1. Who we are
Coded Codes IT and Communication Solutions is the organisation responsible for the personal data described in this Policy where we determine why and how the data is processed.
References to “Coded Codes”, “we”, “us” or “our” have the same meaning.
Our contact address is Plot 3120, Rima Street, Maitama, Abuja, Nigeria. Privacy enquiries may be sent to info@codedcodes.com.
2. Scope of this Policy
This Policy applies to personal data collected through:
- codedcodes.com and its associated web pages;
- quotation, enquiry and contact forms;
- email, telephone and WhatsApp communications;
- meetings, proposals, contracts and invoices;
- support and maintenance requests;
- recruitment processes; and
- the delivery of our IT and digital services.
This Policy does not govern a third-party website or platform linked from our website. Please review the relevant provider’s privacy notice before submitting information to it.
3. Personal data we may collect
Depending on your relationship with us, we may collect the following categories of personal data:
Identity and contact information: your name, organisation, job title, telephone number, email address and business or correspondence address.
Project and transaction information: project requirements, proposals, contracts, invoices, payment status, support history, communications, approvals and files you provide.
Technical and usage information: IP address, browser and device information, approximate location derived from IP address, pages viewed, referring page, timestamps, cookies and security logs.
Marketing and preference information: your communication choices, areas of interest and responses to campaigns.
Recruitment information: where applicable, your CV, qualifications, employment history, portfolio, interview information and references.
We do not intentionally request sensitive personal data unless it is necessary, lawful and appropriately protected. Please avoid sending unnecessary sensitive information.
4. How we collect personal data
We collect personal data directly from you when you:
- complete a form on our website;
- request a quotation or consultation;
- communicate with us;
- sign an agreement or approve a proposal;
- make or receive a payment;
- attend a meeting or project session;
- submit a support request; or
- otherwise use our services.
We may also receive data automatically from your device, from your organisation, from a person authorised by you, from service providers involved in a transaction or from lawful public sources.
5. Why we use personal data
We may use personal data to:
- respond to enquiries and consultation requests;
- prepare quotations, proposals and project plans;
- enter into and perform contracts;
- design, develop, deploy and maintain digital services;
- manage projects and communicate progress;
- provide customer and technical support;
- issue invoices and manage payments;
- secure our website, systems and accounts;
- detect and prevent fraud or misuse;
- maintain business, accounting and tax records;
- improve our website and services;
- manage recruitment and employment processes;
- establish, exercise or defend legal claims;
- comply with legal and regulatory obligations; and
- send marketing communications where permitted.
6. Our lawful bases for processing
We process personal data only where a recognised lawful basis applies.
These lawful bases may include:
Contract: processing needed to take steps you requested before entering a contract or to perform an agreement with you.
Consent: where you have freely given clear permission for a particular use, such as certain marketing or non-essential cookies.
Legal obligation: processing required to comply with tax, accounting, regulatory, court or other legal obligations.
Legitimate interests: processing reasonably necessary to operate, secure and improve our business where those interests do not override your rights and freedoms.
We may rely on another lawful basis recognised by applicable law where appropriate.
7. Consent and withdrawal
Where we rely on consent, you may withdraw it at any time by contacting us or using an available preference control.
Withdrawing consent does not affect processing that was lawful before withdrawal. It may, however, prevent us from continuing an optional service that depends on that consent.
8. Cookies and similar technologies
Our website may use essential cookies required for security, navigation and functionality.
It may also use analytics, preference or marketing technologies where those services are enabled.
Where required, non-essential cookies will be used only after you have been given an appropriate choice.
You can adjust your browser settings to block or delete cookies, although some website functions may be affected.
9. How we share personal data
We may share only the personal data reasonably necessary with:
- website hosting and cloud-service providers;
- email, messaging and communications providers;
- payment processors and financial institutions;
- analytics and website-performance providers;
- domain registrars and infrastructure providers;
- professional advisers, including lawyers and accountants;
- employees, consultants and contractors working under appropriate confidentiality obligations;
- regulators, courts, law-enforcement authorities and public bodies where disclosure is legally required; and
- parties involved in a lawful business reorganisation, merger or transfer.
We do not sell personal data.
