Privacy Policy
This Privacy Policy describes how Vanguard Learning ("the Platform", "the operator") collects, processes, stores, and protects personal data obtained through the website vanguardlearning.site and related communications. The Platform operates in compliance with the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR) issued by the National Information Technology Development Agency (NITDA). By using this website, you acknowledge that you have read and understood this policy.
1. Identity and Contact Details of the Data Controller
The data controller responsible for personal data collected through this website is:
| Detail | Information |
|---|---|
| Platform Name | Vanguard Learning |
| Website | vanguardlearning.site |
| Physical Address | 10 Ashabi Cole St, Alausa, Ikeja 101233, Lagos, Nigeria |
| Contact Email | [email protected] |
| Contact Phone | +234 704 246 9598 |
2. Categories of Personal Data Collected
The Platform collects personal data only where necessary and proportionate to the purpose for which it is collected. The table below describes the categories of data collected, the source, and the legal basis under the NDPA 2023.
| Data Category | Examples | Source | Legal Basis |
|---|---|---|---|
| Contact Information | Name, email address | Contact form submission | Consent / Legitimate interest |
| Communication Content | Message text submitted via contact form | Contact form submission | Consent |
| Technical Data | IP address, browser type, device type, operating system | Automatic collection via server logs and analytics | Legitimate interest |
| Usage Data | Pages visited, time on site, referral source | Analytics cookies (with consent) | Consent |
| Cookie Preferences | Consent or decline status for analytics cookies | Cookie consent system | Legal obligation / Consent |
3. Purposes of Processing
Personal data is processed for the following purposes:
- Responding to enquiries submitted through the contact form
- Providing information about training programs and enrollment processes
- Improving the website's functionality and user experience through analytics
- Maintaining records of communications for legitimate business purposes
- Complying with applicable legal obligations under Nigerian law
The Platform does not use personal data for automated decision-making, profiling, or direct marketing without explicit consent.
4. Data Sharing and Third Parties
The Platform does not sell, rent, or trade personal data to third parties. Data may be shared in the following limited circumstances:
| Recipient | Purpose | Safeguards |
|---|---|---|
| Email service providers | Delivery of contact form responses | Contractual data processing terms |
| Website hosting providers | Server infrastructure and uptime | Contractual data processing terms |
| Analytics providers (where consent given) | Website usage analysis | Consent-based; data anonymised where possible |
| Regulatory authorities | Compliance with Nigerian law, court orders, or legal processes | Legal obligation |
5. Data Retention
Personal data is retained only for as long as necessary for the purpose for which it was collected, or as required by applicable law. Contact form submissions are retained for a period of up to 24 months to allow for follow-up on training enquiries. Technical and log data is typically retained for up to 12 months. Cookie consent records are retained for the duration of the consent period. Where data is no longer required, it is securely deleted or anonymised.
6. Your Rights Under the Nigeria Data Protection Act 2023
As a data subject, you have the following rights under the NDPA 2023 and NDPR 2019:
- Right of Access: You may request a copy of the personal data held about you.
- Right to Rectification: You may request correction of inaccurate or incomplete personal data.
- Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose collected.
- Right to Restriction: You may request that processing of your data be restricted in certain circumstances.
- Right to Object: You may object to processing based on legitimate interests.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
- Right to Lodge a Complaint: You may lodge a complaint with NITDA or the Nigeria Data Protection Commission (NDPC) if you believe your data rights have been violated.
To exercise any of these rights, contact the Platform at [email protected]. Requests will be addressed within 30 days in accordance with the NDPA 2023.
7. Data Security
The Platform implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include secure HTTPS transmission, access controls, and regular review of data handling practices. No method of electronic transmission or storage is entirely secure; however, the Platform takes reasonable steps to protect data in its possession.
8. Cookies
This website uses cookies. For detailed information about which cookies are used, their purposes, and how to manage your preferences, please refer to the Cookie Policy.
9. Children's Privacy
This website is not directed at individuals under the age of 18. The Platform does not knowingly collect personal data from minors. If it comes to the attention of the Platform that data has been collected from a person under 18 without appropriate consent, that data will be deleted promptly.
10. International Data Transfers
Where personal data is transferred outside Nigeria (for example, to international hosting or analytics providers), the Platform ensures appropriate safeguards are in place consistent with the requirements of the NDPA 2023, including contractual clauses and assessment of the adequacy of data protection in the recipient country.
11. Changes to This Policy
This Privacy Policy may be updated periodically to reflect changes in legal requirements, platform operations, or data practices. The date of the most recent revision is displayed at the top of this document. Continued use of the website following any update constitutes acknowledgment of the revised policy.
12. Contact for Privacy Matters
For any questions, requests, or concerns relating to this Privacy Policy or the handling of your personal data, contact the Platform directly:
Email: [email protected]
Phone: +234 704 246 9598
Address: 10 Ashabi Cole St, Alausa, Ikeja 101233, Lagos, Nigeria