Privacy Policy

This Privacy Policy explains how Starbiss LTD, operator of Cominy, handles your personal information.

Effective Date: September 1, 2026

This Privacy Policy explains how Starbiss LTD, operator of Cominy ("Cominy", "Starbiss", "we", "us", or "our"), collects, uses, stores, shares, and protects personal information when you use Cominy.

Cominy provides a digital marketplace, community features, campaigns and tasks, payment and payout features, bill payments and VTU services, and other related services.

By using Cominy, you acknowledge the practices described in this Privacy Policy.

1. Who Controls Your Information

Cominy is operated by:

Starbiss LTD Federal Republic of Nigeria

For the purposes of applicable data-protection laws, Starbiss LTD is generally the data controller responsible for determining how and why your personal information is processed.

You can contact us about privacy through the official support or privacy contact channels published on Cominy.

2. Information We Collect

The information we collect depends on how you use Cominy.

Account Information

We may collect:

name;
username;
email address;
telephone number;
date of birth;
country and location information;
profile photograph;
account preferences; and
other information you provide when creating or managing your account.

Identity Verification Information

Cominy requires identity verification and may collect:

your full legal name;
government-issued identification number;
photograph or scan of your government-issued ID;
information contained on your identification document;
live selfie or video selfie;
facial verification information;
liveness verification results; and
information generated during the verification process.

Your facial or biometric-related information may be used to confirm that you are a real person and to compare your live image with the photograph on your identification document.

Identity verification may be performed by Cominy or an approved third-party identity-verification provider.

Transaction and Payment Information

When you buy or sell products, participate in campaigns, receive earnings, make withdrawals, or use payment services, we may collect:

transaction details;
purchase and sales history;
payment method information;
bank or payout details;
transaction references;
account balances;
refund and chargeback information; and
related financial records.

Payment card or banking information may be collected or processed directly by our payment partners rather than stored directly by Cominy.

Bill Payment and VTU Information

When you use Cominy to purchase airtime, data, electricity, television subscriptions, internet services, or other supported bill-payment services, we may process information such as:

telephone number;
meter number;
customer or account number;
decoder or smart-card number;
service provider;
selected package;
transaction amount;
payment status; and
transaction history.

We may share information necessary to process the transaction with the relevant bill-payment provider, aggregator, telecommunications company, utility provider, or payment processor.

Marketplace and Activity Information

We may collect information about how you use Cominy, including:

products you buy or sell;
campaigns or tasks you participate in;
submissions and rewards;
searches;
products you view or save;
reviews and recommendations;
public posts and content;
reports and disputes; and
interactions with features on Cominy.

Device and Technical Information

When you access Cominy, we may automatically receive information such as:

IP address;
device type;
browser type;
operating system;
device identifiers;
session information;
login activity;
approximate location derived from your IP address;
crash and performance information; and
security and fraud-prevention signals.

3. How We Use Your Information

We may use personal information to:

create and manage your account;
verify your identity;
prevent impersonation and fraud;
process purchases and sales;
deliver digital products;
process payments, earnings, refunds, and withdrawals;
provide bill-payment and VTU services;
operate campaigns, tasks, and rewards;
provide customer support;
resolve disputes;
secure accounts and transactions;
detect fraud, abuse, or violations of our policies;
personalise and improve Cominy;
provide relevant products, content, campaigns, or recommendations;
communicate important account or transaction information;
send marketing communications where permitted;
maintain legal and financial records;
comply with applicable laws and regulatory obligations; and
establish, exercise, or defend legal claims.

We will not use identity documents or biometric verification information for unrelated advertising or marketing purposes.

4. Our Legal Bases for Processing

Depending on the circumstances, we process personal information because:

it is necessary to provide Services you request or perform our agreement with you;
you have provided consent;
processing is necessary to comply with a legal obligation;
processing is necessary for our legitimate interests or those of another party, provided your rights do not override those interests;
processing is necessary to prevent fraud, protect users, or maintain platform security; or
another lawful basis permitted by applicable law applies.

