Owambe Fashion

This document governs the use of the Owambe Fashion platform, game, and marketplace by both
individual users and brand or designer partners. Please read it carefully before using our services.

LEGAL NOTICE: This document constitutes a binding agreement between you
and Owambe Fashion. By accessing or using our platform, you confirm that you
have read, understood, and agree to be bound by these terms. If you do not
agree, do not use the platform

What this document covers

Part A — Privacy Policy (Pages 3–8)

Who we are and how to contact us
What data we collect — users
What data we collect — brand and designer partners
How we use your data
Legal basis for processing
Data sharing and third parties
Data retention
Your rights
Cookies and tracking
Children’s data
Cross-border data transfers
Security

Part B — Terms and Conditions (Pages 9–16)

13. Acceptance of terms
14. The Owambe platform — what it is
15. User accounts
16. In-game purchases and digital assets
17. The marketplace — buying physical products
18. Brand and designer partner terms
19. Intellectual property
20. Prohibited conduct
21. Disclaimers and Limitations of Liability
22. Dispute resolution
23. Amendments
24. Governing law

PART A

Privacy Policy

Last updated: April 2026

Owambe Fashion is committed to protecting your personal data. This Privacy Policy explains
what information we collect, why we collect it, how we use it, and what rights you have over it.
It applies to all users of the Owambe Fashion website, game, and marketplace, as well as
brand and designer partners registered on the platform.

This policy is written in compliance with the Nigeria Data Protection Regulation (NDPR) 2019.
the Nigeria Data Protection Act 2023, and, where applicable to users in the European
Economic Area or the United Kingdom, the General Data Protection Regulation (GDPR) and the UK
GDPR

1. Who we are and how to contact us

Owambe Fashion is the data controller for personal data collected through this platform. We
are registered in Nigeria and operate the website owambefashion.com and all associated
game and marketplace services.

Data Protection contact: Owambe Fashion Game Ltd Founder

Email: [email protected]

If you have any questions about how we handle your data or wish to exercise your rights,
please contact us at the above address. We will respond within 7 business days.

2. What data we collect — users

When you create an account or use the Owambe Fashion platform as an individual user, we
may collect the following categories of personal data:

Account data

Full name or display name
Email address
Password (stored in encrypted form — we never see your plain-text password)
Date of birth (used to verify age eligibility)
Country of residence

Profile and gameplay data

Avatar customisation choices and styling preferences
In-game activity, session history, and engagement patterns
Styling challenge entries and competition participation
Wishlist and saved items
User-generated content, including avatar looks shared publicly

Purchase and transaction data

In-app purchase history (digital skins and items)
Marketplace order history (physical products)
Payment method type (we do not store full card numbers; payments are processed by
our third-party payment provider)
Delivery address for physical orders

Technical and device data

IP address
Device type, operating system, and browser or app version
Mobile network and connection type
Game performance data and crash reports
Cookies and similar tracking data (see Section 9)

Communications data

Messages sent to our support team
Survey responses and feedback you choose to provide

3. What data we collect – brand and designer partners

When you register as a brand or designer partner on Owambe Fashion, we collect additional
categories of data relevant to our commercial relationship:

Business identity data

Brand or business name and trading name
Contact person’s full name, title, and email address
Business registration number and country of registration
Tax identification number (where applicable)
Business address

Brand content and catalogue data

Product images, garment descriptions, and collection details were uploaded to the platform
Pricing information and inventory data
Brand logo, assets, and any other intellectual property submitted for use on the
platform

Performance and analytics data

In-game engagement metrics for your brand capsule — views, interactions, wishlist
additions, and styling frequency
Marketplace conversion data — how many in-game interactions resulted in physical
purchases
Revenue and sales data generated through the platform
User demographic data in aggregated, anonymised form — age range, country,
engagement patterns

Financial data

Bank account details for royalty and commission payments
Payment history and invoicing records

Brand partners: the performance and analytics data we collect about how users
engage with your designs is one of the core value propositions of Owambe
Fashion. This data is shared with you in your brand dashboard and belongs to
you in aggregated form. We do not sell individual user data to brand partners.

