1. Who We Are
This site is operated by AFRISOVERA NIGERIA LIMITED, a private limited company registered in Nigeria with the Corporate Affairs Commission (RC No. [pending — to be updated post-incorporation]), with its registered office at [Nigerian registered office address — Lokoja, Kogi State].
For the purposes of NDPR + NDPA, we are the Data Controller of personal data collected through this site and our related operations.
2. Data Protection Officer (DPO)
Our designated Data Protection Officer / data protection contact:
- Name: Jonathan Akinbolade Afolayan, Director (acting DPO in Phase 0; dedicated DPO to be appointed by Stage E)
- Email: privacy@afrisovera.com.ng
- Phone: +234 [Nigerian number]
- Postal: Data Protection — AFRISOVERA NIGERIA LIMITED, [registered office]
3. What Personal Data We Collect
We collect the following categories of personal data:
3.1 Contact information
- Full name
- Email address
- Nigerian phone number
- LGA / State of residence
3.2 Application information (Afrisovera Builders programme)
- Age
- Trade interest / specialization preference
- Educational background (when applying)
- Previous work experience (when applying)
- NIN (only at point of formal enrollment, not at expression of interest)
3.3 Technical information
- IP address
- Browser type + version
- Device type
- Pages visited + time on site
- Referrer URL
4. Lawful Basis for Processing
Under NDPR, all personal data processing requires a lawful basis. We rely on:
| Purpose | Lawful basis (NDPR Art. 2.2) |
|---|---|
| Responding to expressions of interest in Afrisovera Builders | Consent (you initiated the contact) |
| Career application processing | Consent + Pre-contractual step |
| Site analytics + security | Legitimate interest (operational necessity) |
| Marketing communications (when opted-in) | Consent |
| Legal compliance (taxation, employment law if employed) | Legal obligation |
5. How We Use Your Data
Personal data collected is used to:
- Respond to your enquiries
- Process Afrisovera Builders applications
- Contact you about programmes you have applied for
- Improve the site experience
- Ensure security (block bots + attackers)
- Send opted-in marketing communications
- Comply with our legal obligations under Nigerian law
We do NOT:
- Sell your personal data
- Share your data with third parties for their marketing purposes
- Use your data for purposes outside what you originally consented to
6. Cross-Border Data Transfer
AFRISOVERA NIGERIA LIMITED is sister-company to AFRISOVERA GLOBAL HOLDINGS LIMITED (United Kingdom). Some personal data may be transferred to the UK parent for legitimate operational purposes:
- Group accounting + transparency reporting
- Founder + director-level communications
- Strategic planning + investor relations (anonymized aggregate data only)
Such transfers are protected by:
- An inter-company Data Processing Agreement (IDPA) between AFRISOVERA NIGERIA LIMITED and AFRISOVERA GLOBAL HOLDINGS LIMITED
- The UK General Data Protection Regulation (UK GDPR) protections at the UK side
- NDPC-approved Standard Contractual Clauses (SCCs) when required
You consent to these transfers as part of using this site.
7. Data Retention
| Data category | Retention period |
|---|---|
| Career application data | 2 years from last activity (or longer if you become an employee) |
| General enquiry data | 1 year from last interaction |
| Site analytics | 26 months (per Google Analytics default) |
| Employee data | Per Nigerian employment law + tax requirements |
| Financial records | 6 years (per CAMA + FIRS requirements) |
8. Your Rights Under NDPR + NDPA
You have the following rights:
- Right to be informed — about the processing of your personal data
- Right of access — to obtain a copy of your personal data we hold
- Right to rectification — to correct inaccurate or incomplete personal data
- Right to erasure — to request deletion of your personal data (subject to legal retention obligations)
- Right to restrict processing — to limit how we use your personal data
- Right to data portability — to receive your personal data in a structured, common format
- Right to object — to processing based on legitimate interests or for marketing
- Right to withdraw consent — where processing is based on consent
- Right to lodge a complaint — with the Nigeria Data Protection Commission (NDPC)
To exercise any of these rights, contact our Data Protection Officer at privacy@afrisovera.com.ng. We will respond within 30 days.
9. Right to Complain to the NDPC
If you are dissatisfied with how we handle your personal data, you can lodge a complaint with the Nigeria Data Protection Commission:
- Website: https://ndpc.gov.ng
- Email: info@ndpc.gov.ng
- Address: Nigeria Data Protection Commission, [current NDPC office address]
We encourage you to contact us first so we can address your concerns directly.
10. Cookies
We use cookies and similar technologies. See our separate Cookie Policy for full details.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
- HTTPS encryption for all data in transit
- Cloudflare DDoS protection + WAF
- Access controls — only authorized personnel access personal data
- Regular security audits
- Data minimization — we collect only what's necessary
- Breach notification within 72 hours to NDPC if a breach occurs (per NDPR Art. 2.6)
12. Children's Data
We do not knowingly collect personal data from children under 18 without parental/guardian consent. Afrisovera Builders applications are open to those 16+; applicants under 18 require parental consent.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via the site and (where applicable) by email to registered users.
14. Contact
For any questions about this Privacy Policy or our data practices:
- Email: privacy@afrisovera.com.ng
- Post: Data Protection — AFRISOVERA NIGERIA LIMITED, [registered office]
- Phone: +234 [Nigerian number]