Where sensitive personal information, including biometric information, requires specific consent or another special lawful basis, we will comply with the applicable requirements.

Where consent is relied upon, you may withdraw that consent, subject to legal and operational limitations.

5. Identity and Biometric Information

Your physical ID, identification number, selfie, facial image, and liveness information are particularly sensitive.

We use this information primarily to:

verify your identity;
determine whether an ID belongs to you;
perform liveness checks;
prevent account duplication and impersonation;
prevent fraud;
secure payments and withdrawals;
meet applicable compliance requirements; and
investigate suspicious activity.

Cominy may send this information to an approved identity-verification provider that performs verification on our behalf.

Where possible, we may receive only a verification result or limited verification information instead of retaining all information generated by the verification provider.

We do not sell your biometric information.

6. How We Share Information

We do not sell your personal information to advertisers.

We may share information when reasonably necessary with:

Service Providers

Companies that help us operate Cominy, including providers of:

identity and liveness verification;
payment processing;
payouts and banking services;
VTU and bill payments;
cloud hosting;
authentication;
communications;
security and fraud prevention;
analytics; and
customer support.

These providers may only receive information reasonably necessary for their role and are subject to applicable contractual and legal obligations.

Sellers, Buyers and Other Users

Certain information may be shared with another user where necessary to facilitate a transaction or feature.

For example, sellers may receive limited information necessary to manage an order or provide purchased access.

Information you choose to make public, such as your username, profile, product listings, posts, reviews, or public activity, may be visible to other users.

Legal and Regulatory Authorities

We may disclose information where reasonably necessary to:

comply with applicable law;
respond to lawful requests;
prevent or investigate fraud;
protect users;
enforce our agreements;
establish or defend legal claims; or
cooperate with regulators, courts, financial institutions, or law-enforcement authorities.

Business Transfers

If Cominy or Starbiss LTD undergoes a merger, acquisition, financing, restructuring, or sale of all or part of the business, personal information may be transferred as part of that transaction, subject to applicable law.

7. International Data Transfers

Some of our service providers or technology infrastructure may be located outside Nigeria.

This means your personal information may be processed or stored in another country.

Where personal information is transferred outside Nigeria, we will take reasonable and legally required steps to ensure an appropriate level of protection, including using recognised transfer mechanisms and contractual safeguards where required.

8. How Long We Keep Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, regulatory, accounting, fraud-prevention, dispute-resolution, and security requirements.

Retention periods may vary depending on the type of information.

For example:

ordinary account information may generally be retained while your account remains active;
transaction records may be retained for longer periods to meet financial, tax, dispute, and legal obligations;
identity-verification records may need to be retained after account closure for fraud prevention, compliance, or legal purposes; and
information associated with an investigation or dispute may be retained until the matter is resolved and applicable retention requirements expire.

Where information is no longer required, we will delete, anonymise, or securely dispose of it as appropriate.

9. Security

We use reasonable technical and organisational safeguards designed to protect personal information against unauthorised access, disclosure, alteration, destruction, loss, or misuse.

These measures may include access controls, encryption where appropriate, secure authentication, monitoring, restricted employee access, security testing, and safeguards imposed on service providers.

No online service can guarantee absolute security.

You are also responsible for keeping your account credentials and devices secure.

If you believe your account or personal information has been compromised, contact us immediately.

10. Cookies and Similar Technologies

Cominy may use cookies, local storage, pixels, and similar technologies to:

keep you signed in;
maintain security;
remember preferences;
understand how Cominy is used;
measure performance;
improve features; and
support analytics or marketing where permitted.

Some cookies are necessary for Cominy to function.

Where required, we will obtain consent before using optional analytics or advertising technologies.

You may be able to manage cookies through your browser or the privacy controls provided by Cominy.

11. Marketing Communications

We may send you information about Cominy products, features, offers, or opportunities where permitted by law.