A service provider may process personal data only for authorised purposes and must apply appropriate confidentiality and security protections.
10. International transfers
Some technology providers may process information outside Nigeria.
Where personal data is transferred internationally, we will use a lawful transfer mechanism and appropriate safeguards required by applicable Nigerian data-protection law.
11. Payment information
Payments may be processed through banks, payment gateways or other authorised payment-service providers.
Payment providers may collect and process transaction details under their own terms and privacy policies. We may receive transaction references, payment status and limited information needed to reconcile the payment.
We do not intentionally store complete payment-card details on our website.
12. Data security
We use reasonable administrative, organisational and technical measures designed to protect personal data against accidental or unlawful loss, misuse, alteration, disclosure or access.
These measures may include:
- access controls and authentication;
- secure hosting and network protections;
- encryption where appropriate;
- backups and recovery procedures;
- security monitoring and logging;
- staff and contractor confidentiality obligations;
- software updates and vulnerability management; and
- assessment of relevant service providers.
No internet transmission or electronic storage method can be guaranteed to be completely secure.
13. Data retention
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected.
The applicable retention period may take account of:
- the duration of our relationship with you;
- project delivery and support requirements;
- security and fraud-prevention needs;
- accounting and tax obligations;
- contractual and regulatory requirements;
- applicable limitation periods; and
- the need to resolve complaints or legal disputes.
When information is no longer required, we will delete, anonymise or securely archive it in accordance with applicable requirements.
14. Your data-protection rights
Subject to applicable conditions and exceptions, you may have the right to:
- be informed about how we process your personal data;
- request access to personal data held about you;
- request correction of inaccurate or incomplete data;
- request deletion of personal data in appropriate cases;
- request restriction of processing;
- object to certain processing;
- withdraw consent where processing depends on consent;
- request portable data where applicable;
- request appropriate safeguards relating to certain automated decisions; and
- lodge a complaint with the Nigeria Data Protection Commission.
These rights are not absolute and may be subject to lawful limitations or exemptions.
15. Exercising your rights
To exercise a data-protection right, send your request to info@codedcodes.com.
Please explain the right you wish to exercise and identify the information or interaction involved.
We may request reasonable information to verify your identity, protect your data and confirm your authority where you act for another person.
We will respond within the period required by applicable law.
16. Marketing communications
We may send information about relevant Coded Codes services where we have a lawful basis to do so.
You may opt out of marketing at any time by using an unsubscribe facility where provided or contacting us.
Service, security, transaction and project communications are not marketing and may still be sent where necessary.
17. Children’s privacy
Our business and professional services are not directed to children.
We do not knowingly collect a child’s personal data without the consent or other lawful authority required by applicable law.
If you believe that a child has provided personal data improperly, contact us so that we can investigate and take appropriate action.
18. Acting as a service provider for clients
During a client project, we may process personal data solely on that client’s documented instructions.
In that situation, the client ordinarily determines why and how the information is processed. The client’s own privacy notice should explain that processing.
We will process the information according to the relevant contract, applicable instructions and any agreed data-processing terms.
19. Personal-data breaches
We maintain procedures for assessing and responding to suspected personal-data breaches.
Where legally required, we will notify the Nigeria Data Protection Commission and affected individuals within the applicable period.
20. Third-party websites and services
Our website may link to third-party websites, social-media platforms, payment providers or other external services.
We do not control their privacy practices and are not responsible for how they independently process your personal data.
You should review the privacy notice of each external service before submitting information.
21. Complaints
If you have a concern about how we process personal data, please first contact us at info@codedcodes.com so that we can investigate and attempt to resolve it.
You also have the right to lodge a complaint with the Nigeria Data Protection Commission through its official complaint channels.
22. Changes to this Policy
We may update this Privacy Policy when our processing, technology, services or legal obligations change.
The latest version will appear on this page with a revised effective date.
We will provide additional notice where a material change requires it.
23. Contact us
Questions, requests or complaints concerning this Privacy Policy may be directed to:
Company: Coded Codes IT and Communication
Solutions
Email:
info@codedcodes.com
Telephone:
+234 806 513 1265
Address:
Plot 3120, Rima Street, Maitama, Abuja, Nigeria.