PKH Privacy Policy

...how we protect you and your data

1. Introduction

PK Hadassah Consulting (“we,” “us,” or “our”) provides digital tech services, training, coaching, and recruitment facilitation globally. We value your privacy and are committed to protecting your personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023, the NDPR 2019, and the GDPR.

2. The Data We Collect

We collect information that identifies you (“Personal Data”). This includes:

Identity Data: Name, date of birth, and nationality.
Contact Data: Email address, phone number, and physical address.
Professional Data: CVs, employment history, and skills (for applicants and interns).
Financial Data: Payment details (processed securely via third-party gateways).
Technical Data: IP addresses and website usage patterns via cookies.
Sensitive Data: We only collect biometric or health data if strictly necessary for employment/internship purposes and only with your explicit consent.

3. How and Why We Use Your Data (Lawful Basis)

Under the NDPA 2023, we must have a “lawful basis” for every use of your data:

Performance of Contract: To deliver the courses, coaching, or tech services you purchased.
Consent: To send marketing emails or to share an applicant’s CV with partner companies for job placement.
Legal Obligation: To comply with Anti-Money Laundering (AML) and tax laws.
Legitimate Interest: To improve our website security and business operations.

4. Special Provisions for Minors (Learners and Interns aged 16 - 17)

In accordance with the Nigeria Child Rights Act and the NDPA 2023:

We do not process data for individuals under 18 without verifiable parental or guardian consent.
If you are a guardian/parent of a 16- or 17-year-old learner/intern, you have the right to review, edit, or request the deletion of your ward/child’s data at any time.

5. Data Sharing and Third Parties

We will NEVER sell your data. We only share data with:

Service Providers: Cloud hosting (e.g., AWS/Google), payment processors, and email tools.
Partner Companies: Only if an applicant has opted in to be considered for external job placements.
Regulators: When required by Nigerian law (e.g., the NDPC or NFIU).

6. International Data Transfers

As a global firm, your data may be stored on servers outside Nigeria. We ensure these transfers comply with the NDPA’s “Adequacy” requirements, using Standard Contractual Clauses (SCCs) to ensure your data remains protected to the same standard as it would be in Nigeria or the EU.

7. Data Retention

We keep your data only as long as necessary.

Client Records: 5–7 years for tax and AML compliance.
Unsuccessful Applicants: 1 year (or 2 years if you consent to remain in our talent pool).
Marketing Data: Until you click “Unsubscribe.”

8. Your Legal Rights

You have the right to:

Access: Request a copy of the data we hold about you.
Correction: Ask us to fix inaccurate information.
Erasure: Request that we delete your data (the “Right to be Forgotten”).
Object: Opt-out of direct marketing at any time.
Portability: Request your data in a structured, machine-readable format.

9. Security

We implement robust technical measures, including SSL encryption and multi-factor authentication (MFA), to prevent unauthorised access or data breaches.

10. Contact and Complaints

If you have questions or wish to exercise your rights, contact our Data Protection Officer:
Email: legal@pkhadassah.com

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

For clarity and further questions, please contact us via: hello@pkhadassah.com

Last revised June, 2025.