1. Operating Entity & Core Principles
This Privacy Policy describes how Leatra Technologies LTD (“Leatra Technologies”, “ZapPoll”, “we”, “us”, or “our”), a company registered and incorporated under the laws of the Federal Republic of Nigeria, collects, protects, processes, and handles personal data through our software platform at zappoll.com, app.zappoll.com, and our ingestion endpoints at api.zappoll.com.
ZapPoll was architected specifically to dismantle surveillance-capitalism models in survey and form software:
- Zero Cross-Site Ad Tracking: We do not deploy third-party advertising cookies, retargeting pixels, social trackers, or data-broker SDKs.
- Per-Poll Commercial Model: Capabilities are purchased as discrete, one-time grants tied permanently to an individual poll. We do not store persistent billing profiles to execute recurring auto-renewals.
- Invariant Privacy Ceilings: Purchasing additional capacity or advanced analytics never weakens a privacy promise. Payment cannot buy access to deanonymize respondents.
A commercial purchase controls feature availability and response capacity; it never overrides identity, privacy tiers, authorization, or small-sample statistical suppression.
2. The Creator vs. Respondent Boundary
ZapPoll enforces a strict architectural boundary between two distinct user roles:
Creators
Creators design, configure, publish, and analyze polls or headless form endpoints. Creators authenticate through our dedicated authentication gateway (powered by Keycloak) using passwordless methods (single-use Email OTP or Google identity brokering) with PKCE-protected tokens stored exclusively in browser memory. Creators belong to workspaces that own polls and billing records.
Respondents
Respondents submit votes, answers, or form data. Respondents never enter the creator authentication boundary and never need an account to participate. A respondent opens a link, scans a QR code, or submits an external form. Respondent access is scoped strictly to that specific poll and cannot inherit creator permissions or cross workspace boundaries.
3. The Four Privacy Tiers
When a creator publishes a hosted poll, they select one of four immutable privacy tiers. Once the first response is accepted, the privacy tier is permanently locked for that poll ID.
| Privacy Tier | What Creators See | Individual Row Access | Respondent Identifiers |
|---|---|---|---|
| Anonymous | Aggregate results only. Cells with fewer than 5 responses are strictly suppressed. | Prohibited. Row-level data is never queryable, exportable, or logged. | Zero. No IP, user-agent, email, name, or session handle is linked to answers. |
| Confidential | Shuffled, decoupled individual rows released only after ≥ 5 submissions exist. | Allowed in delayed batches. Timestamps are coarsened. | Decoupled. Single-use return credentials permit edits/withdrawals without disclosing identity. |
| Pseudonymous | Answers grouped by an opaque, poll-scoped pseudonym. | Allowed per pseudonym. Pseudonym resets across different polls. | Opaque handle only; no external account IDs, names, or reversible hashes. |
| Identified | Full responses with attached verified or self-reported identity. | Allowed. Respondent sees explicit disclosures before submitting. | Attached (e.g. verified email OTP, SSO subject, or explicit form inputs). |
In the Anonymous tier, ZapPoll enforces an invariant mathematical threshold: no cross-tab, filter, or chart view displays cohorts with fewer than 5 responses. This mathematically prevents differencing attacks from isolating individual respondent answers.
4. Information We Collect & Why
A. Information Collected from Creators
- Account Identity: Verified email address and name provided during passwordless login. We do not store passwords.
- Workspace & Configuration Data: Workspace titles, poll definitions, question schemas, brand color configurations, and notification webhook destinations.
- Commercial Transaction Records: Invoice references, transaction timestamps, purchased entitlements, and currency amounts. Payment card processing is handled directly by our certified PCI-DSS Level 1 payment gateway; Leatra Technologies LTD never handles or stores raw payment card numbers (PAN/CVV).
B. Information Collected from Respondents
- Poll Responses: Answers, selections, ratings, or text inputs submitted into a poll or form endpoint.
- Access Verification Data (Tier-Dependent): If a creator configures Email OTP or Respondent SSO, the respondent's verified email address or SSO token subject is validated solely to enforce single-response multiplicity, then handled according to the selected privacy tier.
- Volatile Edge Metadata: IP address and client header fingerprints are processed transiently in volatile memory at the edge for rate-limiting, DDoS mitigation, and anti-stuffing protection. In Anonymous and Confidential polls, IP addresses are never persisted with answer records.
C. Information Collected from Website Visitors
When you browse our public website at zappoll.com, our edge network (Cloudflare) collects
standard server log records (IP address, requested path, HTTP status, and user-agent string) strictly
for security monitoring, caching, and network diagnostics.