You may opt out of eligible marketing communications at any time using the unsubscribe option provided or through available account settings.

You may still receive essential communications relating to security, transactions, payments, policies, account administration, or Services you request.

12. Automated Systems

Cominy may use automated systems to help:

detect fraud;
identify suspicious transactions;
moderate prohibited activity;
rank or recommend content and products;
protect accounts; and
enforce certain platform rules.

Where a decision is based solely on automated processing and produces legal or similarly significant effects, we will provide applicable protections and rights required by law.

13. Your Privacy Rights

Subject to applicable law, you may have the right to:

know whether and how we process your information;
request access to your personal information;
request correction of inaccurate information;
request deletion of certain information;
restrict certain processing;
object to certain processing;
withdraw consent where processing is based on consent;
request portability of eligible information;
object to certain automated decision-making; and
lodge a complaint with the appropriate data-protection authority.

These rights are not absolute. For example, we may need to retain certain information to comply with legal obligations, prevent fraud, maintain transaction records, or establish or defend legal claims.

We may need to verify your identity before processing a privacy request.

14. Closing Your Account

You may request to close your Cominy account.

Closing your account does not necessarily result in immediate deletion of every record associated with you.

We may retain information where reasonably necessary for legal compliance, transactions, refunds, chargebacks, fraud prevention, disputes, security, or other legitimate purposes permitted by law.

Information that we are not required or permitted to retain will be deleted or anonymised according to our retention practices.

15. Users Under 18

Cominy is not intended for users under 18 years of age.

We do not knowingly allow individuals under 18 to create accounts.

If we discover that an underage person has provided personal information in violation of our eligibility requirements, we may restrict the account and delete the information where appropriate, subject to applicable legal retention requirements.

16. Third-Party Services

Cominy may contain integrations or links to third-party services.

Those companies may process information under their own privacy policies and may act independently from Starbiss LTD.

We encourage you to review their privacy practices when using third-party services.

17. Changes to This Policy

We may update this Privacy Policy as Cominy develops, our processing activities change, or legal requirements evolve.

If we make material changes, we will provide reasonable notice through Cominy, email, or another appropriate method.

The current version will always display its effective date.

18. Contact and Complaints

If you have questions about this Privacy Policy, want to exercise your privacy rights, or have concerns about how your information is handled, contact Starbiss LTD through the official privacy or support channels published on Cominy.

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another competent data-protection authority where applicable.

Starbiss LTD Federal Republic of Nigeria

Last updated: 2026-09-01

Privacy Policy

This Privacy Policy explains how Starbiss LTD, operator of Cominy, handles your personal information.

Effective Date: September 1, 2026

Cominy provides a digital marketplace, community features, campaigns and tasks, payment and payout features, bill payments and VTU services, and other related services.

By using Cominy, you acknowledge the practices described in this Privacy Policy.

1. Who Controls Your Information

Cominy is operated by:

Starbiss LTD Federal Republic of Nigeria

For the purposes of applicable data-protection laws, Starbiss LTD is generally the data controller responsible for determining how and why your personal information is processed.

You can contact us about privacy through the official support or privacy contact channels published on Cominy.

2. Information We Collect

The information we collect depends on how you use Cominy.

Account Information

We may collect:

name;
username;
email address;
telephone number;
date of birth;
country and location information;
profile photograph;
account preferences; and
other information you provide when creating or managing your account.

Identity Verification Information

Cominy requires identity verification and may collect:

your full legal name;
government-issued identification number;
photograph or scan of your government-issued ID;
information contained on your identification document;
live selfie or video selfie;
facial verification information;
liveness verification results; and
information generated during the verification process.

Your facial or biometric-related information may be used to confirm that you are a real person and to compare your live image with the photograph on your identification document.

Identity verification may be performed by Cominy or an approved third-party identity-verification provider.

