Privacy Policy

Effective Date: October 8, 2026

INTRODUCTION

This Privacy Policy (“Policy”) explains how Boxer Live (“Boxer Live”, “we”, “us”, or “our”) collects, uses, stores, shares, and protects your personal data when you access or use the Boxer Live platform, including our website, mobile applications, and related services (collectively, the “Platform”). By using the Platform, you acknowledge that you have read and understood this Policy and agree to the practices described herein.

This Policy forms part of our Terms of Use.

DEFINITIONS

For purposes of this Policy:

2.1 “Personal Data” means any information relating to an identified or identifiable natural person.

2.2 “Processing” means any operation performed on personal data, including collection, storage, use, disclosure, or deletion.

2.3 “Data Subject” means an individual whose personal data is processed.

2.4 “Controller” refers to Boxer Live, which determines the purposes and means of processing.

2.5 “Processor” means and third party that processes personal data on our behalf.

3. LEGAL AND REGULATORY COMPLIANCE

This Privacy Policy is designed to comply with:

Nigeria Data Protection Act 2023

Nigeria Data Protection Regulation (NDPR)

General Data Protection Regulation (EU GDPR), where applicable

Other applicable international data protection and privacy laws

4. PERSONAL DATA WE COLLECT

We collect the following categories of personal data:

4.1 Identity Data

Includes full name, username, date of birth, gender, and government-issued identification.

Contact Data

Includes email address, phone number and residential address

Account Data

Includes login credential, account preferences and profile information

4.4 Financial Data

Includes bank account information, payment card data (processed via third-party providers), and transaction history. Boxer Live does not store complete card numbers.

4.5 Technical Information

Includes IP address, device information, operating system, browser type, and log files.

4.6 Usage Data

Includes content viewed, streams participated in, and interactions with features on the Platform.

4.7 KYC and Verification Data

Includes identity documents, verification selfies, facial embeddings, verification results, and proof of address. Our face-data practices are explained in Sections 4.8, 8.1, 10.1, 10.2, 12.4, and 13.1.

4.8 Face Data and Verification

When you complete face verification to obtain access to streaming, the app processes camera frames to detect your face position and head orientation and captures a verification selfie. Boxer Live collects the submitted selfie and retains a facial embedding associated with verification. A facial embedding is a numerical representation of facial features used to compare faces; it remains face data even though it is not a photograph.

Our current verification process is reviewed manually by Boxer Live. We use verification selfies and facial embeddings to verify users, support authentication and access to streaming, and identify attempts to create another account using the same face. Retained embeddings are also used to prevent automatic registration of a new account after account deletion. A returning user must contact support@boxer.live and obtain manual approval before being allowed to create or access another account.

We plan to integrate Esectra for passive liveness checks and age verification. This integration is not currently active, and Boxer Live does not currently send verification face data to Esectra. Before activating this integration, we will update this Policy to explain the face data sent to Esectra and its processing, storage, sharing, and retention practices.

5. HOW WE COLLECT PERSONAL DATA

We collect data through:

Direct interactions—information you provide during registration, form submissions, or communications.

Automated technologies—cookies, analytics tools, and interaction logs.

Third-party sources—payment processors, identity verification providers, and analytics partners.

6. PURPOSE AND LAWFUL BASES FOR PROCESSING

We process your Personal Data for the following purposes:

Contract Performance

To create and manage your account, provide Platform services, process payments, and verify your identity.

Legal Obligations

To comply with Anti-money laundering laws (AML), fraud prevention, and regulatory compliance requirements.

Legitimate Interests

To improve Platform performance, ensure security, prevent fraud, and enhance user experience.

Consent

For marketing communications and any processing requiring your explicit consent. You may withdraw consent at any time through your account settings or by contacting us.

7. AUTOMATED DECISION-MAKING

We may use automated systems for fraud detection, identity verification, and risk assessment to maintain Platform security. These systems do not produce legal or similarly significant effects without human oversight.

8. DATA SHARING

We may share Personal Data with:

Cloud hosting and infrastructure providers

Payment processors

Identity verification partners

Regulatory authorities

Legal and professional advisors

Parties involved in mergers, acquisitions, or corporate restructuring

All third-party processors are bound by strict confidentiality and data protection obligations.

