Enugu Life Privacy Notice
Version: 2026-10-07
This notice explains what personal data Enugu Life collects, why, where it is kept, for how long, and what your rights are under the Nigeria Data Protection Act 2023 (NDPA). It is part of our Terms of Service.
1. Who is responsible for your data
The data controller is [PLACEHOLDER: operator legal name]. For anything about your data, write to [PLACEHOLDER: contact email]. Postal address: [PLACEHOLDER: postal address]. Data protection officer: [PLACEHOLDER: name and contact of the data protection officer, if one is appointed]. NDPC registration: [PLACEHOLDER: registration number, or "not yet registered"].
2. The short version
- Enugu Life is for adults only. If you are under 18 we refuse the sign-up and keep nothing.
- We collect what we need to run the game: your email, a scrambled (hashed) password, your date of birth, your character, your game activity, and the messages you send.
- We do not record voice chat.
- We do not sell your data, show you ads, or use analytics or tracking tools.
- Everything is stored on our own server in France.
- You can delete your account in the game at any time.
3. What we collect and why
| What | Why | Lawful basis (NDPA s.25) |
|---|---|---|
| Email address | Your sign-in name, and how we contact you about your account | Contract |
| Password | Sign-in. We store only a scrambled form (an scrypt hash), never the password itself | Contract |
| Date of birth | To check you are 18 or over, at sign-up and again before voice chat | Contract and legitimate interest (keeping minors out) |
| When you accepted these terms, and which version | Proof that you agreed | Legitimate interest |
| Your character: name, @username, body and look, in-game phone number, where it is, its needs, goals, skills and work style | Playing the game. Your name, @username and look are shown to other players | Contract |
| Home, furniture, items and bills | Playing the game | Contract |
| In-game money record (every ₦ payment, wage, purchase and transfer, with any note you add to a transfer) | Running the in-game economy, tracing mistakes, cheating and fraud | Contract and legitimate interest |
| Area group chat and direct messages (DMs) | Delivering your messages | Contract |
| Blocks you make, reports you file and reports about you, and any warnings, mutes or bans | Keeping players safe | Legitimate interest |
| Sign-in sessions (a random token, stored only in scrambled form, and when it expires) | Keeping you signed in | Contract |
| Your IP address, held for up to 15 minutes | Limiting repeated sign-in attempts and @username lookups | Legitimate interest (security) |
Speech bubbles (what you type in the street) are passed to nearby players and are not stored.
4. Voice chat
Proximity voice chat is optional. When you join, your microphone audio goes to our own voice server (LiveKit, which we run ourselves on our server; it is not a third-party service) and from there to the players near your character, in real time.
- We do not record, store or transcribe voice chat, and we do not use voices to identify anyone.
- Like any live call, the voice server handles your IP address and the audio stream while you are connected.
- Before we give you access to voice we check your date of birth again.
- If we ever add a way to attach a short voice clip to a report, we will tell you before it is switched on and update this notice.
5. Your device
We set one cookie, enugu_session, to keep you signed in. It lasts 30 days, or until you sign out. It is needed for the game to work.
The game also saves a few settings in your browser's local storage: sound levels, data saver, the first-time tips, and players you muted. These never leave your device.
We use no advertising or analytics cookies. We use the system's own fonts, so no font service sees your visit.
6. Who we share it with
We do not sell or rent your data, and we do not share it for advertising.
- Other players see your character's name, @username and look, what you say near them, your area chat messages, and the DMs you send them.
- Contabo, our server provider, rents us the server our game, database, voice server and backups run on. The server is in Lauterbourg, France. Contabo provides the machine; it does not use your data for its own purposes.
- Our domain's DNS is managed by Cloudflare. [PLACEHOLDER: confirm whether game traffic passes through Cloudflare's proxy; if it does, name Cloudflare here as a service provider that sees IP addresses and traffic.]