Transaction and Payment Information

When you buy or sell products, participate in campaigns, receive earnings, make withdrawals, or use payment services, we may collect:

transaction details;
purchase and sales history;
payment method information;
bank or payout details;
transaction references;
account balances;
refund and chargeback information; and
related financial records.

Payment card or banking information may be collected or processed directly by our payment partners rather than stored directly by Cominy.

Bill Payment and VTU Information

When you use Cominy to purchase airtime, data, electricity, television subscriptions, internet services, or other supported bill-payment services, we may process information such as:

telephone number;
meter number;
customer or account number;
decoder or smart-card number;
service provider;
selected package;
transaction amount;
payment status; and
transaction history.

We may share information necessary to process the transaction with the relevant bill-payment provider, aggregator, telecommunications company, utility provider, or payment processor.

Marketplace and Activity Information

We may collect information about how you use Cominy, including:

products you buy or sell;
campaigns or tasks you participate in;
submissions and rewards;
searches;
products you view or save;
reviews and recommendations;
public posts and content;
reports and disputes; and
interactions with features on Cominy.

Device and Technical Information

When you access Cominy, we may automatically receive information such as:

IP address;
device type;
browser type;
operating system;
device identifiers;
session information;
login activity;
approximate location derived from your IP address;
crash and performance information; and
security and fraud-prevention signals.

3. How We Use Your Information

We may use personal information to:

create and manage your account;
verify your identity;
prevent impersonation and fraud;
process purchases and sales;
deliver digital products;
process payments, earnings, refunds, and withdrawals;
provide bill-payment and VTU services;
operate campaigns, tasks, and rewards;
provide customer support;
resolve disputes;
secure accounts and transactions;
detect fraud, abuse, or violations of our policies;
personalise and improve Cominy;
provide relevant products, content, campaigns, or recommendations;
communicate important account or transaction information;
send marketing communications where permitted;
maintain legal and financial records;
comply with applicable laws and regulatory obligations; and
establish, exercise, or defend legal claims.

We will not use identity documents or biometric verification information for unrelated advertising or marketing purposes.

4. Our Legal Bases for Processing

Depending on the circumstances, we process personal information because:

it is necessary to provide Services you request or perform our agreement with you;
you have provided consent;
processing is necessary to comply with a legal obligation;
processing is necessary for our legitimate interests or those of another party, provided your rights do not override those interests;
processing is necessary to prevent fraud, protect users, or maintain platform security; or
another lawful basis permitted by applicable law applies.

Where sensitive personal information, including biometric information, requires specific consent or another special lawful basis, we will comply with the applicable requirements.

Where consent is relied upon, you may withdraw that consent, subject to legal and operational limitations.

5. Identity and Biometric Information

Your physical ID, identification number, selfie, facial image, and liveness information are particularly sensitive.

We use this information primarily to:

verify your identity;
determine whether an ID belongs to you;
perform liveness checks;
prevent account duplication and impersonation;
prevent fraud;
secure payments and withdrawals;
meet applicable compliance requirements; and
investigate suspicious activity.

Cominy may send this information to an approved identity-verification provider that performs verification on our behalf.

Where possible, we may receive only a verification result or limited verification information instead of retaining all information generated by the verification provider.

We do not sell your biometric information.

6. How We Share Information

We do not sell your personal information to advertisers.

We may share information when reasonably necessary with:

Service Providers

Companies that help us operate Cominy, including providers of:

identity and liveness verification;
payment processing;
payouts and banking services;
VTU and bill payments;
cloud hosting;
authentication;
communications;
security and fraud prevention;
analytics; and
customer support.

These providers may only receive information reasonably necessary for their role and are subject to applicable contractual and legal obligations.

Sellers, Buyers and Other Users

Certain information may be shared with another user where necessary to facilitate a transaction or feature.

For example, sellers may receive limited information necessary to manage an order or provide purchased access.

Information you choose to make public, such as your username, profile, product listings, posts, reviews, or public activity, may be visible to other users.

Legal and Regulatory Authorities

We may disclose information where reasonably necessary to:

comply with applicable law;
respond to lawful requests;
prevent or investigate fraud;
protect users;
enforce our agreements;
establish or defend legal claims; or
cooperate with regulators, courts, financial institutions, or law-enforcement authorities.

Business Transfers

7. International Data Transfers

Some of our service providers or technology infrastructure may be located outside Nigeria.

This means your personal information may be processed or stored in another country.

8. How Long We Keep Information

Retention periods may vary depending on the type of information.

For example:

ordinary account information may generally be retained while your account remains active;
transaction records may be retained for longer periods to meet financial, tax, dispute, and legal obligations;
identity-verification records may need to be retained after account closure for fraud prevention, compliance, or legal purposes; and
information associated with an investigation or dispute may be retained until the matter is resolved and applicable retention requirements expire.

Where information is no longer required, we will delete, anonymise, or securely dispose of it as appropriate.

9. Security

We use reasonable technical and organisational safeguards designed to protect personal information against unauthorised access, disclosure, alteration, destruction, loss, or misuse.

These measures may include access controls, encryption where appropriate, secure authentication, monitoring, restricted employee access, security testing, and safeguards imposed on service providers.

No online service can guarantee absolute security.

You are also responsible for keeping your account credentials and devices secure.

If you believe your account or personal information has been compromised, contact us immediately.

10. Cookies and Similar Technologies

Cominy may use cookies, local storage, pixels, and similar technologies to:

keep you signed in;
maintain security;
remember preferences;
understand how Cominy is used;
measure performance;
improve features; and
support analytics or marketing where permitted.

Some cookies are necessary for Cominy to function.

Where required, we will obtain consent before using optional analytics or advertising technologies.

You may be able to manage cookies through your browser or the privacy controls provided by Cominy.

11. Marketing Communications

We may send you information about Cominy products, features, offers, or opportunities where permitted by law.

You may opt out of eligible marketing communications at any time using the unsubscribe option provided or through available account settings.

You may still receive essential communications relating to security, transactions, payments, policies, account administration, or Services you request.

12. Automated Systems

Cominy may use automated systems to help:

detect fraud;
identify suspicious transactions;
moderate prohibited activity;
rank or recommend content and products;
protect accounts; and
enforce certain platform rules.

Where a decision is based solely on automated processing and produces legal or similarly significant effects, we will provide applicable protections and rights required by law.

13. Your Privacy Rights

Subject to applicable law, you may have the right to:

know whether and how we process your information;
request access to your personal information;
request correction of inaccurate information;
request deletion of certain information;
restrict certain processing;
object to certain processing;
withdraw consent where processing is based on consent;
request portability of eligible information;
object to certain automated decision-making; and
lodge a complaint with the appropriate data-protection authority.

We may need to verify your identity before processing a privacy request.

14. Closing Your Account

You may request to close your Cominy account.

Closing your account does not necessarily result in immediate deletion of every record associated with you.

We may retain information where reasonably necessary for legal compliance, transactions, refunds, chargebacks, fraud prevention, disputes, security, or other legitimate purposes permitted by law.

Information that we are not required or permitted to retain will be deleted or anonymised according to our retention practices.

15. Users Under 18

Cominy is not intended for users under 18 years of age.

We do not knowingly allow individuals under 18 to create accounts.

16. Third-Party Services

Cominy may contain integrations or links to third-party services.

Those companies may process information under their own privacy policies and may act independently from Starbiss LTD.

We encourage you to review their privacy practices when using third-party services.

17. Changes to This Policy

We may update this Privacy Policy as Cominy develops, our processing activities change, or legal requirements evolve.

If we make material changes, we will provide reasonable notice through Cominy, email, or another appropriate method.

The current version will always display its effective date.

18. Contact and Complaints

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another competent data-protection authority where applicable.

Starbiss LTD Federal Republic of Nigeria

Last updated: 2026-09-01