Privacy Policy

Last updated: 2nd March 2026

Tango Brook Technologies Limited (“Tango” or “we”) recognizes the importance of your privacy and is committed to safeguarding your personal information in accordance with this Privacy Policy (“Policy”). This Policy outlines the principles and practices governing the collection, use, storage, and disclosure of personal information of individuals who use our services (“Users”).

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with or use the Website or App. By registering with or using the Website or App, you agree to this Policy.

This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device"). This Privacy Policy also applies to your offline interactions with Tango.

When you submit an inquiry to us via any means, register for a Tango Card, register to attend a Tango event, interact with us on social media, partake in competitions and promotional activities and volunteer information to us; we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, image and other information that identifies you (collectively, "Personal Information").

Tango is committed to maintaining the principles in the Nigerian Data Protection Act (NDPA) 2023, the Nigeria Data Protection Act General Application and Implementation Directive (2025) and other applicable privacy and data protection laws regarding the processing of Personal Information.

This Policy may change from time to time. Your continued use of the Website and App after we revise this Policy means you accept those changes, so please check this Policy periodically for updates.

1. DATA CONTROLLER PROCESSOR STATUS

For the purposes of the Nigeria Data Protection Act, 2023 (NDPA) and the Nigeria Data Protection Act – General Application and Implementation Directive (GAID) 2025, Tango acts as a Data Controller where it determines the purposes for which and the means by which personal data is processed in connection with its website, mobile applications, Tango Fuel Card, Tango Devices, and related services (collectively, the “Services”).

2. POLICY APPLICATION

This Privacy Policy applies to personal data processed by Tango in relation to:

a. Individual users with active and verified Tango accounts;Natural persons who access or use Tango’s website, mobile applications, Tango Fuel Card, Tango Devices, or related Services;
b. Corporate customers, governmental bodies, and other organisations that utilise Tango’s Services, including their authorised representatives, employees, and agents;
c. Vendors, suppliers, contractors, service providers, and business partners engaged by Tango;
d. Employees, job applicants, prospective employees, and interns of Tango; and

Any other individual whose personal data is lawfully provided to or collected by Tango in connection with its business operations.

4. DATA MINIMIZATION AND PURPOSE LIMITATION

Tango processes Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Policy or otherwise communicated at the point of collection. We do not collect or process Personal Data that is excessive, irrelevant, or unrelated to the purposes for which it is obtained

Personal Data shall not be further processed in a manner incompatible with the original purposes for which it was collected, unless such further processing is permitted or required by applicable law. Where new or materially different purposes arise, Tango will provide appropriate notice and, where required, obtain additional consent before processing.

5. LEGAL BASIS FOR PROCESSING YOUR DATA

The legal basis we rely on for processing your Personal Data are:

a. Your consent: Where you agree to us collecting and using your Personal Data.

b. We have a contractual obligation: Without your Personal Data, we cannot provide our Services to you. We may process your Personal Information to fulfil our contractual obligations such as providing our Services to you or to take necessary actions at your request before providing our Services to you. This enables us to provide you with the Services you request. When you enter into a contract with us, such as subscribing to our Services, or engaging in a business agreement, we need to use your Personal Information to carry out our commitments.

c. We have a legal obligation: We have a legal obligation and responsibility to act in compliance with applicable laws, legislations and regulations to protect against fraud by verifying identity, terrorism financing, proliferation financing and money laundering. To ensure we are fully compliant with all applicable financial legislations such as Anti-Money Laundering and Counter Terrorist Financing Laws, we must collect and store your Personal Data.

d. Vital Interest: We may process your Personal information if necessary to protect your vital interests or the interests of another natural person, where the data subject is physically or legally incapable of giving consent such as in the event of a claim for any amounts in the account of a deceased User by the User's next-of-kin.

e. We have a legitimate interest: In certain instances and as permitted by law, we may rely on legitimate interests in our business to process your Personal Data. These may include sharing your data with our affiliates, or protecting against fraud by checking your identity before providing you with a service.

f. Public Interest: We may process your Personal Information if necessary to perform an obligation in the public interest or by virtue of an official authority bestowed on us.

These lawful bases may be extended to cover any additional grounds for the processing of personal data as may be recognized by Data Protection Laws in force from time to time.

