privacy policy

Greena | Effective Date: 1 July 2026

Your privacy is important to us

  1. Introduction and Who We Are

Greena Technologies Limited ("Greena", "we", "us", or "our") is a technology company incorporated under the laws of the Federal Republic of Nigeria. We operate Greena — a cloud-based e-invoicing and tax compliance platform ("Platform") — that helps Nigerian businesses issue NRS-compliant electronic invoices.

We are registered with the Nigeria Data Protection Commission (NDPC) as a Data Controller and Data Processor, and we operate in compliance with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR) 2019, and all applicable subsidiary legislation.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what your rights are. It applies to:

  • Visitors to our website at www.greena.ng

  • Registered users of the Platform

  • Buyers who transact through our public-facing checkout

  • Any other person whose personal data we process

Please read this policy carefully. By using our Platform or website, you confirm that you have read and understood it.

  1. Our Certifications and Compliance Framework

Greena holds the following relevant certifications and registrations:

Certification / Registration

Issuing Body

NDPC Data Controller Registration

Nigeria Data Protection Commission

NDPC Data Processor Registration

Nigeria Data Protection Commission

CAC Business Registration

Corporate Affairs Commission, Nigeria

We conduct annual Data Protection Impact Assessments (DPIAs) and engage a qualified Data Protection Officer (DPO) as required under the NDPA 2023. Our DPO can be contacted at dpo@greena.ng.

  1. Personal Data We Collect

We collect only the data that is necessary for the purposes described in this policy. The categories of data we collect depend on how you interact with us.

3.1 Account and Identity Data

  • Full name

  • Business name and registered address

  • Tax Identification Number (TIN)

  • Email address

  • Phone number

  • Role within your organisation (e.g. Admin, Issuer, Viewer)

3.2 Financial and Transaction Data

  • Invoice details (items, quantities, amounts, VAT)

  • Customer billing information

  • Payment transaction references

  • Bank account details (where applicable for payouts)

3.3 Compliance and Fiscal Data

  • Invoice Reference Numbers (IRNs) issued by the NRS

  • QR codes embedded in fiscalised invoices

  • Submission timestamps and gateway response records

  • Audit log entries tied to invoice state changes

3.4 Customer Data (Processed on Your Behalf)

When you use the Platform to issue invoices, you upload data about your own customers ("End Customers"). This includes their names, email addresses, TINs, and purchase details. For this data, you are the Data Controller and we act as your Data Processor. See Section 9 (Data Processing Agreement) for details.

3.5 Technical and Usage Data

  • IP address

  • Browser type and version

  • Device information

  • Session activity and access logs

  • Pages visited and features used on the Platform

3.6 Communications Data

  • Support tickets and messages sent to our team

  • Email correspondence with Greena

  • Feedback and survey responses

3.7 Public Checkout Data (Buyers)

If you make a purchase through a Greena-powered public checkout page, we collect your name, email address, phone number, and transaction reference. This data is used to generate an invoice and create a buyer record for the merchant.

  1. How We Collect Personal Data

We collect personal data through the following means:

  • Directly from you — when you register, complete your profile, create invoices, or contact support

  • Automatically — through cookies, server logs, and analytics tools when you use the Platform or visit our website

  • From third parties — payment processor transaction confirmations; NRS gateway responses; your colleagues when an Administrator adds you to an Organisation account

  1. Legal Basis for Processing

We process personal data only where we have a lawful basis to do so under the NDPA 2023. The applicable bases are:

Processing Activity

Legal Basis

Creating and managing your account

Performance of a contract (NDPA s.25(1)(b))

Submitting invoices to the NRS

Legal obligation (NDPA s.25(1)(c)); NRS MBS compliance

Processing payments

Performance of a contract

Fraud prevention and security

Legitimate interests (NDPA s.25(1)(f))

Sending product updates and announcements

Legitimate interests / Consent

Sending marketing emails

Consent (NDPA s.25(1)(a))

Analytics and Platform improvement

Legitimate interests

Responding to support requests

Performance of a contract / Legitimate interests

Complying with regulatory requests

Legal obligation

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Where we rely on legitimate interests, we have conducted a balancing test and determined that our interests do not override your fundamental rights and freedoms. You may request a summary of that assessment by contacting our DPO.