- OpenRouter is an AI model service. When you chat with a named character, the text you type to them (with a short description of your character's look and state, never your name, email or account details) is sent to OpenRouter and the AI model provider it picks, to write the character's reply. We keep that chat text for no longer than 15 minutes, only so the character can follow the conversation, and we do not store it after that. Do not share personal details with characters.
- Authorities: we may share data when Nigerian law requires it, for example a valid request from the police or a court, or to report child sexual abuse material.
The database, cache, voice server (LiveKit) and voice relay (TURN) are software we run ourselves on that server. They are not separate companies.
We do not use an email service, a payment service, an analytics service or an age-verification service yet, and the only AI service is the one above. If we add one, we will update this notice before it sees your data.
7. Your data leaves Nigeria
Our server is in France, so your data is transferred out of Nigeria and stored in the European Union. Nigeria has not made an adequacy decision for France. We protect the data as described in section 9, and [PLACEHOLDER: the transfer safeguard to be confirmed with a lawyer, for example an NDPC-approved transfer agreement]. When you tick the box at sign-up you also agree to this transfer.
8. How long we keep it
| What | How long |
|---|---|
| Your account, character, game data and sessions | Until you delete your account (sessions end after 30 days) |
| Area group chat and DMs | Until you delete your account. We plan to delete chat messages after 30 days automatically; until that is built, they stay until the account is deleted or the test is reset |
| Reports you filed, and your blocks | Until you delete your account |
| Reports about you, warnings, mutes and bans | Up to 2 years, even after you delete your account, to keep players safe and handle appeals |
| In-game money record | As long as the game runs. When you delete your account it is anonymised (see section 10) |
| Which version of the terms you accepted, and when | Kept after deletion, linked only to an anonymous account number, as proof of what was agreed |
| IP address for sign-in and lookup limits | Up to 15 minutes |
| Server access logs | [PLACEHOLDER: confirm how long the web server keeps access logs, which can include IP addresses] |
| Backups | Up to 7 days. Deleted data can stay in a backup until that backup is replaced |
| Under-18 sign-up attempts | Not stored at all |
During the test we may reset the game, which deletes game data for everyone.
9. How we protect it
- Passwords are stored only as scrypt hashes. Session tokens are stored only as hashes.
- The site uses HTTPS. The database and cache are not open to the internet.
- Only the developer can reach the server and the database.
- Server logs record events and error codes, not your email, date of birth, password or messages.
If a data breach is likely to put you at risk, we will tell the Nigeria Data Protection Commission within 72 hours of finding out, and tell you without delay if the risk is high.
10. Your rights
Under the NDPA you can:
- ask for a copy of your personal data;
- ask us to correct it;
- ask us to delete it;
- ask us to limit how we use it, or object to how we use it;
- ask for your data in a form you can move to another service;
- withdraw any consent you gave, without affecting what we did before;
- not be subject to decisions made only by a machine that seriously affect you. Our text filter only hides words or stops a message; any ban can be reviewed by a person.
To delete your account: in the game, open the Phone, then Settings, then Delete my account, and type your @username to confirm. This happens straight away and cannot be undone. We:
- delete your sessions, DMs (for both people in the conversation), the chat messages you sent, your home, items, blocks and the reports you filed;
- remove your email, password, date of birth, character name, @username, look and in-game phone number, and keep only an anonymous account number;
- keep the in-game money record so the accounts still add up, but anonymised: transfer notes you wrote are removed, and any money left is taken out of the game;
- keep reports about you and any sanctions, as set out in section 8.
For anything else, email [PLACEHOLDER: contact email]. We may ask you to confirm it is your account. We aim to answer within 30 days.
If you are not happy with our answer, you can complain to the Nigeria Data Protection Commission (NDPC), ndpc.gov.ng.
11. Under 18s
Enugu Life is not for anyone under 18. We do not knowingly keep data about children. If we learn an account belongs to someone under 18, we close it and delete its data.
12. Changes
If we change this notice in a way that matters, we will update the version at the top and ask you to accept it the next time you sign in.
13. Contact
[PLACEHOLDER: operator legal name], [PLACEHOLDER: contact email].