Privacy Policy

ReadWrite Data Solutions Limited ("RWDS", "we", "our", or "us") is committed to protecting the privacy of individuals who interact with our website (readwriteds.com), training platform, SucceedQuiz, and related services (collectively, the "Services"). This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, and your rights with respect to that data. By accessing our Services you agree to this Policy. RWDS is incorporated in Nigeria and is subject to the Nigeria Data Protection Act 2023 (NDPA) and the regulations of the Nigeria Data Protection Commission (NDPC). Where our services are accessed by individuals in the European Economic Area (EEA) or United Kingdom, we also adhere to the principles of the General Data Protection Regulation (GDPR) to the extent applicable.

We collect personal data in the following categories: **Identity data:** Full name, job title, company name, LinkedIn profile URL. **Contact data:** Email address, phone number, WhatsApp number, physical address. **Transactional data:** Purchase history, invoice details, payment method type (not card numbers — card data is processed exclusively by Paystack and GlobalPay), billing address. **Usage data:** Pages visited, time on site, browser type, referral source, IP address collected via analytics tools (Google Analytics 4, Vercel Analytics). **Quiz and learning data:** SucceedQuiz quiz responses, scores, progress through course materials, completion dates. **Communications data:** Records of emails, WhatsApp messages, and support tickets exchanged with our team. **Marketing preferences:** Opt-in status for our newsletter and promotional communications.

We use personal data to: - **Deliver services:** Process orders, issue invoices, provide course access, deliver training. - **Communicate:** Respond to enquiries, send order confirmations, provide platform notifications. - **Improve our services:** Analyse usage patterns to improve website experience and course content. - **Marketing:** Send newsletters and product updates (only to subscribers who have opted in). - **Compliance:** Meet legal obligations including tax records, anti-fraud checks, and data protection requests. - **Lead management:** Score and route incoming enquiries to the appropriate RWDS team member. We will never sell your personal data to third parties.

Our primary legal bases under the NDPA and GDPR are: - **Contract:** Processing necessary to deliver a purchased service (e.g., course enrolment, hosting account). - **Legitimate interests:** Analytics, fraud prevention, improving our services where this does not override your rights. - **Consent:** Marketing communications and optional cookies. You may withdraw consent at any time. - **Legal obligation:** Compliance with Nigerian tax law, NDPC regulations, and other applicable statutes.

We share personal data only with trusted third-party service providers necessary to operate our business: | Recipient | Purpose | Location | |-----------|---------|----------| | Paystack | Payment processing | Nigeria | | GlobalPay (Interswitch) | Alternative payment rails | Nigeria | | Zeptomail (Zoho) | Transactional email delivery | International | | Google Analytics | Website analytics | USA (EU Standard Contractual Clauses) | | Vercel | Website hosting and edge network | USA/Global | | Microsoft 365 | Internal operations and email | International | All third parties are bound by contractual data protection obligations. We do not transfer personal data to countries outside Nigeria, the EEA, or countries with adequate data protection frameworks without appropriate safeguards.

We retain personal data for as long as necessary to fulfil the purposes described in this Policy: - **Customer records:** 7 years from last transaction (tax compliance) - **Marketing data:** Until you unsubscribe + 1 year - **Website analytics:** 26 months (Google Analytics default, reduced) - **Support tickets:** 3 years from closure - **Training records:** 5 years from course completion (certification evidence) After the applicable retention period, data is deleted or anonymised.

Under the NDPA (and GDPR where applicable) you have the right to: - **Access:** Request a copy of the personal data we hold about you. - **Rectification:** Correct inaccurate or incomplete data. - **Erasure:** Request deletion of your data where there is no lawful reason to retain it. - **Restriction:** Ask us to limit the ways in which we process your data. - **Portability:** Receive your data in a structured, machine-readable format. - **Object:** Object to processing based on legitimate interests or direct marketing. - **Withdraw consent:** Withdraw marketing consent at any time by clicking "Unsubscribe" in any email or contacting us. To exercise any of these rights, email privacy@readwriteds.com. We will respond within 30 days.

We use the following types of cookies: - **Essential cookies:** Required for the website to function (session management, shopping cart). These cannot be disabled. - **Analytics cookies:** Google Analytics 4 and Vercel Analytics to understand site usage. These can be disabled via our cookie banner. - **Marketing cookies:** Only placed if you consent via our cookie banner. You can manage cookie preferences at any time using the cookie settings link in our footer.

We implement industry-standard technical and organisational measures to protect your data, including: - HTTPS/TLS encryption for all data in transit - Data at rest encryption on our hosting infrastructure - Role-based access controls limiting who can access customer data internally - Regular security reviews and penetration testing No method of transmission over the Internet is 100% secure. If you believe your data has been compromised, contact security@readwriteds.com immediately.

For privacy-related queries, contact our Data Protection Lead: Email: privacy@readwriteds.com Address: 2A Salvation Estate, Langbasa, Ajah, Lagos State, Nigeria If you are dissatisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng, or the relevant supervisory authority in your country.