Privacy Policy
YPP Mandate — Official 2026 Party Primaries E-Voting Platform
The Young Progressives Party (“YPP”) and VoteTrack Ltd are committed to protecting the personal data of every individual who uses the YPP Mandate e-voting platform. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have under the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR).
This policy applies to all users of vote.ypp.ng — including voters, aspirants, panel members, and administrators — in connection with the 2026 YPP Ward, LGA, State, and Presidential Party Primaries. It should be read together with our Terms of Service and Data Protection Policy.
Contents
- 1.Who We Are & Policy Overview
- 2.Data Controller & Processor
- 3.Personal Data We Collect
- 4.Data We Do NOT Collect
- 5.Legal Basis for Processing
- 6.How We Use Your Data
- 7.Data Sharing & Disclosure
- 8.International Data Transfers
- 9.Data Retention
- 10.Security Measures
- 11.Your Rights Under the NDPA 2023
- 12.Children's Data
- 13.Cookies & Tracking
- 14.Complaints & Contact
- 15.Changes to This Policy
Who We Are & Policy Overview
Young Progressives Party (YPP) is a registered Nigerian political party operating under the Constitution of the Federal Republic of Nigeria 1999 (as amended) and the Electoral Act 2022. YPP is the Data Controller for personal data processed through the YPP Mandate platform.
VoteTrack Ltdis the technology provider that designed, built, and maintains the YPP Mandate platform. VoteTrack Ltd acts as a Data Processor on YPP's behalf, processing personal data only on YPP's documented instructions and for no other purpose.
This Platform is used exclusively for YPP internal party primaries. It is not a commercial service and does not sell, monetise, or use voter data for advertising or any non-electoral purpose.
Data Controller & Processor
| Role | Entity | Responsibility |
|---|---|---|
| Data Controller | Young Progressives Party (YPP) | Determines the purposes and means of processing personal data on this Platform. Registered with NITDA under the NDPA 2023. |
| Data Processor (Technology) | VoteTrack Ltd | Processes data solely on YPP's instructions. Maintains the Platform infrastructure, security controls, and audit trails. Bound by a Data Processing Agreement with YPP. |
| Data Processor (Infrastructure) | Supabase, Inc. | Cloud database and authentication infrastructure provider. Processes data in accordance with Supabase's Data Processing Agreement, ISO 27001 certification, and SOC 2 Type II compliance. |
| Data Processor (Communications) | SMS Gateway Provider (TBC) | Processes phone numbers for UVP delivery. Bound by NDPA-compliant data processing terms. Numbers not stored beyond delivery confirmation. |
Personal Data We Collect
3.1 Data Sourced from the YPP Member Registry (Read-Only)
The Platform accesses the following fields from the YPP Member Registry (portal.ypp.ng) in read-only mode to establish voter eligibility. We do not write to, modify, or delete any member data:
| Data Field | Purpose | Retention |
|---|---|---|
| Member ID / Membership Number | Link voter to their VoterRegister entry; INEC register | Duration of electoral cycle + 7 years (INEC requirement) |
| Full Legal Name | Voter roll, INEC register, accreditation verification | Duration of electoral cycle + 7 years |
| Phone Number (last 4 digits for UVP) | Default UVP generation (bcrypt-hashed; plain text not stored after generation) | Hash stored; plain digits purged after UVP delivery |
| State / LGA / Ward | Assign voter to correct VotingSession; delegate resolution | Duration of electoral cycle + 7 years |
| Membership Status / Date | Eligibility verification; cutoff date enforcement | Duration of electoral cycle + 7 years |
| INEC PVC Number (if available) | INEC register submission requirement | Duration of electoral cycle + 7 years (INEC requirement) |
3.2 Data Generated by Platform Use
| Data | Purpose | Retention |
|---|---|---|
| Accreditation timestamp & session ID | Confirm voter checked in; official electoral record | 7 years minimum (INEC) |
| Device type / user agent (anonymised) | Fraud detection; integrity monitoring | 90 days, then aggregated |
| IP address (partial — last octet masked) | Denial-of-service detection; geographic consistency check | 30 days, then purged |
| UVP hash (bcrypt) | Verify PIN at ballot time; never reversible to plain text | Duration of VotingSession, then purged |
| Vote Receipt Token | Voter self-verification; integrity audit | 7 years (INEC) |
| Accreditation count contribution | INEC turnout report | 7 years (INEC) |
3.3 Aspirant-Specific Data
| Data | Purpose | Retention |
|---|---|---|
| Aspirant application details (office sought, supporting docs) | Screening, INEC submission | 7 years |
| Screening outcome & panel notes | INEC compliance, appeal record | 7 years |
| Appeal submissions | Internal tribunal, potential court record | 10 years |
| Consensus / withdrawal consent | INEC mandatory record | 10 years |
| Aspirant login credentials (email + bcrypt password hash) | Account access control | Until account deletion or 2 years post-primary |
3.4 Panel / Administrator Data
Panel members and administrators who access the screening or administrative dashboards provide their name, party role, and login credentials. This data is used solely for access control, audit trail attribution, and INEC compliance reporting.
