PRIVACY POLICY

Ideate 360 Limited
(Effective Date: 23 November 2025)

1. Introduction

Ideate 360 Limited (“we,” “us,” “our,” or “the Firm”) is a leading data protection and privacy consultancy firm registered in Nigeria with RC 1051907 . We are committed to protecting the privacy and personal data of our clients, website visitors, event attendees, and all individuals who interact with us. This Privacy Policy explains how we collect, use, disclose, store, and protect your Personal Data in compliance with the Nigeria Data Protection Act 2023, the Nigeria Data Protection Regulation 2019, and other applicable laws.

2. Who We Are
Data Controller:
Ideate 360 Limited
Address: 9 Bassey Akpan Street , Uyo. Nigeria
Email: hello@ideate360.com.ng
Data Protection Officer (DPO): The Managing Director, Ideate 360 Limited

3. Personal Data We Collect
We may collect the following categories of Personal Data:

Category Examples

Identity Data Full name, gender, title, date of birth
Contact Data Email address, phone number, postal address, social media handles
Professional Data Job title, employer, industry, professional qualifications
Financial Data Bank account details (only when paying invoices or receiving payments)
Technical Data IP address, browser type, device information, cookies
Usage Data Pages visited on our website, time spent, referral source
Communication Data Contents of emails, recorded calls (where consent is obtained)

Special Categories Only with explicit consent or where required by law (rare)

4. How We Collect Your Personal Data

 Directly from you (via forms, emails, contracts, phone calls, events)
 Automatically through our website (cookies, Google Analytics, etc.)
 From third parties (referrals, public registers, your employer when they engage us on your behalf)

5. Purposes and Legal Bases for Processing

Purpose Lawful Basis (NDPA/NDPR)
Providing consultancy & training services Performance of contract / Legitimate interests
Sending newsletters & marketing materials Consent / Legitimate interests
Processing payments and invoicing Performance of contract / Legal obligation
Improving our website and services Legitimate interests
Complying with legal or regulatory requests Legal obligation
Defending or establishing legal claims Legitimate interests

6. Data Sharing and International Transfers

We may share your Personal Data with:
 Authorized staff and contractors bound by confidentiality
 Payment processors and banks (e.g., Paystack, Flutterwave)
 Professional advisers (lawyers, auditors)

 Regulatory authorities (e.g., NITDA, NDPC) when required
 Cloud service providers (Microsoft Azure, Google Cloud, AWS) located outside Nigeria – we only transfer data under
Standard Contractual Clauses or where the country has been granted adequacy status.

7. Data Security

We implement appropriate technical and organisational measures including:
 Encryption of data in transit and at rest
 Access controls and two-factor authentication
 Regular security audits and staff training
 ISO 27001-aligned information security management system (in progress / achieved)

8. Data Retention

We keep your Personal Data only as long as necessary:
Data Type Retention Period Client contracts & records 7 years after project completion Financial records 7 years (required by Nigerian law) Marketing subscribers Until you unsubscribe
Website logs Maximum 12 months

9. Your Rights Under Nigerian Law You have the right to:

 Access your Personal Data
 Rectify inaccurate data
 Request erasure (“right to be forgotten”) where applicable

 Restrict or object to processing
 Data portability
 Withdraw consent at any time
 Lodge a complaint with the Nigeria Data Protection Commission (NDPC)
To exercise any right, email hello@ideate360.com.ng We will respond within one month (extendable in complex cases).

10. Cookies

Our website uses cookies. You can manage preferences via the cookie banner or browser settings. See our separate Cookie Policy for details.

11. Children

Our services are not directed at individuals under 18 years. We do not knowingly collect data from children.

12. Changes to this Policy
We may update this Policy from time to time. The latest version will always be published on our website with the “Effective Date”
updated.

13. Contact Us
For any privacy concerns:
Data Protection Officer
Email: hello@ideate360.com.ng
Address: 9 Bassey Akpan Street , Uyo . Nigeria
©2005 Ideate 360 Limited. All Rights Reserved.