8.1 Face Data Sharing

Verification face data is processed by Boxer Live and its storage and hosting infrastructure providers. Selfies are stored in Boxer Live's Cloudflare R2 storage, and verification records and facial embeddings are stored in our database infrastructure. These infrastructure providers process the data to supply storage and hosting services. Our current verification review is performed manually by Boxer Live; Esectra is a planned provider and does not currently receive this data.

9. INTERNATIONAL DATA TRANSFERS

Your data may be transferred outside Nigeria. Where this occurs, we implement legally-recognized safeguards such as:

Standard Contractual Clauses (SCCs)

Jurisdictional adequacy decisions

Encryption and secure transfer protocols

10. DATA RETENTION

We retain Personal Data only as long as necessary for service delivery, regulatory compliance, fraud prevention, or as permitted by law. The specific retention practices for verification selfies and facial embeddings, including retention after account deletion, are set out below.

10.1 Verification Selfie Retention and Deletion

We retain verification selfies for as long as your account remains active because they support verification and authentication for streaming. After you delete your account, we retain your verification selfie for up to one month to help prevent immediate registration of another account using the same face. We delete the retained verification selfie at the end of that period.

10.2 Facial Embedding Retention After Account Deletion

Deleting your account or verification selfie does not automatically delete your facial embedding. We retain the embedding after account deletion to detect attempts to register another account using the same face and to require manual approval for returning users. This retention currently has no fixed expiry date. You may contact support@boxer.live to request deletion of your retained face data or to object to its continued retention. Such requests are considered subject to applicable law; a request to return to the Platform is handled separately through manual review.

11. DATA SECURITY

We implement technical and organizational safeguarding measures such as:

Encryption

Firewalls

Access controls

Monitoring systems

Although we strive to protect your data, it is important to know that no system is entirely secure.

12. DATA STORAGE LOCATION 12.1 Boxer Live stores and processes personal data using secure, enterprise‑grade cloud infrastructure. Our Platform is hosted on reputable cloud service providers such as Amazon Web Services (AWS) or equivalent providers that offer industry‑standard security, redundancy, and compliance certifications.

12.2 All data is stored in encrypted form, both at rest and in transit, and may be hosted in data centers located within or outside Nigeria. Where data is stored or processed outside Nigeria, Boxer Live ensures that such locations maintain adequate data protection standards in line with the Nigeria Data Protection Act (NDPA), NDPR/NDPB requirements, and the GDPR.

12.3 We ensure that any international data storage or processing is protected through legally recognized safeguards, including Standard Contractual Clauses (SCCs), jurisdictional adequacy decisions, or other approved mechanisms that guarantee a level of protection consistent with applicable data protection laws.

12.4 Verification selfies are stored in Boxer Live's Cloudflare R2 object storage. Verification records and facial embeddings are stored in Boxer Live's database infrastructure. These are server-side records and are not stored solely on your device. The retention periods in Sections 10.1 and 10.2 apply separately to selfies and embeddings.

13. YOUR RIGHTS

Subject to applicable law, you have the right to:

Access your data

Rectify inaccurate data

Request deletion

Restrict processing

Object to processing

Request data portability

These requests may be sent to the designated contact email:

support@boxer.live

13.1 Face Data Requests

To request access to or deletion of your verification selfie or facial embedding, or to object to continued retention, contact support@boxer.live and specify that your request concerns face verification data. Account deletion alone does not remove the retained embedding described in Section 10.2. To request permission to return after account deletion, contact the same address for manual review.

14. COOKIES

We use cookies to enhance user experience and analyse Platform performance. You may disable cookies through your browser settings, though some features may become unavailable.

15. CHILDREN’S PRIVACY

The Platform is not intended for individuals under 18. We do not knowingly collect data from minors.

16. DATA BREACH RESPONSE

If a data breach occurs, Boxer Live will notify regulators and affected users as required by law (Within 72 Hours) and take prompt remedial action.

17. THIRD-PARTY LINKS

The Platform may contain links to third-party websites. We are not responsible for their privacy practices, and users are encouraged to review third-party policies before engaging with their services.

18. CHANGES TO POLICY

We may update this Privacy Policy periodically. Changes become effective upon publication, and we will provide reasonable notice where required.

19. CONTACT INFORMATION

For inquiries or to exercise your rights, please contact our Privacy Officer at:

support@boxer.live