4. How we use your data

For users, we use your data to:

Create and manage your account
Deliver the game experience, including personalised AI styling recommendations
Process in-app purchases and marketplace orders
Send transactional communications (order confirmations, delivery updates)
Improve game performance, fix bugs, and develop new features
Provide customer support
Detect and prevent fraud, abuse, or violations of our terms
Send marketing communications where you have opted in
Conduct analytics to understand how the platform is used

For brand and designer partners, we use your data to:

Set up and manage your brand account and dashboard
Display your products and designs within the game and marketplace
Process royalty and commission payments
Provide performance analytics and engagement data through your dashboard
Communicate with you about your partnership, new features, and platform updates
Ensure compliance with our brand partner agreement

5. Legal basis for processing

Under the NDPR and GDPR, we must have a lawful basis for processing your personal data.
Our bases are:

Contract: processing necessary to perform our agreement with you — delivering the
game, processing purchases, paying royalties
Legitimate interests: analytics, fraud prevention, platform improvement, and direct
marketing to existing customers (where our interests do not override your rights)
Consent: marketing communications to new contacts, and the use of non-essential
cookies — you may withdraw consent at any time
Legal obligation: where we are required to process data to comply with Nigerian law or
other applicable regulations

6. Data sharing and third parties

We do not sell your personal data. We share data only in the following circumstances:

Service providers

We work with trusted third-party service providers who process data on our behalf under strict
data processing agreements. These include payment processors (Paystack or Flutterwave),
cloud hosting and infrastructure providers, analytics platforms, customer support tools, and
email communications providers.

Brand partners

If you purchase a physical product through our marketplace, your delivery address and order
details are shared with the relevant designer or brand partner to fulfil your order. We share
only what is necessary for fulfilment. We share aggregated, anonymised engagement
analytics with brand partners; we do not share your individual identity with brand partners
without your consent

Legal requirements

We may disclose your data where required by Nigerian law, a court order, or to protect the
rights and safety of Owambe Fashion, our users, or third parties.

Business transfers

In the event of a merger, acquisition, or sale of Owambe Fashion, your data may be
transferred to the acquiring entity. We will notify you before your data is transferred and
becomes subject to a different privacy policy.

7. Data retention

We retain your personal data only for as long as necessary for the purposes set out in this
policy, or as required by law

Active user accounts: data is retained for the lifetime of your account
Inactive accounts: if your account has been inactive for 24 consecutive months, we will
notify you and delete your data within 30 days unless you reactivate it.
Transaction records: retained for 7 years in accordance with Nigerian financial
record-keeping requirements
Brand partner data: retained for the duration of the partnership and 7 years thereafter
for financial and legal records
Support communications: retained for 2 years

8. Your rights

Under the NDPR and applicable law, you have the following rights regarding your personal
data:

Right of access: request a copy of the personal data we hold about you
Right to rectification: ask us to correct inaccurate or incomplete data
Right to erasure: request deletion of your data where there is no legitimate reason for
us to continue processing it
Right to restrict processing: ask us to pause processing your data in certain circumstances
circumstances
Right to data portability: receive your data in a structured, machine-readable format
Right to object: object to processing based on legitimate interests or for direct marketing
Right to withdraw consent: where processing is based on consent, withdraw it at any time without affecting prior processing

To exercise any of these rights, contact us at owambefashion.com. We will respond within 7
business days. You also have the right to lodge a complaint with the Nigerian Data Protection
Commission (NDPC) if you believe we have not handled your data lawfully.

9. Cookies and tracking

Our website and platform use cookies and similar technologies to ensure the platform
functions correctly, remembers your preferences, and understands how users engage with our
content.

Essential cookies

Required for the platform to function. These cannot be disabled. They include session management, login authentication, and security tokens

Analytics cookies

Help us understand how users interact with the platform so we can improve it. We use
anonymised data only. You may opt out through our cookie settings.

Marketing cookies

Used to deliver relevant advertising where you have consented. You may withdraw consent at
any time through our cookie settings or your browser.

You can manage your cookie preferences at any time through the cookie settings link in our
website footer.

10. Children’s data

Owambe Fashion is not directed at children under the age of 13. We do not knowingly collect
personal data from children under 13. If you are between 13 and 17, you may use the platform
only with the consent of a parent or guardian.

If we become aware that we have collected data from a child under 13 without parental
consent, we will delete it promptly. If you believe we have done so, please contact us
immediately.

11. Cross-border data transfers

Owambe Fashion is based in Nigeria. If you access our platform from outside Nigeria —
including from the UK, EU, or other jurisdictions with data protection laws — your data may be
transferred to and processed in Nigeria.

Where we transfer data from the EEA or UK to Nigeria or other countries, we ensure
appropriate safeguards are in place, including standard contractual clauses where required. By
using our platform, you consent to this transfer.

12. Security

We implement appropriate technical and organisational measures to protect your personal
data against unauthorised access, loss, alteration, or disclosure. These include encrypted data
storage, secure HTTPS connections, restricted staff access, and regular security reviews.

No system is completely secure. In the event of a data breach that is likely to result in a risk to
your rights and freedoms, we will notify you and the NDPC as required by law within 72 hours
of becoming aware.

PART B

Terms and Conditions

Last updated: April 2026

These Terms and Conditions govern your access to and use of the Owambe Fashion platform,
including the game, marketplace, and all associated services (collectively, the “Platform”).
Please read them carefully. By creating an account or using the Platform, you agree to be
bound by these terms.

