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Privacy Policy

Introduction

Code 19 Digital Solutions (“we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, and store personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR), and applicable international laws including, where relevant, the California Consumer Privacy Act (CCPA) and other U.S. privacy regulations.

By accessing our website or engaging our services, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

We may collect the following types of personal information from clients, prospects, and website visitors:

a. Identification & Contact Information

  • Full Name
  • Email Address
  • Phone Number
  • Company Name
  • Business Address

b. Professional or Service Information

  • Nature of your business or organization
  • Project requirements, documentation, or communications
  • Service preferences and feedback

c. Technical & Usage Data

  • IP address
  • Browser type and device information
  • Operating system
  • Pages visited on our website
  • Duration of visits and clickstream patterns

d. Communications

  • Email correspondences
  • Service inquiries or complaints
  • Invoice or contract-related exchanges

Note: We do not collect or process payment card information on our website. However, we may issue service invoices via email and process payments through secure, third-party banking or invoicing platforms.

2. How We Collect Your Data

We collect your data through:

  • Website contact forms
  • Email and business communications
  • Discovery or consultation calls
  • Voluntarily submitted project briefs
  • Automatic website analytics and cookies

3. How We Use Your Data

We use the data we collect for the following purposes:

  • To communicate with you about your inquiries or projects
  • To issue service invoices and contracts
  • To deliver our digital and IT solutions effectively
  • To understand client needs and improve our service offerings
  • To respond to legal obligations or enforce agreements
  • To send you service updates or company news (only if you opt-in)

4. Legal Basis for Processing

Our processing of personal data is based on:

  • Consent — where you explicitly give permission
  • Contract — to perform our obligations to you under a service agreement
  • Legal Obligation — where necessary to comply with legal or regulatory requirements
  • Legitimate Interest — where processing is required for our operations, and your rights do not override such interest

5. Who We Share Your Data With

We do not sell your personal data. However, we may share your information with trusted third parties including:

  • Cloud-based project management or invoicing platforms (e.g., Google Workspace, Trello, Notion, Zoho)
  • Communication and collaboration tools (e.g., Slack, Zoom)
  • Data storage or hosting service providers
  • Legal or regulatory bodies, when legally required
  • Trusted third-party payment processors when absolutely necessary.

All third-party service providers we engage must comply with data protection laws applicable to their jurisdictions and sign appropriate data protection agreements.

6. International Clients (Including United States)

If you are a client or visitor from the United States, we are committed to ensuring your data rights and privacy expectations are met. While Nigeria is our country of operation, we follow internationally recognized privacy frameworks and provide the following assurances:

  • Your data will be processed in accordance with lawful bases, and only for the purposes outlined in this policy.
  • We implement security and confidentiality measures that align with best practices.
  • We do not share your data for marketing purposes without your consent.
  • You may request access, deletion, correction, or restriction of your data as described below.

If you are a California resident, the California Consumer Privacy Act (CCPA) may grant you rights such as:

  • The right to know what data we collect and how it is used
  • The right to access or delete your personal data
  • The right to opt out of the sale of your data (we do not sell data)
  • The right to non-discrimination for exercising your privacy rights

To exercise these rights, please contact us at privacy@code19digitals.com

7. Data Retention

We retain your personal data only as long as necessary for:

  • The purpose for which it was collected
  • Legal, regulatory, or contractual obligations
  • Ongoing client relationships

Once no longer needed, your data will be securely deleted or anonymized.

8. Data Security

We employ appropriate technical and organizational security measures including:

  • Encrypted email communications
  • Password-protected access to client data
  • Secure cloud-based storage solutions
  • Access control for authorized personnel only

While no method of digital transmission is completely secure, we strive to protect your information with commercially reasonable safeguards.

9. Your Rights

You have the following rights under Nigerian law and, where applicable, international data laws:

  • Right to Access: You may request access to your personal data.
  • Right to Rectification: You may ask us to correct inaccuracies.
  • Right to Deletion: You may request we delete your personal information.
  • Right to Object: You can object to certain types of data processing.
  • Right to Data Portability: You can request your data be transferred to another provider.
  • Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of the above rights, contact our Data Protection Officer via email at privacy@code19digitals.com

10. Cookies and Tracking

Our website may use cookies or similar tracking technologies to:

  • Understand user behavior
  • Monitor traffic and site performance
  • Improve site functionality

You may disable cookies through your browser settings. Note that disabling cookies may impact your user experience.

11. Third-Party Links

Our website may contain links to third-party websites or platforms. We are not responsible for the privacy practices or content of such sites. We encourage you to review their privacy policies before engaging with them.

12. Children’s Privacy

Our website and services are not intended for children under the age of 13. We do not knowingly collect data from minors. If we discover that we have inadvertently received such data, we will delete it promptly.

13. Changes to This Policy

We reserve the right to update or modify this Privacy Policy at any time. When changes are made, the “Last Updated” date at the top will reflect the revision. We encourage you to review this page periodically.

14. Contact Us

If you have questions about this Privacy Policy or your personal data, please contact:

Data Protection Officer
Code 19 Digital Solutions
Email: privacy@code19digitals.com

Code 19 Digital Solutions remains committed to ensuring that your privacy is protected and your data rights are respected.