Privacy Policy

1. Identity of the Data Controller

The data controller in respect of personal data processed through this website is:

Clerqly (trading as QnQ Services and Solutions)
43, Sobo Arobiodu Street, GRA, Ikeja, Lagos, Nigeria
Email: info@qnqservicesandsolutions.com
Website: www.qnqservicesandsolutions.com

Queries relating to data protection and privacy may be directed to the email address above, marked for the attention of the Data Compliance Officer.

2. Personal Data We Collect

2.1 Information You Submit

When you complete the enquiry form on this website, we collect the following personal data:

• Full name
• Email address
• Telephone number (if provided)
• Organisation name (if provided)
• The content of your message or enquiry

2.2 Automatically Collected Technical Data

When you visit this website, certain technical information is automatically recorded by our web hosting infrastructure, including your IP address, browser type and version, operating system, pages visited, and time and duration of visit. This information is used solely for the administration and security of the website and is not linked to any personally identifiable information.

3. Legal Basis for Processing

We process your personal data on the following legal bases as provided under section 25 of the Nigeria Data Protection Act 2023:

• Consent: Where you submit an enquiry via our contact form, you consent to the collection and use of your personal data for the purpose of responding to that enquiry. You may withdraw consent at any time by contacting us; withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Legitimate Interests: We process technical data for the purpose of maintaining website security, diagnosing technical issues, and improving the functionality of the website.
• Performance of a Contract: Where we enter into a formal consulting engagement following your enquiry, the processing of your data is necessary for the performance of that contract.

4. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To respond to your enquiry and communicate with you regarding our services
• To assess whether and how we are able to assist with your requirements
• To provide consulting and advisory services where a formal engagement is established
• To maintain and improve the performance and security of this website
• To comply with applicable legal obligations

We do not use your personal data for marketing purposes unless you have separately and explicitly consented to receive such communications.

5. Disclosure of Personal Data

We do not sell, rent, or trade your personal data with third parties. We may share your data with the following categories of recipients, strictly to the extent necessary:

• Website Hosting Provider: Our website is hosted by iClassServer, which provides server infrastructure. Data transmitted through the website may be processed by them in the ordinary course of hosting services.
• Contact Form Processor: We use Web3Forms to process contact form submissions. Web3Forms receives and forwards your submitted data to us. Their privacy policy governs their handling of that data.
• Professional Advisers: We may share information with our legal advisers, accountants, or auditors on a strictly confidential and need-to-know basis.
• Regulators and Law Enforcement: We may disclose your data where required to do so by applicable law, court order, or the lawful request of a regulatory authority.

All third parties with whom we share personal data are required to handle it in accordance with applicable data protection law.

6. International Data Transfers

This website and certain of our third-party processors may operate or store data outside the Federal Republic of Nigeria. Where personal data is transferred to jurisdictions outside Nigeria, we take steps to ensure that such transfers are subject to appropriate safeguards as required by section 43 of the Nigeria Data Protection Act 2023, including contractual protections that require the recipient to handle your data to a standard equivalent to that required under Nigerian data protection law.

7. Data Retention

We retain your personal data only for as long as is necessary for the purposes for which it was collected, subject to any longer retention period required by applicable law:

• Enquiry data (no engagement resulting): Three (3) years from the date of the enquiry, after which it is securely deleted.
• Client engagement data: Seven (7) years from the conclusion of the engagement, consistent with applicable statutory limitation periods under Nigerian law.
• Website technical logs: Twelve (12) months, after which they are overwritten or deleted.

8. Your Rights as a Data Subject

Subject to applicable exceptions and conditions, you have the following rights in respect of your personal data under the Nigeria Data Protection Act 2023:

• Right to be Informed — The right to be informed about the collection and use of your personal data, as set out in this Policy.
• Right of Access — The right to obtain a copy of your personal data and information about how it is processed (NDPA 2023, s.34).
• Right to Rectification — The right to have inaccurate or incomplete personal data corrected (NDPA 2023, s.35).
• Right to Erasure — The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful (NDPA 2023, s.36).
• Right to Restrict Processing — The right to request restriction of processing in certain circumstances (NDPA 2023, s.37).
• Right to Data Portability — The right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on consent or contract (NDPA 2023, s.38).
• Right to Object — The right to object to processing carried out on the basis of legitimate interests (NDPA 2023, s.39).
• Rights in Relation to Automated Decision-Making — The right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects (NDPA 2023, s.40).

To exercise any of these rights, please contact us at info@qnqservicesandsolutions.com. We will respond within the timeframe prescribed by the NDPA 2023. We may require verification of your identity before processing your request.

9. Cookies and Tracking Technologies

This website uses only essential functional cookies necessary for the website to operate correctly. These cookies do not track your activity across other websites and are not used for advertising or profiling purposes.

We do not currently use analytics, targeting, or performance cookies. If this changes in the future, this Policy will be updated and, where required, your consent will be sought prior to the placing of such cookies.

10. Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include encryption of data in transit via SSL/TLS protocols, restricted internal access controls, and periodic review of our security practices.

While we take all reasonable steps to safeguard your data, no method of internet transmission or electronic storage is entirely secure. We cannot guarantee absolute security and, to the fullest extent permitted by law, disclaim liability for any breach that occurs despite these measures.

11. Children's Privacy

This website is directed at business professionals and organisations. It is not intended for use by individuals under the age of eighteen (18) years. We do not knowingly collect personal data from minors. If we become aware that personal data has been inadvertently collected from a minor, we will take prompt steps to delete it.

12. Links to Third-Party Websites

This website may contain links to third-party websites. We have no control over the content, privacy practices, or data handling of those websites and accept no responsibility for them. We encourage you to review the privacy policy of any third-party website you visit.

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory requirements. Material changes will be notified by updating the "Last Updated" date at the top of this Policy. Continued use of this website following any update constitutes acceptance of the revised Policy. We recommend that you review this Policy periodically.

14. Contact Us and Lodging a Complaint

For questions about this Privacy Policy or to exercise your data subject rights, please contact:

Clerqly — Data Compliance
43, Sobo Arobiodu Street, GRA, Ikeja, Lagos, Nigeria
Email: info@qnqservicesandsolutions.com

If you are dissatisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC):

Nigeria Data Protection Commission (NDPC)
No. 5 Donau Crescent, Off Amazon Street, Maitama District, Abuja, FCT
Website: ndpc.gov.ng