We recently worked with a client who wanted to set up a digital savings platform in Nigeria. Shortly after offering the client legal advice as regards regulatory requirements for setting up their digital platform, they engaged the services of a developer, who commenced work on developing a mobile app and a website.

They however reached out to us afterward, because they had gotten stuck on the project. Google had brought their project to a halt as they had failed to comply with one or more of their developer program policies. They needed our help with the policies, and we swung into action.

The issue was resolved in no time, and they had their app approved on Google Play Store!

Are you about developing a mobile app or a website? Have you come across a similar experience such as the above?

In this article, we will consider the legal documents you need for setting up your mobile app or website. This will help you avoid similar challenges faced by our client above while starting out.


With most of us living our lives and doing business online, there has been an increased conversation on subjects related to the World Wide Web such as; data privacy, online bullying, curbing down fraudulent businesses online, etc. To this end, technology companies such as Google, Facebook, etc. have legal policies that developers or anyone who wishes to host or integrate their products or services, must comply with.

Furthermore, with Google being the most powerful multinational technology company in the world with a large usage, complying with their policies is a must if you want your website or mobile app to be accessed by any audience. Google has one of the most used hosting platforms for mobile apps, to have the content on your website exposed to a large audience, you need Google. And to integrate Google’s products or services, your mobile app and or website, must comply with its legal policies.

The easiest way to comply with developer program policies is to have your legal documents in place and ensure they meet up with these policies.

For those of you who own basic informative websites, it’s very easy to assume that your website doesn’t need legal documents. So long as your website is live, it tracks information about your visitors and it is therefore your responsibility to let them know how such information is tracked, as well as where it is stored.

If your website is for e-commerce purposes, having legal documents or policies on your website, makes transactions carried out to be legally binding.

It also builds trust with your users. Users are now aware of their data protection rights. Therefore when they see you have these policies, it makes them feel safe doing business with you on your website.


In Nigeria, data protection and privacy is governed by the Nigeria Data Protection Regulation (NDPR).  The regulation covers the storage and processing of data by citizens and residents. Below are the policies that are guaranteed to ensure your website and mobile app are NDPR compliant.

Privacy policies

A privacy policy assures, users of your website that all personal information (such as; visitors’ names and emails, payment card information, etc.) provided by them in the course of using your website is protected and will not be disclosed to third parties. The law mandates website and mobile app owners to protect the personal information of their users. To this end, having a privacy policy on your website creates a sense of security for users who have no personal knowledge of you or your business and may have reservations about doing business with you.

By the way, are you aware that to enable your website to make use of important online marketing tools from software companies such as Facebook, and Google you need a privacy policy?

Please bear in mind that a privacy policy contains information such as; what user information you receive, how you use visitor information, who you share it with, how long data collected is retained etc.

Cookie pop-ups and Consent banner

Cookies are text files with small pieces of data like a username and password that are used to identify your computer. When you use a computer network, cookies are placed on the device used to access a website, and more than one cookie may be placed on a user’s device during a session.

Most websites, if not all, use cookies. Thus, a cookie banner should be displayed whenever visitors interact with your website for the first time.

Terms and Conditions/ Terms of Use

Terms and conditions (T&C) are rules your web or mobile app users are required to follow should they choose to use your website or mobile application. If you sell a service or product directly from your website, you should consider, putting up a T&C.

A  T & C protects you and your business from errors or technical challenges which may occur while using your website or mobile app, particularly errors that are out of your control.


Prior to now, you could automatically add emails of persons who downloaded freebies from your website without their consent. However, that is currently not the case as your visitors must give their consent to be added to your mailing list.

To achieve this, you must leave room in your sign-up form, for subscribers to consent to be added to your email list.


Below are a few checklists to ensure the legal documents on your website or mobile app, satisfy the conditions for compliance.

  • Ensure all legal documents are on your website
  • Ensure that all legal documents are visible and accessible on all pages of your website
  • Ensure that the sign-up process is designed in a way that shows that website users had the option of going through the policies before their consent was given.

Designing policies for your website or mobile app can be a tedious aspect of setting up your website. But that is the only effective way of protecting your business from likely legal issues with users.

To provide your customers with the ultimate experience, you must ensure that all clauses contained in policy documents are consistent with what is obtainable in your business. Lifting contents of policies/legal documents from other websites is risky as you may end up making false statements about your own practices which may amount to a crime. In addition, laws governing the geographical location from which a website or mobile app is created and operates vary from one country to another. Seek professional help from experienced business lawyers who are up to date with data protection laws to enable you to come up with airtight legal documents for your website.

Finally, ensure your policies are up to date as they may change from time to time.

Need help with preparing new legal documents/policies for your website? Or if you already have these policies but you need to make an update on these documents, you may reach out to us through the Whatsapp icon on the lower right part of this page or here, and we will be delighted to assist you.


Cynthia Tishion
Cynthia is a lawyer and currently serves as Head of Corporate / Commercial Services at LEX – PRAXIS. With her passion for business and entrepreneurship, she is actively engaged in creating awareness on the legal aspect of businesses through various platforms such as writing, public speaking engagements.

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