6. TYPE OF DATA COLLECTED

By providing your Personal Information or any other data to us, you expressly consent to its collection, use, storage, and disclosure in accordance with this Policy. We may collect, process, store, and share various categories of Personal Information about you, including but not limited to:

a. Personal identification information: This could be any data that could potentially identify an individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data. Such data includes, but is not limited to name, age, height.

b. Contact Information: To help us make communication more useful and interesting, we collect information that includes, but is not limited to email address, phone number etc.

c. Other sensitive personal information: These are defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual such information includes but is not limited to marital status and religious affiliation.

d. Financial Information: This includes data such as card numbers, account balances and other monetary facts about a person or organization that are used in billing and other financial activities.

e. Mobile: When you download or use apps created by Tango, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services such as the closest service station to you, amongst other promotions.

f. Online Information (cookies): Cookies are small text files that are stored on your computer or mobile devices whenever you visit a website.

g. Device Data: We may collect data relating to the device being used to access our services as; device IP addresses, hardware model, operating system, version, software, unique device identifiers, advertising identifiers, serial numbers, mobile network data and Web browsing data.

h. Location data: We may collect precise or approximate location data from a user's mobile device if enabled by the user to do so. We may also collect, use and share aggregated data such as statistical or demographic data for any purpose.

i. Usage data: We collect data about how users interact with our services via our website and mobile application. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services.

j. Marketing and Communications Information: which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

k. Tax compliance information: This include verification and evidence of compliance to relevant tax regulations by vendors which include but not limited to Value Added Tax (VAT) certificate.

l. Next-of-Kin form: We may collect your Personal Information from a User where your Personal Information is filled in a Next-of-Kin form.

m. Information from Companies: We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from a consumer reporting agency or we may collect Personal Information from your employer where your employer is providing a service to Tango or Tango is providing a service to your employer.

n. Telematics and Operational Data: Data generated by Tango Devices installed on vehicles, generators, fuel systems, or equipment, including movement data, fuel usage metrics, sensor outputs, performance analytics, and operational activity logs

o. Vendor and Corporate Due Diligence Data: Information provided by vendors, contractors, or corporate customers for onboarding, compliance, or verification purposes, including tax documentation, regulatory certificates, corporate records, and verification material

Tango does not collect personal data that is excessive, irrelevant, or unrelated to the purposes for which it is processed.

7. THIRD-PARTY COOKIES

We allow certain third parties to place cookies through our Services to enhance user experience, analyze usage patterns, and deliver targeted advertisements. These third parties may track your online activities across different websites over time. For exam ple, we use Google Analytics to gather insights into how our Services are used. Google Analytics places a cookie to collect data, generate activity reports, and provide related services. While Google may use a portion of your IP address for identification, it does not associate this with other data.

Additionally, third - party service providers may place cookies for analytics or marketing purposes, subject to your consent. We do not control these third - party cookies or the data they collect, nor are we responsible for their policies or actions. By using our Services, you consent to the placement of cookies on your devices. You may adjust your browser settings to manage or block cookies, but doing so may limit certain features of our Services.

"Do Not Track" (DNT) is an optional browser setting that expresses user preferences regarding tracking by advertisers and other third parties. Our Services do not currently respond to DNT signals.

We may share aggregated or anonymized analytics data with third parties for commercial purposes.

8. DATA STORAGE AND SECURITY

Tango implements appropriate technical, administrative, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, loss, misuse, or destruction. Personal data may be stored on secure servers, protected physical facilities, and reputable cloud infrastructure providers that implement industry - standard security controls. Access to personal data is restricted to authorized personnel on a need - to - know basis and subject to confidentiality obligations.

Security measures may include, without limitation:

a. access controls and authentication mechanisms
b. encryption of data in transit and, where appropriate, at rest;
c. system monitoring and intrusion detection measures
d. audit logging and activity tracking;
e. regular security assessments and vulnerability management; and
f. internal policies governing data handling and incident response.

While Tango takes industry standard steps to safeguard personal data, no method of transmission over the internet or electronic storage system is entirely secure. Accordingly, we do not guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials and access devices. Any instructions, transactions, or communications received through your authenticated account credentials shall be deemed authorized by you unless we ar e notified promptly of unauthorized access.

9. PERSONAL DATA BREACH NOTIFICATION

In the event of any actual, suspected, or confirmed personal data breach that may compromise the confidentiality, integrity, or availability of Personal Data, Tango shall promptly investigate the incident and take appropriate remedial measures. Where a bre ach is likely to result in a risk to the rights or freedoms of affected individuals, Tango will notify the relevant regulatory authority and affected data subjects in accordance with applicable data protection laws and regulatory requirements. Tango will a lso take reasonable steps to mitigate any adverse effects and prevent recurrence, including implementing corrective technical and organizational measures where necessary.