13. Acceptance of terms

By accessing or using the Platform, you confirm that you are at least 13 years of age, that you
have the legal capacity to enter into a binding agreement, and that you have read and agree to
these Terms and Conditions and our Privacy Policy. If you are accepting on behalf of a brand
or organisation, you confirm that you have the authority to bind that entity

14. Owambe platform — what it is

Owambe Fashion is a phygital fashion game and marketplace. It combines an interactive
mobile game in which users dress digital avatars in contemporary African fashion, with a
marketplace that enables users to purchase physical versions of the garments featured in the
game.

The Platform also provides brand and designer partners with a digital storefront, engagement
analytics, and access to a Gen Z African and diaspora audience.

We reserve the right to modify, update, or discontinue any feature of the Platform at any time
with reasonable notice. We will not be liable for any modification, suspension, or
discontinuation of the Platform.

15. User accounts

You must create an account to access most features of the Platform. You are
responsible for maintaining the confidentiality of your login credentials.
You must provide accurate, current, and complete information when registering. You
agree to update your information if it changes.
You are responsible for all activity that occurs under your account. If you believe your account has been compromised, notify us immediately.
You may not create more than one account without our prior written consent. Duplicate accounts may be suspended.
We reserve the right to suspend or terminate any account that violates these terms,
without prior notice, where the violation is serious.

16. In-game purchases and digital assets

The Platform offers virtual items, including digital fashion skins, styling tools, and premium
features, available for purchase using real currency (“In-App Purchases” or “IAP”).

Payment

All IAP transactions are processed through our third-party payment provider. Prices are
displayed in Nigerian Naira (NGN) or USD, depending on your location. All prices include
applicable taxes where required

No refund policy for digital items

All In-App Purchases are final and non-refundable once the digital item has been delivered to
your account, except where required by applicable consumer protection law. If you experience
a technical issue with a purchase, contact us within 7 days.

Licence for digital items

When you purchase a digital item, you receive a limited, non-exclusive, non-transferable,
revocable licence to use that item within the Platform for personal, non-commercial purposes.
You do not own the digital item. Digital items have no monetary value outside the Platform and
cannot be exchanged for real currency.

17. The marketplace — buying physical products

The Owambe Fashion marketplace enables users to purchase physical garments and fashion
items from African designers and brand partners. The following terms apply to all marketplace
transactions:

The contract of sale

When you place an order through the marketplace, your contract of sale is with the brand or
designer partner fulfilling that order, not with Owambe Fashion. Owambe Fashion acts as a
facilitator, not the seller of physical goods, unless we are expressly identified as the seller for a
specific transaction.

Pricing and availability

Prices and product availability are set by individual brand partners and are subject to change
without notice. We make reasonable efforts to display accurate pricing, but we are not responsible for errors in pricing set by brand partners.

Returns and refunds

Return and refund policies for physical products are set by individual brand partners and are
displayed in their store profiles. As a general minimum standard, all brand partners on Owambe
Fashion must offer a return window of at least 7 days for items that arrive damaged, defective,
or materially different from their description. Contact us if a brand partner fails to honour their
return policy.

Owambe Fashion’s role in disputes

If a dispute arises between you and a brand partner regarding a physical purchase, contact us, and we will use reasonable efforts to assist in resolving it. We reserve the right to issue a refund directly where a brand partner is unresponsive or in breach of our marketplace
standards.

18. Brand and designer partner terms

By registering as a brand or designer partner, you agree to the following additional terms,
which form part of this agreement and your Brand Partner Agreement:

Eligibility and onboarding

Brand partners must be registered businesses or professional designers with the legal right to
sell the products listed on the Platform. We reserve the right to approve or reject any
application at our discretion.

Content standards

All content submitted to the Platform — including product images, descriptions, and brand
assets — must be accurate, not misleading, and free from any third-party intellectual property
claims. You warrant that you own or have the right to use all submitted content.

Royalties and commissions

Digital skin royalties and physical marketplace commissions are set out in your individual
Brand Partner Agreement. Payments are made monthly to your registered bank account,
subject to a minimum payout threshold of NGN 5,000. Owambe Fashion deducts its
commission before remitting your royalties.

Data and analytics

You acknowledge that Owambe Fashion collects engagement and performance data on how
users interact with your brand within the Platform. This data is yours to access through your
dashboard. We may use aggregated, anonymised data across brand partners for platform
improvement and research purposes.

Exclusivity

Registering with Owambe Fashion does not create an exclusive arrangement. You are free to
sell your products through other channels. However, you may not use data, insights, or user
connections derived from the Owambe Platform to contact our users directly for commercial
purposes outside the Platform without our prior written consent.

