of which are provided by carefully selected third-party AI providers acting as our sub-processors. Your messages are sent to these models only to generate a response and to operate, secure and improve the Services, under contractual terms that restrict how the providers may use that data.

We do not use your website conversations to make decisions that produce legal or similarly significant effects about you based solely on automated processing. Customers that use our products for decisions of that kind are responsible for applying appropriate human oversight and for telling the individuals concerned.

5. Cookies and similar technologies

Cookies are small text files placed on your device. We also use similar technologies such as local storage and scripts. We group them as follows:

When you first visit, we ask whether you want to accept all cookies or reject all cookies. If you reject them, we use only strictly necessary cookies, and the FigoChat assistant will not load. You can change your choice at any time using Cookie settings at the foot of every page, or by clearing cookies in your browser.

6. How we share information

We do not sell your personal data. We share it only as needed for the purposes described in this policy, with:

• Service providers who act on our instructions, including cloud hosting, AI model, email delivery, security, customer support and billing providers;
• Communication channels such as WhatsApp, Instagram, Facebook and email providers, when you or a Customer choose to communicate through them;
• Professional advisers such as lawyers, auditors and insurers, under duties of confidentiality;
• Authorities and regulators, where we are required by law or need to protect our rights, our users or the public;
• A buyer or successor, if we are involved in a merger, acquisition, financing or sale of assets, subject to this policy; and
• Anyone else, with your consent or at your direction.

7. International transfers

Some of our service providers, including cloud and AI model providers, may process personal data outside Nigeria. When we transfer personal data abroad, we do so in line with Part VIII of the NDPA, relying on an adequacy decision, appropriate contractual safeguards such as standard contractual clauses, or another lawful transfer mechanism.

8. How long we keep information

We keep personal data only for as long as we need it for the purposes described in this policy, including:

• enquiries and sales correspondence: for up to 24 months after our last interaction, unless you become a Customer;
• website FigoChat conversations: for up to 12 months, unless needed longer to resolve a request or complaint;
• newsletter data: until you unsubscribe;
• Customer account and billing records: for the duration of the relationship and then for as long as required by tax, accounting and other laws; and
• data we process for Customers: as instructed by the Customer and set out in our agreement with them.

When data is no longer needed, we delete it or anonymise it so that it can no longer identify you.

9. How we protect information

We use technical and organisational measures appropriate to the risk, including encryption in transit, access controls based on least privilege, authentication, logging and monitoring, vendor due diligence, and staff confidentiality obligations. No system is completely secure, but if a personal data breach occurs that is likely to put your rights at risk, we will notify the Nigeria Data Protection Commission and, where required, you, within the timelines set by law.

10. Your rights

Subject to the conditions and exceptions in the law, you have the right to:

• be informed about how your personal data is used, and access a copy of it;
• have inaccurate or incomplete data corrected;
• have your data deleted;
• restrict or object to certain processing, including direct marketing;
• receive your data in a commonly used, machine-readable format and have it transferred to another controller;
• withdraw consent at any time, where we rely on consent;
• not be subject to a decision based solely on automated processing that significantly affects you; and
• complain to the Nigeria Data Protection Commission (ndpc.gov.ng) or to the data protection authority where you live.

To exercise any of these rights, email us at hello@figolabs.ai. We may need to verify your identity before responding. We will respond within the time required by law, and in any case within 30 days. Exercising your rights is free, unless a request is clearly unfounded or excessive.

11. Data we process for our Customers

If you interact with a business that uses FigoChat or another of our products (for example, by messaging your bank or insurer on WhatsApp), that business decides how your data is used, and we process it only on their instructions under a data processing agreement. Please contact that business to exercise your rights. If you contact us instead, we will forward your request to them where we can.

12. Children

Our website and Services are intended for businesses and are not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe a child has given us personal data, please contact us and we will delete it.

13. Third-party websites

Our website may link to third-party websites and social media pages, such as LinkedIn, X, Instagram and TikTok. We are not responsible for their privacy practices, and we encourage you to read their privacy policies.

14. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and change the effective date above. If we make material changes, we will take reasonable steps to let you know, for example by a notice on our website or by email.

15. Contact us

If you have any questions about this policy or how we handle your personal data, or wish to reach our Data Protection Officer, please contact us:

• Figocard Limited (trading as Figo AI Labs), Lekki, Lagos, Nigeria
• Email: hello@figolabs.ai
• Phone: +234 802 145 6086

Please also read our Terms and Conditions.