1. Introduction
Princeps Development LTD ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (cepsdev.com.ng), use our services, or engage with us as a client, partner, or prospect.
We comply with the Nigeria Data Protection Act (NDPA) 2023, enforced by the Nigeria Data Protection Commission (NDPC) — the statutory successor to the earlier NDPR framework issued by the National Information Technology Development Agency (NITDA) — as well as applicable international data protection standards. By using our website or services, you consent to the practices described in this Privacy Policy.
Services provided by Princeps Development LTD shall not be used against the local and international laws of the nation in which they are being used. All data processing activities are conducted in strict compliance with applicable legal frameworks.
2. Data Controller
The data controller responsible for your personal data is:
- Company Name: Princeps Development LTD
- RC Number: 9447876 (CAC Registered)
- TIN: 2621022591060
- Registered Address: 10 Life-Line House, Etaghene Street, Abraka, Delta State, Nigeria
- Email: pakpobasa@gmail.com
- Phone: +234 808 016 7018
- Managing Director: Prince Akpobasa
3. Information We Collect
We collect and process the following categories of personal data:
3.1 Information You Provide Directly
- Contact Information: Name, email address, phone number, company name, and job title when you fill out contact forms, request quotes, or subscribe to our newsletter.
- Project Information: Business requirements, technical specifications, and other details you share during project discovery and scoping.
- Communication Records: Emails, WhatsApp messages, meeting notes, and other correspondence.
- Payment Information: Bank account details, billing address, and transaction records for invoicing purposes.
3.2 Information Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device information, and referring URLs.
- Usage Data: Pages visited, time spent on site, click patterns, and navigation behavior.
- Location Data: General geographic location derived from your IP address.
3.3 Information from Third Parties
- Professional networking platforms (e.g., LinkedIn) when you connect with us.
- Referral partners who recommend our services to you.
- Publicly available business directories and registries.
4. How We Use Your Information
We use your personal data for the following purposes:
- Service Delivery: To provide, maintain, and improve our web development, cloud infrastructure, database optimization, and AI/ML integration services.
- Communication: To respond to inquiries, send project updates, provide technical support, and share relevant information about our services.
- Business Operations: To process payments, manage contracts, maintain accounts, and comply with legal obligations.
- Marketing: To send newsletters, case studies, and promotional content (only with your explicit consent, which you may withdraw at any time).
- Analytics: To analyze website usage patterns, improve user experience, and optimize our marketing efforts.
- Security: To detect and prevent fraud, unauthorized access, and other security incidents.
- Legal Compliance: To comply with applicable laws, regulations, and legal processes, including tax and corporate reporting requirements.
5. Legal Basis for Processing
Under the NDPA and applicable data protection laws, we process your personal data based on the following legal grounds:
- Contractual Necessity: Processing is necessary to perform our contract with you or to take steps at your request before entering into a contract.
- Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving services, preventing fraud, and ensuring network security.
- Legal Obligation: Processing is necessary to comply with our legal obligations under Nigerian law (e.g., tax reporting, corporate filings).
- Consent: Where required by law, we obtain your explicit consent before processing your data for marketing or other specified purposes.
6. Data Sharing & Third Parties
We do not sell your personal data. We may share your information with the following categories of recipients:
6.1 Service Providers
- Cloud infrastructure providers (AWS, Google Cloud) for hosting client applications and data.
- Payment gateway providers (Flutterwave, Paystack) for processing transactions.
- Project management and communication tools (Asana, Slack, GitHub) for service delivery.
- Accounting and legal professionals for compliance and advisory services.
6.2 Business Partners
- Technology vendors and referral partners with whom we have formal partnership agreements.
- Professional associations (SMEDAN, Lagos Chamber of Commerce) for market access programs.
6.3 Legal Requirements
- We may disclose your data if required by law, court order, or governmental authority.
- We may share information to protect our rights, property, or safety, or that of our clients or the public.
All third-party recipients are contractually bound to maintain the confidentiality and security of your data and to process it only for the purposes we specify.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:
- Encryption: Data encryption in transit (TLS/SSL) and at rest (AES-256) for all sensitive information.
- Access Controls: Role-based access controls (RBAC) and multi-factor authentication (MFA) for all systems.
- Code Security: OWASP Top 10 compliance, password hashing (bcrypt), input validation, and SQL injection prevention.
- Monitoring: Automated monitoring and alerting for suspicious activity and potential breaches.
- Backups: Regular automated backups with redundancy across geographic regions.
- Employee Training: Staff training on data protection best practices and confidentiality obligations.
In the event of a data breach, we will notify affected individuals and the Nigeria Data Protection Commission (NDPC) within 72 hours, as required by the NDPA.
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law:
- Client Data: Retained for the duration of the engagement plus 6 years for tax and legal compliance purposes.
- Prospect Data: Retained for 2 years from the last interaction, unless you request deletion earlier.
- Website Analytics: Retained for 26 months, after which data is anonymized or deleted.
- Communication Records: Retained for 3 years for dispute resolution and quality assurance.
When data is no longer needed, we securely delete or anonymize it in accordance with our data retention schedule.
9. Your Rights
Under the NDPA and applicable data protection laws, you have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your personal data ("right to be forgotten"), subject to legal retention requirements.
- Right to Restrict Processing: Request limitation on how we use your data.
- Right to Data Portability: Receive your data in a structured, machine-readable format.
- Right to Object: Object to processing based on legitimate interests or for direct marketing.
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
- Right to Lodge a Complaint: File a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.
To exercise any of these rights, please contact us using the details provided in Section 14. We will respond within 30 days of receiving your request.
10. Cookies & Tracking Technologies
Our website keeps cookie and local storage use to a minimum:
10.1 Types We Use
- Preference (Local Storage): Remembers your dark/light mode preference and your cookie-consent choice. Not a cookie, never leaves your device.
- Analytics Cookies (Consent-Based): Google Analytics, which only loads after you accept our cookie banner. Helps us understand aggregate site traffic.
- Third-Party Form Cookies: Our contact form is processed by a third-party form service, which may set its own cookies to deliver your message securely.
We do not use marketing, advertising, or cross-site tracking cookies.
10.2 Managing Cookies
You can accept or reject analytics at any time using the "Cookie Settings" link in the footer, or manage cookies through your browser settings. Disabling analytics does not affect your ability to browse the site or use the contact form.
For more information, please see our Cookie Policy.
11. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete such information promptly.
If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.
12. International Data Transfers
As a Nigeria-based company, we primarily store and process data within Nigeria. However, we use cloud services (AWS, Google Cloud) that may involve data transfers to other jurisdictions. When data is transferred internationally, we ensure appropriate safeguards are in place, including:
- Standard contractual clauses approved by relevant data protection authorities.
- Data processing agreements with third-party providers.
- Selection of cloud regions that comply with NITDA cloud security standards.
All international transfers are conducted in compliance with the NDPA and applicable cross-border data transfer regulations.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will:
- Post the updated policy on this page with a revised "Last Updated" date.
- Notify active clients via email of significant changes.
- Update the effective date at the top of this document.
We encourage you to review this Privacy Policy periodically. Your continued use of our website and services after any changes constitutes acceptance of the updated policy.