10. DATA RETENTION

Tango retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the provision of Services, compliance with legal and regulatory obligations, dispute resolution, enforcement of agreements, fraud pr evention, and legitimate business operations. Retention periods may vary depending on the nature of the data and the purpose of processing. In determining the appropriate retention period, Tango considers:

Security measures may include, without limitation:

a. the sensitivity and volume of the personal data;
b. the potential risk of harm from unauthorized use or disclosure;
c. applicable statutory, regulatory, tax, accounting, and anti - money laundering requirements;
d. contractual obligations; and
e. the need to establish, exercise, or defend legal claims.

Financial transaction data, identity verification records, and compliance - related documentation may be retained for minimum statutory retention periods required under applicable financial, anti - money laundering, and regulatory frameworks. Where personal data is no longer required, Tango will securely delete, anonymize, or archive such data in accordance with applicable law and internal data governance policies. Even where you cease using our Services, certain data may be retained where required for compliance, audit, regulatory reporting, fraud prevention, or legitimate legal purposes.

11. CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in our Services, legal requirements, regulatory guidance, or data processing practices. Where changes are material or significantly affect your rights or the manner in which we process personal data, we will provide reasonable notice through appropriate channels, which may include publication on our website, in - app notifications, or email com munication where available. The revised version will be effective 4 days after publication . You retain the discretion to accept or decline any revised version of this Privacy Policy. However, continued access to or use of our Services requires acceptance of the most current version. If you do not agree to the terms of this Privacy Policy or any subsequent revisions, your sole remedy is to discontinue your access and use of our Services. Y our use of our Services shall be governed by the version of this Privacy Policy in effect at the time of access or use

12. THIRD - PARTY PROCESSOR DUE DILIGENCE AND SAFEGUARDS

Where Tango engages third - party service providers, vendors, contractors, or partners to process Personal Data on its behalf, Tango conducts appropriate due diligence to assess their data protection and information security standards prior to engagement.

Tango requires such third parties to:

a. process Personal Data only in accordance with Tango’s documented instructions;
b. implement appropriate technical and organisational measures to protect Personal Data;
c. maintain confidentiality obligations;
d. notify Tango promptly of any actual or suspected personal data breach; and
e. comply with applicable data protection laws and contractual data protection obligations.

Tango remains responsible for ensuring that any third - party processing conducted on its behalf is carried out in accordance with applicable data protection laws

13. USE OF PERSONAL INFORMATION AND COMMUNICATION PREFERENCES

Our third - party service providers will only be permitted to use Personal Information for the clearly intended purpose. We may use your email address to respond to your inquiries and to provide information about our Services. You may elect not to receive pr omotional emails from us either by " unsubscribing " to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you non - promotional emails, such as emails about your Tango account or our ongoing business relations, unless you withdraw your consent to receive electronic communications .

14. USE OF YOUR PERSONAL DATA

We may use your Personal Data that we collect to:

a. create and manage any Accounts you may have with us, verify your identity, provide our Services, and respond to your inquiries;

b. process your payment and other transactions (including authorization, clearing, chargebacks and other related dispute resolution activities) and provide other payment related services to you;

c. protect against and prevent fraud, unauthorized transactions, claims and other liabilities;

d. communicate with you about products, newsletters, advertisements, offers, programs and promotions of Tango, financial institutions, merchants and other partners. You have the right to opt-out of this at any time;

e. send communication on service updates (downtime, service support, regulatory notices, etc);

Tango remains responsible for ensuring that any third - party processing conducted on its behalf is carried out in accordance with applicable data protection laws

a. create and manage any Accounts you may have with us, verify your identity, provide our Services, and respond to your inquiries;

b. process your payment and other transactions (including authorization, clearing, chargebacks and other related dispute resolution activities) and provide other payment related services to you;

c. protect against and prevent fraud, unauthorized transactions, claims and other liabilities;

d. communicate with you about products, newsletters, advertisements, offers, programs and promotions of Tango , financial institutions, merchants and other partners. You have the right to opt - out of this at any time;

e. create and manage any Accounts you may have with us, verify your identity, provide our Services, and respond to your inquiries;

f. communicate with you to resolve an inquiry, complaint or concerns with your Account. We also use your contact data to send you one - time passwords (OTP) for account authentication via short messaging service (SMS), email, whatsapp or other electronic mediums:

g. evaluate and improve our business, including developing new products and Services;

h. establish, exercise and defend legal rights, as necessary;

i. comply with applicable laws and regulations, including for compliance with Know - Your - Customer, Know - Your - Business, Anti - Money Laundering, anti - corruption, fraud monitoring, sanctions screening and risk assessment requirements, or as requested by any judici al process, law enforcement or governmental agencies having or claiming jurisdiction over Tango or Tango affiliates and partners;

j. use data analytics to improve our website, products or Services, user experience and to optimise our Services.