5. Forms Collection (Headless Endpoints) & Liability Boundary
ZapPoll provides a headless Forms Ingestion API where developers point existing HTML forms directly to our ingestion endpoints. In this architecture:
- Role of the Creator (Independent Data Controller): The creator (website owner) is the sole Data Controller responsible for providing notice, obtaining valid consent, accessibility, and lawful processing on their external website.
- Role of Leatra Technologies LTD (Data Processor): Leatra Technologies LTD acts strictly as a Data Processor providing input validation, envelope encryption at rest, abuse filtering, and creator inbox storage.
- No Responsibility for External Collection: Leatra Technologies LTD does not monitor, inspect, or verify external website collection practices. The creator is solely liable for any regulatory fines, claims, or disputes arising from data collected on their external website.
- Prohibited Ingestion: ZapPoll form endpoints must never be configured to harvest sensitive credentials, passwords, raw payment card data, private cryptographic keys, or government national identifiers.
6. Legal Bases for Processing (NDPA 2023 & GDPR Art. 6)
Under the Nigeria Data Protection Act (NDPA 2023), the European Union General Data Protection Regulation (GDPR), and the UK GDPR, we process personal data under the following lawful bases:
- Performance of a Contract (NDPA Section 25 / GDPR Art. 6(1)(b)): To authenticate creators, provision workspaces, process capability purchases, and deliver polling and form endpoints as contracted.
- Legitimate Interests (NDPA Section 25 / GDPR Art. 6(1)(f)): To secure our network, prevent automated vote manipulation and spam, mitigate DDoS attacks, and enforce capacity admission limits.
- Compliance with Legal Obligations (NDPA Section 25 / GDPR Art. 6(1)(c)): To maintain accurate corporate financial, statutory tax, and billing audit records under Nigerian and international commercial law.
- Consent (NDPA Section 25 / GDPR Art. 6(1)(a)): Where creators or respondents voluntarily opt in to specific communications or optional notifications.
7. Data Sharing & Sub-processors
We never sell, rent, monetize, or broker personal data to data aggregators or advertisers. We share data only with infrastructure sub-processors essential to operating the platform:
| Sub-processor | Purpose | Data Transferred | Location |
|---|---|---|---|
| Cloudflare, Inc. | Edge CDN, DDoS mitigation, static asset hosting | IP addresses, transient request headers | Global Edge Network |
| Hetzner Online GmbH | Secure VPS hosting (Go API, PostgreSQL, Keycloak) | Encrypted application databases, creator accounts | European Union (Germany/Finland) |
| Supromail / Transactional SMTP | Transactional email (Email OTP login codes) | Recipient email address, verification codes | European Union |
| Stripe / Merchant of Record | Payment settlement, tax calculation, invoices | Billing name, transaction amount, tax location | United States / Global |
8. Security & Encryption at Rest
Leatra Technologies LTD implements technical and organizational safeguards engineered for high security:
- Encryption in Transit: Strict HTTPS with TLS 1.3 across all services, with HSTS enabled for one year.
- Envelope Encryption at Rest: Form submission payloads and sensitive response fields are encrypted at rest using AES-256 envelope encryption. Database backups and disks are encrypted.
- Memory-Only Credentials: Creator authentication tokens use PKCE S256 and reside only in volatile browser memory. Tokens are never stored in localStorage, sessionStorage, cookies, or application logs.
- Network Isolation: Application PostgreSQL and Keycloak PostgreSQL databases reside on isolated internal Docker networks with no exposed public ports.
9. Data Retention & Deletion Rights
We retain data only as long as necessary to fulfill the purposes outlined in this policy:
- Poll Data: Creators maintain full control over their poll and form data. Creators can delete individual responses, wipe form inboxes, or delete entire polls at any time.
- Permanent Purging: When a poll or workspace is deleted by a creator, the associated encrypted responses, schemas, and entitlement records are permanently deleted from active databases within 24 hours.
- Account Deletion: Creators may request account deletion at any time. All associated personal data is erased, except for financial records required by statutory tax laws.
10. Your Legal Rights (NDPA, GDPR & CCPA)
Depending on your jurisdiction, you possess statutory data protection rights:
- Nigeria Data Protection Act (NDPA 2023): Nigerian data subjects have the right to request access, rectification, erasure, and objection to processing, and lodge complaints with the Nigeria Data Protection Commission (NDPC).
- GDPR / UK GDPR: European and UK residents have rights of access, rectification, erasure (“right to be forgotten”), restriction, data portability, and right to lodge a complaint with a supervisory authority.
- California Consumer Privacy Act (CCPA/CPRA): California residents have the right to know what personal information is collected, request deletion, and opt out of any sale of personal information. Leatra Technologies LTD does not sell personal information.
To exercise any of these rights, contact our Data Protection Officer at [email protected].
12. Corporate & Data Protection Officer Contact
For legal notices, data protection inquiries, or regulatory communications: