Privacy notice

This notice explains how [Company legal name] ("DPO Copilot", "we") handles personal data under the Nigeria Data Protection Act 2023 (NDPA).

Two roles

As a data controller, we process data about people who visit our website, request pilot access, or hold an account with us.

As a data processor, we process the personal data that DPCO firms and their clients put into DPO Copilot, only on the firm's instructions and under a data processing agreement. For that data, the firm (or its client) is the controller. Please contact them first about it.

What we collect as a controller

  • Pilot requests: your name, work email, firm name, phone number and message.
  • Accounts: name, email, password (stored only as a one-way hash), two-step sign-in settings, and sign-in records.
  • Security logs: IP address, browser type and the actions taken in the app.

Why and on what basis

  • Responding to a pilot request: steps you asked us to take before a contract (NDPA s.25).
  • Providing accounts and the service: performance of our contract with your firm.
  • Security, fraud prevention and audit trails: our legitimate interests and legal obligations.

Where your data is kept

We host the service with [hosting provider] in Nigeria. Client data is never used to train AI models. Our sub-processors are listed at [link to sub-processor list].

Who we share it with

Only our sub-processors (such as hosting and email delivery providers), under contract, and authorities where the law requires it. We don't sell personal data.

How long we keep it

  • Pilot requests: [12 months] after our last contact, unless you become a customer.
  • Account data: for the life of your firm's subscription, then [period] under our data processing agreement.
  • Audit logs: [6 years].

Your rights

You can ask for a copy of your personal data, ask us to correct or delete it, object to or restrict how we use it, ask for it in a portable format, and withdraw consent where we rely on it. You can also complain to the Nigeria Data Protection Commission.

Personal data breaches

If a breach affects data we process for a firm, we notify that firm without undue delay so it can meet its own obligations under NDPA s.40.

Contact

Data Protection Officer: [name], [email], [address].

Last updated: [date].