Data We Do NOT Collect
The following data is not collected by this Platform:
- How you voted — The
Votetable contains nomember_idcolumn. Your ballot choice and your identity exist in separate, uncrossable database structures. - Your plain-text UVP — UVPs are hashed immediately upon generation. Plain-text PINs are transmitted once (via SMS) and are never stored anywhere on the Platform.
- Biometric data — No fingerprints, facial recognition, or other biometric data are collected.
- Financial data — No payment card details or bank account information are collected.
- Location data — No GPS coordinates or precise location data are collected.
- Social media profiles or third-party account data.
- Sensitive personal data beyond what is strictly necessary for electoral eligibility (e.g., health data, religious beliefs, ethnic origin are not collected).
Legal Basis for Processing
Under the Nigeria Data Protection Act 2023 (NDPA), we rely on the following lawful bases for processing personal data:
| Processing Activity | Legal Basis (NDPA 2023) | Statutory Authority |
|---|---|---|
| Voter eligibility verification | Legal obligation | Electoral Act 2022, s.82–84; INEC Guidelines on Party Primaries |
| VoterRegister generation & INEC submission | Legal obligation | Electoral Act 2022, s.82; INEC Registration of Voters Regulations |
| UVP generation and delivery | Contractual necessity (party membership) | YPP Constitution; Terms of Service |
| Ballot casting and recording | Legal obligation + contractual necessity | Electoral Act 2022; YPP Constitution s.51(b) |
| Vote receipt generation | Legitimate interests (electoral integrity) | Balanced against minimal data use |
| Aspirant screening records | Legal obligation | Electoral Act 2022, s.82; INEC Guidelines |
| Audit trail / fraud detection | Legitimate interests (security and integrity) | Balanced against data minimisation |
| INEC Result Report | Legal obligation | Electoral Act 2022, s.64–67 |
| Platform administration & security | Legitimate interests | Balanced against proportionality |
We do not rely on consent as the primary legal basis for processing voter data in the context of party primaries, because processing is primarily required by law. However, we are committed to transparency and will always inform you of how your data is used.
How We Use Your Data
We use personal data collected through the Platform for the following specific purposes:
- Electoral administration: Generating and managing VoterRegisters, processing accreditation, administering ballots, and producing official results.
- INEC compliance: Producing and submitting the INECRegisterSubmission, INEC Result Reports, compliance items, and all other documents required by INEC within statutory deadlines.
- Voter authentication: Verifying UVPs at the time of voting to prevent double voting and enforce session eligibility.
- Aspirant management: Processing applications, conducting screening, recording appeals and consensus decisions, and maintaining required INEC records.
- Platform security and integrity: Detecting and preventing fraud, system abuse, and prohibited conduct as defined in the Terms of Service.
- Audit and forensic review: Maintaining a tamper-evident log of all Platform activities to support post-election audits, INEC inspections, and court proceedings if required.
- Voter verification: Allowing voters to verify their own participation via the Receipt Token system (never revealing vote choices).
International Data Transfers
The Platform's primary cloud infrastructure is provided by Supabase, Inc., which may store and process data on servers located in the United States of America and/or the European Union.
In conducting these transfers, we rely on the following safeguards in compliance with NDPA 2023 and NDPR 2019 requirements for cross-border data transfers:
- Contractual clauses: Our Data Processing Agreement with Supabase incorporates Standard Contractual Clauses approved by the Nigeria Data Protection Commission (NDPC).
- Technical safeguards: All data is encrypted in transit (TLS 1.3) and at rest (AES-256), and Supabase is ISO 27001 certified and SOC 2 Type II compliant.
- Data minimisation: Only the minimum necessary data is stored in the cloud infrastructure. Sensitive operational data uses additional application-level encryption.
Data Retention
| Data Category | Retention Period | Basis |
|---|---|---|
| VoterRegister (locked snapshots) | 7 years from election date | Electoral Act 2022; INEC Guidelines |
| Accreditation records | 7 years from election date | Electoral Act 2022 |
| INEC submission records | 10 years | INEC archival requirements |
| Vote Receipt Tokens (anonymised) | 7 years | Electoral integrity; INEC audit rights |
| Aspirant application & screening records | 7 years from election date | Electoral Act 2022 |
| Appeal records | 10 years (potential court use) | Evidence Act 2011; Electoral Act 2022 |
| Consensus consent records | 10 years | INEC mandatory; Evidence Act 2011 |
| Audit trail / system logs | 2 years | Legitimate interest (security) |
| Partial IP addresses | 30 days | Legitimate interest; proportionality |
| Aspirant account credentials | 2 years post-primary or until deletion | Contractual |
| SMS delivery logs (anonymised) | 90 days | Legitimate interest (delivery verification) |
| Aggregated, anonymised analytics | Indefinite | No personal data; public interest |
Upon expiry of the applicable retention period, data is securely deleted using cryptographic erasure (for cloud-stored data) or physical destruction (for any printed records). Where data forms part of an ongoing legal proceeding, retention is extended until the proceeding concludes.