k. if you register for and/or attend any Tango sponsored events, we collect your registration and contact details to complete your registration. We may also collect your images, in video or still form, audio - visual recordings or other forms of digital information gathered at such events by the media t eam and use them for promotion, publication or marketing of the event as Tango may determine

l. in order to experience the full range of our mobile application’s seamless services , we would require your consent granting access to your contact list. You have the right to withdraw your consent allowing us access to your contact list at any time

m. if you apply for employment with Tango , we use your Personal Data to evaluate your interest in employment, for compliance checks and to contact you regarding possible employment with Tango

n. For other purposes, for which we provide specific notices at the time of collection.

15. HOW WE SHARE INFORMATION

Tango may disclose personal data to third parties only where such disclosure is lawful, necessary, proportionate, and consistent with the purposes described in this Privacy Policy or otherwise permitted under applicable law. Such disclosures may be made in the following circumstances:

a. With Your Authorization: When you expressly request or authorize us to share your personal data.

b. Service Providers and Vendors: With third - party service providers, contractors, installers, infrastructure providers, analytics providers, customer support vendors, logistics partners, and other vendors engaged to perform services on our behalf, strictly to the extent necessary for them to perform those services and subject to appropriate confidentiality and data protection obligations

c. Financial Institutions and Payment Partners: With licensed financial institutions, payment processors, settlement partners, and other financial service providers where necessary to facilitate transactions, payment processing, or related financial operations

d. With Referring Users: If you sign up through a referral link, we may inform the referring User of your enrollment

e. With Non - Financial Third Parties: With non - financial companies, such as email service providers for marketing services and fraud prevention service providers assisting in risk management.

f. With Authorized Third Parties for Data Access: With non - affiliated third parties authorized to access and transmit your personal and financial information from relevant institutions, in accordance with their privacy policies.

g. Business Partners and Contractual Counterparties: With business partners, suppliers, subcontractors, and other counterparties where disclosure is reasonably necessary for the performance or administration of contractual obligations

h.For Business Transfers: In the event of a sale, transfer, or merger of parts of our business or assets, or in cases where we acquire all or part of another business

i. To Comply with Legal Requirements: In response to legal requests, including court orders, subpoenas, governmental or regulatory inquiries, or if disclosure is required by applicable laws, rules, or regulations.

j. For Business Operations: To facilitate our everyday business operations

k. For Marketing and Publicity: For the publication of events, competitions, or promotional activities in digital and print media.

l. To Protect Rights and Safety: To safeguard our rights, property, or safety, as well as those of our Users and third parties.

m. For Fraud Prevention and Investigations: With relevant law enforcement authorities, investigators, or auditors, if we believe such disclosure is necessary to investigate or prevent fraud.

All disclosures will be made in accordance with applicable laws and our privacy policy.

16. INTERNATIONAL DATA TRANSFERS

Tango may transfer, store, or process Personal Data outside the Federal Republic of Nigeria where such transfer is necessary for the provision of the Services, including but not limited to where our service providers, cloud infrastructure providers, analytics partners, or technical support teams operate in other jurisdictions. Where Personal Data is transferred outside Nigeria, Tango shall implement appropriate safeguards in accordance with applicable data protection laws to ensure that such data remains protected to standards substantially equivalent to those required under the law s of the Federal Republic of Nigeria . Such safeguards may include contractual data protection obligations, confidentiality commitments, security controls, and reliance on jurisdictions recognized as providing adequate levels of data protection. By using the Services, you acknowledge tha t such transfers may occur where necessary for service delivery.

18. OPT-OUT RIGHTS

If you do not wish to receive promotional offers or other communications from us, you may opt out by:

a. Following the " unsubscribe " instructions included in any email you receive from us, or

b. Contacting us through the details provided at the end of this Privacy Policy.

Tango will process opt - out requests within a reasonable timeframe in accordance with applicable law . However, please note that if you are a registered User, you cannot opt out of receiving essential communications regarding your Tango account or related transactions.

