1. Data Controller

This website is operated by Circular Code Systems Ltd, a company incorporated in Nigeria under the Companies and Allied Matters Act (CAMA).

• Address: Lagos, Nigeria
• Email: info@circularcodesystems.com
• Regulatory authority: Nigeria Data Protection Commission (NDPC)

2. Scope and Applicable Law

This Privacy Policy governs how Circular Code Systems Ltd collects, uses, stores, and protects personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023 and its implementing regulations. It applies to all visitors of circularcodesystems.com and individuals who contact us through the website.

3. Personal Data We Collect

We collect only the minimum data necessary for the purposes described below:

• Contact data: name, email address, and message content submitted via our contact form.
• Technical data: IP address, browser type, pages visited, and timestamps — collected automatically by our web server for security and performance purposes.
• Cookies: See Section 9 below.

We do not collect sensitive personal data (e.g. biometric, health, or financial data) through this website.

4. Legal Basis for Processing

• Consent (NDPA §25): for non-essential cookies and any marketing communications.
• Contractual necessity (NDPA §26): to respond to enquiries and process service requests.
• Legitimate interest (NDPA §28): for server security logs and fraud prevention.

5. Purposes of Processing

• Responding to contact form submissions and service enquiries.
• Administering and improving our website.
• Complying with legal obligations under Nigerian law.
• Detecting and preventing fraudulent or abusive activity.

We will not use your data for any purpose incompatible with those listed above without first obtaining your explicit consent.

6. Data Retention

Contact form data is retained for a maximum of 24 months from the date of submission, unless a longer retention period is required by law or is necessary for the performance of a contract. Technical/server logs are retained for a maximum of 12 months.

7. Third-Party Sharing and Cross-Border Transfers

We do not sell your personal data. We may share data with:

• Hosting and infrastructure providers who process data on our behalf under appropriate data processing agreements.
• Legal authorities where required by Nigerian law or valid court order.

Where personal data is transferred outside Nigeria, we ensure an adequate level of protection is in place consistent with NDPA Chapter VI, including through contractual safeguards.

8. Your Rights Under the NDPA 2023

As a data subject you have the following rights:

To exercise any right, contact us at info@circularcodesystems.com. We will respond within 30 days. If you are unsatisfied with our response, you may lodge a complaint with the NDPC at ndpc.gov.ng.

9. Cookies

We use the following cookies on this website:

You may withdraw consent for non-essential cookies at any time by clearing your browser's local storage or using the Decline option on our cookie banner.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure consistent with NDPA §38. In the event of a data breach affecting your rights and freedoms, we will notify the NDPC within 72 hours and affected individuals without undue delay.

11. Changes to This Policy

We review and update this Privacy Policy at least annually, as required by the NDPA. Material changes will be communicated via a notice on our website. Continued use of the website after the effective date constitutes acceptance of the updated policy.