This Privacy Policy sets out the basis on which Deltaridge Resources Limited (trading as “Matta”) collects, uses, discloses, and safeguards Personal Data (as defined in under the Data Protection Laws) of users of its product, ORBITAL BY MATTA (the “Platform”, “Website” or “Services”), in accordance with the provisions of the Nigeria Data Protection Act, 2023 (NDPA), the General Application and Implementation Directive, 2025 (GAID), and other relevant data protection laws and regulations in force in Nigeria (collectively referred to as the “Data Protection Laws”).

Welcome to ORBITAL BY MATTA (“ORBITAL” “We” “Our” “Us”) Privacy Notice. ORBITAL understands that you care much about your privacy and is committed to protecting your personal data.

This privacy policy (“Policy”) will help you understand how ORBITAL collects, uses, shares, processes and protects the Personal Data you provide to us when we provide legal services to clients, or when you use any of our services via our website or other mode of communication (collectively referred to as “Services”).

• CONSENT

We may ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. However, it is imperative to note that an implied consent will be deemed when you subscribe to our services, newsletters, or you surf our website. You may withdraw your consent at any time by contacting Orbital via our email legal@matta.trade

• WHAT CONSTITUTES CONSENT

We rely on consent to process your personal data. Where we are relying on consent, entering your PIN number, ticking a yes/no box, clicking “I agree button”, endorsing your signature in a form or document, clicking “I accept button” on our platform or weblink will constitute consent.

Orbital records and stores evidence of consent and where you provide consent by any of the means indicated above, you may change your mind and withdraw consent at any time by contacting Us via legal@matta.trade

• DATA PROTECTION OFFICER 

ORBITAL has appointed a data protection officer for you to contact if you have any questions concerning this Notice or our privacy practices in compliance with the Data Protection Act 2023. Our DPO can be reached via legal@matta.trade

• STATEMENT OF COMPLIANCE WITH DATA PROTECTION PRINCIPLES

We receive your data for the specific purposes stated in this policy geared towards providing our services to you. We receive data you have provided to us or that you have enabled us to access by subscribing to our Services. 

Your personal data is stored securely with Us, and we will take steps to ensure the security of your data by implementing physical, electronic, and procedural safeguards to protect your information. We are committed to ensuring the privacy and integrity of the Personal Data you share with Us, or we otherwise collect, as we provide you with our Services.

• DATA WE COLLECT FROM YOU

Personal data is any information that identifies or can identify you. The personal information we process about you depends on your interaction with us. We may collect Personal Data about you directly or indirectly from you, from third parties or automatically when you subscribe to our services.

 

The type of information we collect from our clients varies depending on which of our services you want to interact with. We may indicate why you must provide us with your Personal Data, as well as the consequences of failing to do so. 

If you do not provide Personal Data when requested, you may not be able to benefit from the Services if that information is necessary to provide such Services or if we are legally required to collect it. For the services we render to you, we process the following broad categories of data and information:

1. Information Obtained from You Directly

1. This information may be provided by:

1. creating an account or registering to use the Platform;
2. accessing the platform without creating an account (e.g. Cookies and Similar tracking technologies, Internet Protocol (IP) address, location data, or browser type and device information)
3. filling in forms or subscribing to any of Our services on Our website or newsletter.
4. corresponding with Us (e.g. by e-mail or chat).
5. registering for an event sponsored by Our Company.
6. provided by providing your information to Us during an event where ORBITAL exhibits. 

For the services we render, we process the following information:

1. Registration data: These are information we collect when you sign into our platform either as a merchant or customer. This information includes your name, email address, photo, country, phone number, location, and time zone.

1. Identity data: They are information we use to identify customers, and it includes name, National Identification Numbers, email addresses, and Utility bills among others.

1. Financial data:  They are information we collect for your virtual wallet and other financial transactions. They include your account name, number, bank name, list of beneficiaries, and transaction pin.

1. Contact data: This may include your name, email address, email content, office address, house address, etc. We collect this information to provide inquiries and support. We may also use this data to provide marketing/communication insights and services to you about Our new products and offers for you.

1. Technical data: When you visit our website our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the location, and other details about your visit.

1. Contract or Business Data: This includes personal data collected in the course of providing services or contractual relationships such as information about the contracts such as the date of conclusion, the type of contract, its duration and the services to be provided, complaints, signatures and names, and feedback.

