Privacy Policy
Draft for review — not yet in effect. Effective date to be announced.
1. Who is responsible for your data
PROVENIER INNOVATION LIMITED, a company registered in Nigeria, is the data controller for Provenance. Our registered address, our privacy contact and our Data Protection Officer will be published here before this policy takes effect, together with whether we need a representative in the EU. For general help, write to help@provenier.com.
This policy applies to Provenance on the web, the Android and iOS apps and the desktop app. Our first market is Nigeria; members elsewhere, including in the EU and UK, are covered too.
Provenance is for people aged 18 and over. We do not knowingly collect data from anyone younger.
2. What we collect and why
What
Examples
Why we use it
Legal basis
Account
Name, e-mail, password (stored hashed), confirmation that you are 18+, sign-in method, passkeys, two-factor settings
Create and secure your account
Contract
Sign-in security
IP address, device/browser description, sign-in attempts, session records
Keep accounts safe, stop abuse
Legitimate interest (security)
Profile and work
Username, photo, bio, skills, seniority, projects, roles, applications, tasks, contributions, evidence links, vouches, collaborator tags
Provide the service; build your verified record
Contract
Credibility and gamification
Credibility %, points, level, streak, league position
Show your standing and progress
Contract
Messages and calls
Direct messages, project chat, reactions, files, call times and participants, whether you are online
Let you communicate
Contract
Community
Posts, replies, ideas, votes, reports
Run the community
Contract
Proficiency tests (where your workspace uses them)
Answers, timings, integrity signals (leaving the test window, pasting, a device change on resume), optional webcam snapshots (web only)
Assess skills fairly; detect cheating
Contract; webcam snapshots only with your consent
Partner verification
Organisation legal name, registration number, documents
Verify organisations
Legitimate interest; legal obligation where applicable
Payments
Plan, seats, amounts, card brand and last four digits, a card token from Flutterwave, payment-provider notifications (which include the payer's e-mail)
Take payment for seats
Contract
Notifications
Preferences, device push tokens, delivery records
Send the notifications you choose
Contract
Usage (our own records)
Which features you use and when, errors the app hit, searches with no results
Run, secure and improve Provenance; measure retention; choose reminder wording
Legitimate interest
Google Firebase Analytics (optional)
Screen views and app interactions, an app-instance ID, your user ID
Understand how the apps are used
Your consent — off until you choose "Allow"
Connected accounts
GitHub login and ID; Google account ID
Link tools and credit your work
Contract
Where the basis is contract, we need the data to provide Provenance; without it you cannot use that part of the service. Where the basis is consent, you can withdraw it at any time, as easily as you gave it; withdrawing does not affect what happened before.
3. Who can see what
- Other members in your workspace see your profile, your public contributions and what you post.
- Project leads and members see your activity in their project.
- People you send a share link to can view your profile without signing in. A named link expires (7, 30, 90 or 365 days; 90 by default) and can include contributions you have marked private. You can revoke links at any time.
- Recruiters and partners in your workspace can search members and view their profiles, including credibility (shown to them as "Reliability"). Contact through Provenance is mediated.
- Workspace administrators see usage analytics for their workspace, including a per-member activity timeline (last 90 days) and pattern flags such as "at risk of leaving".
- We do not sell your data, and we do not use it for advertising.
4. Service providers and where your data goes
We use these providers to run Provenance. They process data for us under contract:
Provider
What for
Where
Railway
Application servers and databases
To be stated here before this policy takes effect
Cloudflare
Website delivery and security, file storage (R2), sign-in challenge (Turnstile), group-call media server and call relay (Realtime)
Global network
Google Firebase
Push notifications (Cloud Messaging), app configuration (Remote Config), optional analytics
Global Google infrastructure
Flutterwave
Card and bank payments
To be stated here before this policy takes effect
Resend
Sending e-mail
To be stated here before this policy takes effect
Anthropic
AI drafting of proficiency questions and AI grading of code answers
United States
GitHub
Only if your project connects GitHub
United States
The AI drafting and grading currently run through a Claude subscription held by Provenance, under Anthropic’s consumer terms rather than a data-processing agreement. Code you submit in a proficiency test is sent to Anthropic for grading; do not include personal data in it.
Penpot, the design tool, is run by us at design.provenier.org.
Using these providers means your data may be transferred outside Nigeria (and outside the EU, if you are there). The legal basis we rely on for each transfer will be stated here before this policy takes effect.
