Legal

Privacy Policy

1. Who we are

BELLYACHE LTD (“Bellyache”, “we”, “us” or “our”) is a private company limited by shares, incorporated in Nigeria under the Companies and Allied Matters Act 2020 and registered with the Corporate Affairs Commission (RC 9927050).

We provide technology services, custom software development, websites, mobile applications and digital platforms, IT consultancy, technical support, systems integration and cloud services. We also research and build solutions in artificial intelligence, automation and data analytics, and we develop and publish our own mobile applications, including Sakura.

For the purposes of the Nigeria Data Protection Act 2023 (“NDPA”) and other applicable data protection laws, BELLYACHE LTD is the data controller for the personal data described in this policy.

2. What this policy covers

This policy explains how we collect, use, share and protect personal data when you:

• visit our website at bellyache.tech (the “Website”);
• contact us or engage us for services as a client or prospective client; or
• use mobile applications and digital products published by BELLYACHE LTD, including Sakura (the “Apps”).

Some Apps may have their own privacy notice with more specific details. Where an App has its own notice, that notice applies together with this policy, and it takes priority if the two conflict.

When we build software for a client, the client is usually the data controller for its end users’ data, and we act as a data processor on the client’s instructions. In that case, the client’s privacy policy governs that data.

3. Personal data we collect

Information you give us

• Contact and enquiry details: your name, email address, phone number, company name and the content of your message when you contact us by email, phone or the contact form on our Website.
• Client and project information: business contact details, project requirements, and billing and invoicing details when you engage us for services.
• App account information: where an App lets you create an account, details such as your name, email address, username and profile information you choose to provide.
• Support requests: information you share when you ask us for help or report a problem.

Information collected automatically

• Technical data: IP address, browser type, device type, operating system, and pages visited, with dates and times. This is collected through standard server logs kept by our hosting provider.
• App usage and diagnostic data: crash reports, performance data and basic usage information that help us keep the Apps working and improve them, where an App collects this.

Cookies: our Website does not use advertising or tracking cookies. If we introduce analytics or other cookies in future, we will update this policy and, where required, ask for your consent.

We do not knowingly collect sensitive personal data, such as health, religious or biometric data, unless an App clearly requires it for a feature you choose to use. In that case we will ask for your explicit consent first.

4. How we use your personal data, and our legal basis

We do not sell your personal data. We do not use your personal data for automated decision-making that has legal or similarly significant effects on you.

5. Who we share personal data with

We share personal data only where necessary, with:

• Service providers who help us operate our business, such as website hosting, cloud infrastructure, email, and crash-reporting or analytics tools. They process data only on our instructions and must keep it secure.
• App distribution platforms, such as the Apple App Store, which process data under their own privacy policies when you download or buy an App.
• Professional advisers, such as lawyers, accountants and auditors, under confidentiality obligations.
• Authorities, where required by law, regulation, court order or lawful request, or to protect our rights, users or the public.
• A buyer or successor, if our business or assets are reorganised, merged or sold, subject to equivalent protections.

6. International transfers

Some of our service providers may store or process data outside Nigeria, for example on cloud servers located abroad. Where this happens, we transfer personal data only as permitted by the NDPA. This means, for example, to countries with adequate data protection, under appropriate contractual safeguards, or with your consent.

7. How long we keep personal data

We keep personal data only for as long as we need it for the purposes above:

• Enquiries that do not lead to a project: up to 2 years after our last contact.
• Client and contract records: for the duration of the engagement, and for up to 6 years afterwards for legal, tax and accounting purposes.
• App account data: for as long as your account is active. When you delete your account, we delete or anonymise your data within a reasonable period, unless we are required to keep it by law.
• Server logs: for a short period, normally no more than 90 days, unless needed to investigate a security incident.

8. How we protect personal data

We use appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure and alteration. These include encrypted connections (HTTPS), access controls, and using reputable service providers. No method of transmission or storage is completely secure, but we work to protect your data and will respond promptly to any security incident as required by law.

9. Your rights

Under the NDPA, you have the right to:

• be informed about how we process your personal data;
• request access to, and a copy of, your personal data;
• ask us to correct inaccurate or incomplete data;
• ask us to delete your data, where we have no lawful reason to keep it;
• restrict or object to certain processing, including processing based on legitimate interests and direct marketing;
• withdraw your consent at any time, where we rely on consent; this does not affect processing carried out before you withdrew it;
• receive your data in a structured, commonly used and machine-readable format (data portability); and
• not be subject to decisions based solely on automated processing that significantly affect you.

To exercise any of these rights, email us at onario@bellyache.tech. We may need to verify your identity before acting on your request. We will respond within the time required by law.

If you are not satisfied with how we handle your personal data, you may complain to the Nigeria Data Protection Commission (NDPC). We would appreciate the chance to address your concerns first, so please contact us before you do.

10. Deleting your App account and data

Where an App lets you create an account, you can delete your account from within the App, where that option is available, or by emailing onario@bellyache.tech from the email address linked to your account. Deleting your account removes your personal data as described in section 7.

11. Children’s privacy

Our Website and services are aimed at businesses and adults. Our Apps are not directed at children under 13, and we do not knowingly collect personal data from them. If you believe a child has given us personal data, contact us and we will delete it. Where an App is intended for users under 18, we will get parental consent where the law requires it.

12. Third-party links and services

Our Website and Apps may contain links to, or integrations with, third-party websites and services. We are not responsible for their privacy practices, and we encourage you to read their privacy policies.

13. Changes to this policy

We may update this policy from time to time. When we do, we will change the “Last updated” date above. If the changes are significant, we will give notice on our Website or in the relevant App.

14. Contact us

If you have any questions about this policy or how we handle your personal data, contact us:

© 2026 BELLYACHE LTD. All rights reserved. Registered in Nigeria — RC 9927050.