Privacy Policy & Nigeria Data Protection Act (NDPA) 2023 Notice
This Privacy Policy explains how The Bridge Family Coaching Ltd ('we', 'us', 'our'), operating at folasadeadejoorin.com, collects, uses, stores, and protects personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023 and applicable international privacy standards.
1. Data Controller Identity
Data Controller: The Bridge Family Coaching Ltd
Principal Contact: Folasade Adejoorin
Website: https://folasadeadejoorin.com
Privacy Contact Email: [email protected]
2. Personal Information We Collect & Data Minimisation
We strictly practice data minimisation, especially because our services involve families and adolescents:
- Booking & Enquiry Data: Name, email address, phone number, selected appointment type, audience category, parental consent confirmation (where a teenager is involved), and a brief objective statement. We explicitly prohibit and avoid collecting detailed family histories or clinical counselling notes through website forms.
- Bookshop Order Data: Name, email, phone number, delivery details (for physical books), order items, and payment verification references processed via Paystack. Card numbers and banking credentials are processed directly by Paystack and are never stored on our servers.
- Newsletter Data: Email address, optional first name, and timestamped consent record when you explicitly opt in.
- Technical & Analytics Data: Anonymised page views, referrer domain (including search, social, and AI referral sources), and essential security/rate-limiting logs.
3. Lawful Bases for Processing (NDPA 2023 Section 25)
- Contractual Necessity: To schedule and deliver coaching appointments and fulfil book orders.
- Consent: For optional newsletter subscriptions and parental consent for safeguarded adolescent coaching.
- Legitimate Interests: To maintain website security, prevent booking fraud, and understand aggregate website performance.
- Legal Obligation: To maintain statutory financial/tax records and comply with regulatory obligations under Nigerian law.
4. Safeguards for Children and Adolescents (NDPA 2023 Section 31)
Services involving teenagers require explicit parental or legal guardian consent. We do not knowingly collect personal data directly from minors without guardian authorisation, nor do we profile minors for marketing.
5. Data Sharing & Disclosures
We do not sell personal data. Data is shared only with essential service providers acting under strict security obligations (such as Paystack for payment processing and our secure OVH VPS hosting infrastructure) or when required by law.
6. Data Retention & Deletion Practices
- Website Enquiries: Retained for up to 12 months and then archived or deleted unless an active coaching relationship continues.
- Booking Records: Retained for operational administration and purged/anonymised when no longer needed.
- Book Order Financial Records: Retained for the statutory accounting period required under Nigerian law.
- Newsletter Subscriptions: Retained until you click the one-click unsubscribe link or request deletion.
7. Your Data Subject Rights under NDPA 2023
Under Part VI of the Nigeria Data Protection Act 2023, you have the right to request access to your personal data, rectification of inaccurate data, erasure ('right to be forgotten'), restriction of processing, data portability, and withdrawal of consent at any time, as well as the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).