Termination of brand partnership

Either party may terminate the brand partner relationship with 30 days’ written notice. Upon
termination, your brand content will be removed from the Platform. Outstanding royalties
earned before the termination date will be paid within 30 days of termination. We may
terminate immediately in cases of fraud, illegal activity, or serious breach of these terms.

19. Intellectual property

Owambe Fashion’s intellectual property

The Platform, including its game design, code, visual assets, AI systems, brand name, logo, and all original content created by Owambe Fashion, is owned by or licensed to Owambe Fashion and protected by Nigerian and international intellectual property law. You may not
copy, modify, distribute, or create derivative works from our property without prior written
consent.

Your content

You retain ownership of any original content you create and submit to the Platform, including
avatar looks and user-generated styling content. By submitting content to the Platform, you grant Owambe Fashion a worldwide, royalty-free, non-exclusive licence to use, display,
reproduce, and distribute that content for the purposes of operating and promoting the
Platform.

Brand partner intellectual property

Brand partners retain full ownership of their designs, brand assets, and submitted content. By
submitting content to the Platform, brand partners grant Owambe Fashion a licence to display
and reproduce that content within the game and marketplace. This licence ends upon
termination of the brand partnership.

Reporting infringement

If you believe that content on the Platform infringes your intellectual property rights, please
contact us with details of the alleged infringement. We take IP rights seriously and will
investigate and act promptly.

20. Prohibited conduct

You agree not to use the Platform to:

Violate any applicable Nigerian or international law or regulation
Impersonate any person or entity, or misrepresent your affiliation with any person or
entity
Upload or transmit any content that is defamatory, obscene, harmful, threatening, or
discriminatory
Engage in any activity that disrupts, damages, or interferes with the Platform or its
infrastructure
Attempt to gain unauthorised access to any part of the Platform, other users’ accounts,
or our systems
Use automated bots, scrapers, or other tools to extract data from the Platform without
our consent
Sell, transfer, or trade your account or digital items outside the Platform
Use the Platform to promote counterfeit goods or infringe any third party’s intellectual property
Engage in harassment, abuse, or hate speech directed at other users or brand partners

Violation of these prohibitions may result in immediate account suspension or termination,
removal of content, and where required, referral to law enforcement.

21. Disclaimers and limitation of liability

Platform provided as-is

The Platform is provided on an “as is” and “as available” basis. We do not warrant that the
Platform will be uninterrupted, error-free, or free of viruses or other harmful components. We
make no warranties, express or implied, regarding the Platform’s fitness for a particular
purpose.

Third-party marketplace

Owambe Fashion is not responsible for the quality, safety, legality, or accuracy of physical
products listed by brand partners. Disputes regarding physical products are primarily between
the buyer and the brand partner. We provide dispute assistance as a courtesy, not as an
obligation.

Limitation of liability

To the fullest extent permitted by Nigerian law, Owambe Fashion’s total liability to you for any
claim arising from your use of the Platform shall not exceed the greater of (a) the total amount
you paid to Owambe Fashion in the 3 months preceding the claim, or (b) NGN 10,000.
We are not liable for any indirect, incidental, special, consequential, or punitive damages,
including loss of profits, data, or goodwill, arising from your use of the Platform.

22. Dispute resolution

We hope to resolve any concerns informally. If you have a dispute with us, please contact us first at owambefashion.com, and we will use good faith efforts to resolve it within 14 business days.

If informal resolution is not possible, any dispute arising from these terms shall be subject to
the exclusive jurisdiction of the courts of Nigeria, specifically the courts of Lagos State, unless
applicable law requires otherwise.

For disputes involving users in the EU or UK, we will cooperate with the relevant alternative
dispute resolution bodies as required by applicable law

23. Amendments

We may update these Terms and Conditions and Privacy Policy from time to time. When we
make material changes, we will notify you by email and through a notice on the Platform at
least 14 days before the changes take effect. Your continued use of the Platform after that date
constitutes acceptance of the updated terms.

For minor changes (such as corrections or clarifications that do not affect your rights), we will update the “last updated” date at the top of this document.

24. Governing law

These Terms and Conditions and Privacy Policy are governed by the laws of the Federal
Republic of Nigeria, including the Nigeria Data Protection Regulation 2019, the Nigeria Data
Protection Act 2023, the Consumer Protection Council Act, and the Federal Competition and
Consumer Protection Act (FCCPA) 2018.

Where you are accessing the Platform from a jurisdiction with mandatory consumer protection
or data protection laws that provide greater protection than Nigerian law, those laws apply to
the extent required.

By using the Owambe Fashion platform, you confirm that you have read and
agreed to this Privacy Policy and Terms and Conditions in their entirety. If you do
not agree, please do not use the platform.

For all privacy and legal inquiries:

Owambe Fashion | [email protected]