Security Measures
We implement the following technical and organisational measures to protect your personal data:
Schema-Level Ballot Secrecy
Vote table contains no member_id — architectural guarantee, not policy.
SECURITY DEFINER Procedures
All votes are cast exclusively through cast_vote_secure — no direct table insertion possible.
bcrypt PIN Hashing
UVPs are hashed with bcrypt (cost factor 12) immediately upon generation. Plain text is never persisted.
Row Level Security (RLS)
Database-level access controls ensure each role sees only the data it is authorised to see.
VoterRegister Immutability
Once snapshot_locked = true, the register is frozen at the database level. No UPDATE is possible.
Encryption in Transit
All communications use TLS 1.3 with HSTS enforcement.
Encryption at Rest
All database storage uses AES-256 encryption at the infrastructure level.
Tamper-Evident Audit Trail
All administrative actions are logged with timestamps, user IDs, and action types.
Access Control
Principle of least privilege enforced. Role-based access (voter / aspirant / panel / admin).
Penetration Testing
Platform subjected to independent security assessment prior to each election cycle.
Your Rights Under the NDPA 2023
As a data subject under the Nigeria Data Protection Act 2023, you have the following rights with respect to your personal data processed on this Platform:
Right to Information
You have the right to be informed about how your data is used. This Privacy Policy fulfils that obligation.
Right of Access
You may request a copy of the personal data we hold about you. Requests will be responded to within 21 days.
⚠ We cannot provide your ballot choice because it is technically inaccessible — the secrecy architecture makes it impossible.
Right to Rectification
You may request correction of inaccurate personal data. Note that the VoterRegister is locked once a snapshot is taken — corrections must be submitted before the snapshot date.
⚠ Corrections to INEC-submitted records require INEC approval.
Right to Erasure
You may request deletion of personal data that is no longer necessary.
⚠ We are unable to delete electoral records that are required by the Electoral Act 2022 or INEC for the statutory retention period. Such requests will be refused with reasons, and you retain the right to complain to the NDPC.
Right to Object to Processing
You may object to processing based on legitimate interests. We will assess your objection and cease processing unless compelling legitimate grounds override your interests.
⚠ Objection to legally mandated electoral processing (e.g., INEC submission) cannot succeed but will be considered.
Right to Data Portability
You may request a copy of data you provided to us in a structured, machine-readable format.
⚠ Applies only to data you actively provided (e.g., aspirant applications), not to data derived from electoral administration.
Right Not to Be Subject to Automated Decisions
No solely automated decisions with significant legal effects are made about you on this Platform. Eligibility determinations are reviewed by the YPP Electoral Committee.
To exercise any of these rights, contact our Data Protection Officer at dpo@votetrack.ng. Requests are processed within 21 days; complex requests may be extended by a further 30 days with notice.
Children's Data
This Platform is intended solely for use by persons aged 18 years or older (the minimum voting age under the Constitution of the Federal Republic of Nigeria 1999). We do not knowingly collect personal data from persons under 18.
If you believe a person under 18 has used this Platform, please contact us immediately at dpo@votetrack.ng. Any data collected from a minor will be deleted promptly upon verification.
Complaints, Contact & Supervisory Authority
13.1 Data Protection Officer
Our Data Protection Officer can be reached at:
Data Protection Officer — VoteTrack Ltd
Email: dpo@votetrack.ng
Subject line: YPP Mandate — Privacy Request
Ref: YPP/ICT/EVOT/001/2026
13.2 Supervisory Authority
If you are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with Nigeria's data protection supervisory authority:
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in the law, our data practices, or the Platform's features. Material changes will be notified via SMS or in-Platform notice at least seven (7) days before taking effect.
The current version is always accessible at vote.ypp.ng/legal/privacy. Your continued use of the Platform after any change constitutes acceptance.
No change to this policy will retroactively alter the legal basis or manner in which we processed data prior to the change.
NDPA 2023 Compliance Statement
This Privacy Policy is published in compliance with Sections 24 and 25 of the Nigeria Data Protection Act 2023 and Article 2.5 of the Nigeria Data Protection Regulation 2019. YPP is registered with the Nigeria Data Protection Commission (NDPC) as a data controller. VoteTrack Ltd is registered as a licensed data protection compliance organisation.
© 2026Young Progressives Party & VoteTrack Ltd | Ref: YPP/ICT/EVOT/001/2026