NDPR & Data Protection

1. Data controller

Cogdemy, operated by Hartlysams (Nigeria), determines the purposes and means of processing your personal data and is the data controller for the purposes of the NDPR/NDPA.

2. Principles we follow

• We process personal data lawfully, fairly, and transparently.
• We collect it for specific, legitimate purposes and do not use it in incompatible ways.
• We collect only what we need, keep it accurate, and retain it no longer than necessary.
• We protect it with appropriate security measures.

3. Lawful basis for processing

Depending on the activity, we rely on: performance of our contract with you, your consent, our legal obligations, and our legitimate interests in operating and securing Cogdemy. Full detail is in our Privacy Policy.

4. Your rights as a data subject

Under the NDPR/NDPA you have the right to:

• Access, obtain confirmation of and a copy of the personal data we hold about you.
• Rectification, have inaccurate or incomplete data corrected.
• Erasure, request deletion of your data where there is no overriding reason to keep it.
• Restriction, ask us to limit how we use your data in certain cases.
• Portability, receive data you provided in a commonly used format.
• Object, object to processing based on legitimate interests, and to marketing.
• Withdraw consent, where processing is based on consent, withdraw it at any time.

5. How to exercise your rights

Submit a request through our contact page. We may need to verify your identity, and we aim to respond within the timeframe required by law. Exercising these rights is free unless a request is manifestly unfounded or excessive.

6. Cross-border transfers

Where personal data is transferred to service providers outside Nigeria, we rely on those providers' safeguards and adequacy/contractual protections consistent with the NDPR/NDPA.

7. Complaints

If you are not satisfied with how we handle your data, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC). We would appreciate the chance to address your concern first via the contact page.

8. Updates

We review this statement periodically; the “Last updated” date reflects the latest version.