5. Automated processing and profiling
- Credibility is calculated automatically from verified contributions and the network of people who verified them. It affects how you appear to recruiters.
- Proficiency tests are partly graded automatically, including by an AI model, and integrity signals can flag a result. A person reviews every flagged result; you can see a flag on your own record, and it can be overturned.
- Usage patterns (for example inactivity) are flagged for administrators, and the wording of reminders is chosen automatically based on what members respond to.
None of these on its own makes a decision with legal effect about you. You can object to profiling and ask for a person to look at any automated outcome (section 8).
6. Calls, messages and security
- Calls are encrypted in transit using the standard WebRTC protection (DTLS-SRTP). One-to-one calls go directly between devices where the network allows; otherwise they pass through Cloudflare's relay, which forwards them without decrypting them. Group calls pass through a Cloudflare media server that decrypts and re-encrypts the audio and video in order to route it. Calls are therefore not end-to-end encrypted. We do not record calls.
- Messages are encrypted in transit and stored on our servers so that they appear on all your devices; they are not end-to-end encrypted. There are no read receipts.
- Files are stored privately and served through short-lived signed links.
- We protect your data with access controls, per-workspace data isolation, hashed passwords and encryption in transit.
- If a breach is likely to put you at risk, we will tell the NDPC within 72 hours of becoming aware of it, and tell you promptly if the risk to you is high.
7. How long we keep data
Data
Kept for
Your account and profile
While your account is open, and afterwards as described under "When you delete your account"
Session records
Until the session chain passes its 90-day limit, plus 30 days
Sign-in attempts
90 days
Notifications
Read ones 180 days; deleted ones 30 days; delivery records 90 days
Reminder records
90 days
Payment-provider notifications
90 days
Charge and plan records
To be stated here before this policy takes effect
Usage event log
180 days; aggregated retention figures 400 days
Activity pattern flags
To be stated here before this policy takes effect
Partner verification documents
Deleted 90 days after the decision (the outcome, reviewer and date are kept)
Proficiency webcam snapshots
90 days
Replaced or detached photos and files
Deleted 7 days after they stop being used
Suspension record (keyed hash of e-mail and linked accounts)
24 months
Platform event history and administrator audit log
Kept, for the integrity of verified records and for accountability
Firebase Analytics
To be stated here before this policy takes effect
When you delete your account, you are signed out on every device and the account cannot be used again. Other members' records that include your work keep it, without your name. The period after which the rest of your account data is erased will be stated here before this policy takes effect. We keep the records listed above for their stated periods where we need them for security, fraud prevention or legal compliance.
8. Your rights
Under the Nigeria Data Protection Act 2023 (and the GDPR if you are in the EU) you can:
- find out whether we hold your data, and get a copy of it;
- have it corrected, or deleted;
- restrict how we use it while a request or objection is being dealt with;
- object to processing based on legitimate interest, including profiling;
- withdraw consent at any time (for example Firebase Analytics, under Privacy settings);
- receive your data in a structured, machine-readable format and have it sent to another service;
- not be subject to decisions based solely on automated processing that significantly affect you, and ask for a person to review one.
In the app you can: turn Google Firebase Analytics on or off (Privacy settings), manage notifications and reminders (including one-tap "turn off reminders" on a reminder), revoke share links, and delete your account. For everything else, write to help@provenier.com. Our privacy contact, and the time within which we reply to a request, will be published here before this policy takes effect.
Your right to complain. You can complain to the Nigeria Data Protection Commission (NDPC); its contact details will be published here before this policy takes effect. EU members can complain to their local supervisory authority. We would like the chance to put things right first.
9. Cookies and device storage
- The web app stores your sign-in session in your browser's local storage. This is necessary to keep you signed in.
- Google Firebase Analytics (web and phone) is off until you choose "Allow". On the web its script is not even downloaded until then. Advertising identifiers and ad-personalisation signals are always off.
- Firebase Cloud Messaging and Remote Config use an app-instance identifier to deliver notifications and app settings.
- The desktop app checks for updates.
10. Changes
If we change this policy in a way that matters, we will tell you before the change takes effect and, where the law requires, ask for your agreement again.
11. Contact
help@provenier.com. Our privacy contact, postal address and Data Protection Officer will be published here before this policy takes effect.
Last revised 30 September 2026
© 2026 Provenance · by Provenier