19. YOUR RIGHTS REGARDING PERSONAL INFORMATION

Beyond your ability to opt out, you have additional rights concerning your Personal Information, including:

a. Right to Request Correction: You have the right to correct inaccurate Personal Information. Users may update certain details via their Tango account profile. However, changes to financial details require direct contact with us. If you are not a registered User, you may request corrections by contacting us. Please note that corrections apply only to future uses of your data, and we may need to verify the accuracy of any updates.

b. Right to Access: Your Personal Information. You may request confirmation on whether we store your Personal Information and request a copy of it. Before providing any Personal Information, we may require proof of identity. If verification is not successful, we reserve the right to decline the request. We will respond to such requests promptly.

c. Right to Data Portability: In certain cases, you can request a copy of your Personal Information in a structured, commonly used electronic format.

This right applies to data:

That you have provided to us directly, such as information submitted through forms or our website or App.
That has been collected through automated means based on your digital interactions with our Services.

This right applies only when processing is based on your consent or a contractual necessity and is carried out electronically.

d. Right to Restrict Processing: You may request that we limit the processing of your Personal Information if you believe it affects your fundamental rights and freedoms. You may also object to the use of your data for direct marketing purposes. In some cases, we may demonstrate overriding legitimate grounds for processing, which will be communicated to you.

e. Right to Erasure: You may request the deletion of your Personal Information where:

It is no longer necessary for the purposes for which it was collected.
You have successfully exercised your right to object to processing.
We have unlawfully processed your data.
We are required by law to erase your data. However, we may not always be able to comply with your request for legal or regulatory reasons, which will be notified to you at the time of your request.

f. Right to Data Transfer: You may request that we transfer your Personal Information to you or a third party of your choosing in a structured, machine-readable format. This applies only to data processed with your consent or for contractual purposes through automated means.

g. Right to Lodge a Complaint: If you believe that the processing of your Personal Information violates data protection laws, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

h. Right to Withdraw Consent: Where we rely on your consent to process Personal Information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of processing conducted prior to withdrawal. In some cases, withdrawing consent may prevent us from providing certain Services. We will inform you if this applies when you withdraw your consent.

i. Right to Object to Automated Decision-Making: You may object to decisions made solely based on automated processing, including profiling, where such decisions may have a legal or significant effect on you.

However, this right does not apply if:

The decision is necessary for entering into or performing a contract with us.
You have provided explicit consent.

There are appropriate safeguards in place to protect your rights and freedoms. We implement measures to protect your interests, including allowing you to seek human intervention, express your views, and challenge automated decisions.

For any inquiries or to exercise your rights, please contact us through the details provided in this Privacy Policy.

21. ACCOUNT SECURITY AND AUTHORIZATION

Any instructions received using your Tango account login credentials or other security information shall be deemed to have been authorized by you. You agree to promptly notify us of any unauthorized access to your Tango account or any breach of security. We reserve the right, at our sole discretion, to refuse service, terminate accounts, or modify or remove content as necessary to protect the integrity of our Services.

22. PROTECTION OF MINORS' PRIVACY

Our Services are not designed for or intended to appeal to individuals under the age of eighteen (18). We do not knowingly collect Personal Information from minors. If you are under eighteen (18), you are prohibited from using our Services or submitting an y information to us.

If Tango becomes aware that Personal Information relating to a minor has been collected without valid authorization or lawful basis, we reserve the right to take appropriate action, including deleting such data, suspending associated accounts, and restrict ing access to the Services.

Where a minor has provided Personal Information through misrepresentation of age or without required authorization, Tango shall not be liable for any consequences arising from such submission to the fullest extent permitted by applicable law.

Parents or legal guardians who believe that a minor may have provided Personal Information through our Services should contact us immediately using the contact details provided in this Policy so that appropriate steps may be taken.

Nothing in this clause limits any obligation Tango may have under applicable data protection laws

23. COMPLAINTS AND PRIVACY CONCERNS

If you have any questions, concerns, or complaints regarding this Privacy Policy or the processing of your Personal Data, you may contact Tango using the contact details provided below. We will make reasonable efforts to investigate and resolve any privacy - related concerns promptly and in accordance with applicable data protection laws.nd binding. Court action is only permitted after arbitration.

Nothing in this Policy prevents you from exercising your statutory rights or lodging a complaint with a competent data protection authority, including the Nigeria Data Protection Commission (NDPC), where you believe your rights have been infringed.

24. CONTACT US

If you have any questions, please contact us at:

Tango Brook Technologies Limited

Synergy Place,

No 16 Billings Way,

Oregun Industrial Estate,

Oregun, Ikeja,

Lagos State, Nigeria.

Email: info@tangobrook.ng

Number: 0906 796 7496

We will respond to your concerns within 10 days of receiving your notice.