1. Other Data: We may collect data from you to be processed in relation to administrative or judicial proceedings.

1. Information we receive from other sources (Third Party)

Due to the nature of the services which we provide, we are required to work with a number of third parties (including regulatory bodies, financial institutions, auditors, enforcement agencies, service providers that support Us with certain services, our subsidiaries and partners, external legal representatives etc.) and we may receive information about you from them.  Information collected from third parties is not controlled by Us, and We are not responsible for the processing of your personal data by the third party. We, however, take measures to ensure the accuracy of the information we receive from third parties about you.

Orbital by Matta is a product of Deltaridge. We may share your Personal Data with Deltaridge or other affiliated entities within the Matta Ecosystem, provided they adhere to equivalent data protection and security standards set out in this policy.

1. Information About Other People

If you provide information to us about any person other than yourself, counterparties, your advisers, or your suppliers, you must ensure that they understand how their information will be used, and that they have given their consent to you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

1. Information About Children

We do not aim any of our products or services directly at children or persons under the age of eighteen (18) years and we have put appropriate measures in place to block a person below the age of 18 years from registering on our platforms. In the event that the need arises for us to process the personal information of a person below 18 years, we will obtain verified consent from the parent or guardian.

• LEGAL GROUND FOR PROCESSING YOUR PERSONAL DATA

ORBITAL generally collects only the Personal Data necessary to fulfill your request or render our services adequately to you. The law in Nigeria allows us to process Personal Data, so long as we have a legal ground to do so. It also requires us to tell you what those grounds are. As a result, we only process your Personal Data when we can rely on any of the following legal grounds:

 

1. Consent: You have consented to the use of your Personal Data, for the purposes of marketing communications, the use of certain cookies, analytics, and optional service enhancements. When we obtain your consent, kindly note that your consent can be withdrawn at any time, and we will comply by not further processing your personal data. purposes of marketing communications, analytics, and optional service enhancements.

1. Execution of a Contract: We need your Personal Data to provide you with our Services, including to operate our website, to perform trade finance, logistics services, as well as marketplace services, to fulfil our obligations under a contract, or to otherwise respond to your queries.

1. Compliance with a Legal obligation: We are required or allowed to collect and use your Personal Data in order to comply with a legal obligation, such as keeping records for tax purposes, Know Your Client (KYC) requirement, compliance with anti-money laundering regulations, and regulatory reporting duties.

1. Legitimate interest: We or a third party, may have a legitimate interest in processing your Personal Data. We may have a legitimate interest in using your Personal Data to conduct business analytics, tailor Our products and services to suit your needs, improve the safety, security and performance of our platform, to prevent fraud, as well as manage supplier relations. We only rely on our third party’s legitimate interests to process your Personal Data when these interest are not overridden by your rights and interests.

1. Public Interest: You have consented to the use of your Personal Data where it is required for public health and safety purposes, or regulatory cooperation.

• COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and other tracking technologies on our website. Cookies are small pieces of text that are saved on your Internet browser when you use our website. The cookies are sent back to our computer each time you visit our website. 

Cookies make it easier to distinguish you from other users, to give you a better experience when you browse Our site and allows us to improve user experience. You will be required to indicate your consent to Our cookies by a conspicuously displayed cookies banner when you visit our website, or to modify your cookies options.

You can stop your browser from accepting cookies, but if you do, some parts of our website or online services may not function appropriately. Please read our comprehensive cookies policy for more information.

• AUTOMATED DECISION MAKING

ORBITAL uses artificial intelligence (AI) to assess customers’ creditworthiness and conduct customer due diligence. ORBITAL will ensure strict compliance with the principles of data protection and has taken steps to put measures including human intervention to ensure the rights and freedoms of our clients are not impacted negatively. 

• DISCLOSURE OF YOUR INFORMATION

1. We may disclose your personal information to any other Affiliate companies that ORBITAL controls or that are under common control of ORBITAL as needed to provide our services.

1. We may disclose your personal information to third parties who are trusted third-party service providers to support our Services and business. These third parties include regulators, public bodies, financial institutions, vendors, merchants, auditors, insurance companies, ORBITAL’s network of external legal counsel and other professional experts, advisors and/or consultants engaged by ORBITAL or its external counsels in the course of business. 

1. We may disclose your personal information you provided to our website or social media platforms such as comments, which may be displayed and viewable by other users.

1. We may disclose your information if we believe such action is necessary to: 

1. comply with laws, law enforcement, regulatory requests, and legal process, such as a court order or subpoena.
2. respond to credit bureaus, debt recovery and enforcement agencies.
3. respond to your requests.
4. protect your, our or others’ rights, property, or safety.

• DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, and We are required to assert or defend against legal claims, pending the final adjudication of the claim. This includes the purposes of satisfying any legal, regulatory, auditing, reporting requirements, recruitment requirements, to carry out legal work, for the establishment or defense of legal claims. 

In some circumstances we will anonymize your personal data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. If you would like to know more about Our retention periods as provided in Our retention policy, please contact us at legal@matta.trade.

• HOW WE STORE AND KEEP YOUR DATA SAFE

We store and process your Personal Data in clouds on our database in Nigeria, and some foreign countries. Where we need to transfer your data to our vendors, clients or expert consultants in foreign countries, we would ensure that such country has an adequate data protection law. We will seek your consent and comply with appropriate safeguards under the law (such as standard contractual clauses, binding corporate rule or other lawful bases provided by the law), where we need to send your data to a country without an adequate data protection law.

• DATA SECURITY

We have put appropriate security measures such as encryption, firewall, and locks in place to prevent accidental loss of personal data, and/or to ensure that personal data is not used, accessed, altered, or disclosed in an unauthorized manner. 

In addition, we limit access to your personal data to only necessary agents, contractors, and other third parties who We have business need with. They will only process your personal data on Our instructions and are strictly subject to a duty of confidentiality. 

We also have in place a high availability cloud application infrastructure and use tier 3 Datacenter, primary and secondary data backup systems to ensure the availability of your personal data. We have put in place some procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach within 72 hours where we are obligated to do so.

• THIRD PARTY LINKS

1. This notice applies to our Site only and does not cover third-party links. Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notice. 

1. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and ORBITAL should not be regarded as the publisher of such opinions or materials. Please be aware that we are not responsible for the privacy practices, or content of these sites.  

1. We encourage you to read the privacy notice and policies of every website, or apps you visit, and evaluate the security of the site or app independently before engaging with same or disclosing personal information therein.  ORBITAL will not be responsible for any loss, or damage resulting to you from the engagement with such website.

• YOUR LEGAL RIGHTS 

Subject to the applicable Data Protection laws, you have the right to the following:

1. Access to your Personal Data: This may also be known as a “data subject access request”. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. Upon your request to access your Personal Data with us, we may ask for proof of identity and sufficient information about your interactions with us to enable us to locate your personal information. If we agree that we are obliged to provide personal information to you, you may be required to pay an administrative fee(s). 

1. Rectification of your Personal Data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

1. Object to processing: You have the right to object to us processing your personal information if we are not entitled to use it anymore or you may have the processing of your Personal Data restricted in certain circumstances.

1. Erasure of your Personal Data: This enables you to ask us to delete your Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your Personal Data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local laws. If there are any lawful reasons that may not allow us to comply with your request to erase your personal data, such shall be communicated to you accordingly.

1. Transfer of your Personal Data to a third party: We will provide to a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with/for you.

1. Withdraw consent at any time: Where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

• RIGHT TO COMPLAINT 

Kindly note that you have the right to make a complaint in accordance with Article 40 of the GAID Principles, to enforce your data protection rights. Where you have any complaints or concerns, kindly click here to use the standardized complaint.

• CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Policy from time to time to reflect our processing activities, changes to our privacy practices or changes by applicable laws.  The “Last updated” date at the top of this page indicates when this Privacy Policy was last revised. The revised policy will be effective as of the published effective date. 

If we make material changes, we may notify you via a notice posted on our website or other method. We encourage you to read this Privacy Policy periodically to stay up to date about our privacy practices.  

In any event, by continuing to use any of our services or surfing our website after the posting of our revised privacy policy, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.

• KEEPING YOUR INFORMATION UP TO DATE

ORBITAL makes every effort to maintain the accuracy and completeness of the personal information held by it. To help us ensure we have the most up to date information about you, it is important that you inform us of any updates to your contact details or other personal information. Please contact your Vendor Verification Officer or the person you usually deal with at ORBITAL. You can also contact our Data Protection Officer at legal@matta.trade.

• REMEDY FOR VIOLATION OF THIS POLICY

The remedy for any violation of this policy we apply in addressing your grievance depends on the nature of the grievance but may include: 

1. conducting an investigation alone (or in conjunction with a Data Protection Compliance Organization) to establish and deal with the source of your grievance
2. deletion of your data from our database.
3. rectification of your data.
4. imposition of restriction on further processing of your data, etc.

• OUR CONTACT DETAILS

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to legal@matta.trade. 

•  POLICY REVIEW

The Policy shall be reviewed from time to time.

• VERSION UPDATE

1. Version 1.1 2025
2. Next Revision: December 2025

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