Privacy Policy
Last updated: Draft — not yet in effect
Not yet in effect
This document is an unreviewed draft. It must be checked by a qualified lawyer, and the outstanding company details supplied, before the site goes live. It is visible here so it can be reviewed, not because it applies.
This policy explains what personal information Sage Solutions Consulting Ltd collects when you use this website, why we collect it, who we share it with, and what rights you have over it.
We serve clients in Nigeria and in Canada, so this policy is written to meet the Nigeria Data Protection Act 2023 and Canada's Personal Information Protection and Electronic Documents Act. Where the two differ, we apply the stricter requirement.
Who we are
Sage Solutions Consulting Ltd is the data controller for information collected through this website.
Privacy enquiries: tunji@sagesolutionsconsult.com. Registered address and company number: to be confirmed.
Information you give us
We only ask for information we need in order to respond to you. Specifically:
- When you book a consultation, our scheduling provider collects your name, email address, timezone and any details you add to the booking.
- When you send an enquiry through the contact form, we collect your name, email address and the content of your message.
- If you contact us on WhatsApp, your phone number and messages are visible to us and are handled under WhatsApp's own terms, not ours.
- If you become a client, we collect whatever information the engagement requires. That is governed by our client agreement rather than this policy.
Information collected automatically
Our hosting provider records standard server logs, including your IP address, browser type and the pages you request. These are used to keep the site running and secure, and to diagnose faults.
We use analytics to understand which pages are read and where visitors come from. This tells us about traffic patterns, not about you personally, and we do not attempt to identify individual visitors from it.
We do not load fonts, trackers or scripts from third-party servers on page load. Fonts are served from our own domain, which means visiting the site does not report your visit to anyone else.
Cookies
The site itself does not require cookies to function. Our analytics provider sets cookies to recognise returning visitors and measure traffic.
Analytics cookies are only set if you consent to them. You can decline without losing access to any part of the site, and you can change your mind at any time.
Why we use your information
We do not sell your personal information. We do not share it for advertising. We do not send marketing email unless you have asked us to, and every such message carries an unsubscribe link.
- To respond to your enquiry or hold the consultation you booked.
- To provide services you have engaged us for.
- To keep the website secure, available and working correctly.
- To understand, in aggregate, how the site is used so we can improve it.
- To meet legal, tax and regulatory obligations.
Our legal basis
Under the NDPA and PIPEDA we rely on your consent for analytics cookies and for any marketing communications. For responding to enquiries and delivering services, we rely on the necessity of processing to take steps at your request or to perform a contract. For security logging and record-keeping, we rely on our legitimate interests and on legal obligations.
Where we rely on consent, you may withdraw it at any time. Withdrawing consent does not affect processing already carried out.
Who we share it with
We share personal information only with service providers who process it on our behalf, under contract, and only for the purposes described above. These currently include:
- Our hosting and infrastructure provider, which stores the site and records server logs.
- Our scheduling provider, which handles consultation bookings.
- Our email delivery provider, which sends contact-form submissions to us.
- Our analytics provider, which reports aggregate site usage.
- Professional advisers, and regulators or law enforcement where we are legally required to disclose.
International transfers
Our service providers operate outside Nigeria and, in some cases, outside Canada. This means your information may be stored or processed in other countries, including the United States.
Under the NDPA, transfers of personal data out of Nigeria require an appropriate legal basis. We rely on contractual protections with each provider and on your consent where required. If you would like details of the safeguards applying to a specific provider, ask us and we will tell you.
How long we keep it
Enquiries and booking records are kept for as long as needed to deal with the matter and for a reasonable period afterwards, in case you come back to us. Client records are kept for as long as required by tax, accounting and professional obligations in the relevant jurisdiction. Server logs are kept for a short period and then deleted.
Specific retention periods: to be confirmed.
Your rights
You have the right to:
- Ask what personal information we hold about you, and get a copy of it.
- Have inaccurate information corrected.
- Ask us to delete information we no longer have a reason to keep.
- Withdraw consent where we relied on it.
- Object to or restrict certain processing.
- Complain to a regulator — the Nigeria Data Protection Commission, or the Office of the Privacy Commissioner of Canada.
Making a request
Write to us at tunji@sagesolutionsconsult.com. We will respond within the time limits set by the applicable law, and we will not charge you for a reasonable request. We may need to verify your identity before we act, particularly for deletion requests.
Security
The site is served over an encrypted connection. Access to enquiry and client information is limited to those who need it. No system is completely secure, and we will tell you promptly if a breach affects your information and we are required to notify you.
Children
This site is aimed at businesses and is not directed at children. We do not knowingly collect information from anyone under 18. If you believe a child has given us information, contact us and we will delete it.
Changes to this policy
We may update this policy as the business or the law changes. The date at the top shows when it was last revised. Material changes will be flagged on the site rather than made quietly.