Privacy & Data Protection Policy
Our Epistemic Commitment to Data Integrity & Confidentiality
ITẸ is an independent customer research and business intelligence organization. Because we study delicate commercial dynamics, conversation drops, and customer elimination factors, we treat all proprietary merchant records, customer puzzles, and commercial intake data as strictly confidential. We do not sell, rent, monetize, or broker personal or corporate data under any circumstance.
1. Identity of the Data Controller
This Privacy Policy governs the processing of personal data collected through the website itehq.org (the “Service” or “Platform”) operated by ITẸ (“we”, “us”, or “our”), an independent research and business intelligence organization based in Lagos, Nigeria.
For the purposes of the Nigeria Data Protection Act, 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR), and applicable international privacy frameworks (including the General Data Protection Regulation - GDPR where applicable to cross-border engagements), ITẸ acts as the Data Controller responsible for your personal data.
2. Categories of Information We Collect
We collect information in three operational contexts:
A. Inbound Advisory & Customer Puzzle Submissions
When you submit an inquiry, request a diagnostic audit through our “For Businesses” portal, or submit a specific commercial puzzle via our contact forms, we collect:
- Personal identifiers: Full name, business title, and leadership role.
- Contact details: Business email address, telephone/WhatsApp contact number.
- Corporate profile: Company/brand name, industry vertical, and operational channels.
- Qualitative context: Observed customer drop-offs, pricing dilemmas, fulfillment frictions, and business hypotheses.
B. Research Briefing & Newsletter Subscriptions
When you subscribe to receive our periodic research dispatches, field notes, and executive briefings, we collect:
- Email address and optional industry affiliation.
- Timestamp and subscription verification metadata.
C. Automated Technical & Diagnostic Telemetry
When accessing itehq.org, our servers and analytics infrastructure may automatically register:
- Internet Protocol (IP) address, approximate geographic region, and device user-agent.
- Referral source, visited sub-pages, duration, and client-side error logs.
- Locally stored session state (such as client-side form drafts and preferences).
3. Lawful Bases for Processing
In accordance with Section 25 of the NDPA 2023 and global privacy regulations, we only process your data when a legitimate lawful basis exists:
When you explicitly opt in to our newsletter, request research briefings, or submit a puzzle through our forms.
When processing is required to assess, prepare, scope, or deliver commercial advisory and elimination diagnostics requested by your enterprise.
For maintaining the security, uptime, integrity, and anti-abuse safeguards of our public research portal and intake infrastructure.
When necessary to comply with applicable statutory filings, commercial audits, or formal legal requests within the Federal Republic of Nigeria.
4. Proprietary Commercial Client Data & Field Anonymization
A cornerstone of ITẸ's research ethics is that raw client financial metrics, internal margins, vendor identities, and customer transaction logs are held strictly confidential.
Whenever qualitative observations derived from commercial engagements are distilled into published “Field Notes”, all data is rigorously anonymized, synthesized across aggregate cohorts, and scrubbed of any identifiable brand markers or proprietary trade secrets unless the client has provided explicit, written prior authorization for a named case study.
5. Third-Party Data Processors & Sub-Processors
We do not sell, rent, or trade your personal information. We only share data with vetted third-party service providers who assist us in operating our infrastructure under strict confidentiality and security covenants:
- Hosting & Edge Infrastructure: Cloud hosting, DNS, and Content Delivery Networks (Vercel, Cloudflare, AWS) for secure HTTPS delivery.
- Email & Communications: Transactional and broadcast email infrastructure for distributing research briefings and advisory confirmations.
6. Cross-Border Data Transfers
Because our website and hosting systems operate on distributed global cloud servers, your information may be transferred to and stored in jurisdictions outside Nigeria. In all such cases, we ensure that adequate safeguards are maintained in compliance with the NDPA 2023, including standard contractual clauses and encryption in transit and at rest.
7. Data Retention Schedules
We retain personal data only for as long as necessary to fulfill the purposes for which it was gathered:
- Newsletter Subscribers: Retained until you opt out via unsubscribe links or directly contact our desk.
- Commercial Inquiries & Puzzles: Retained for a maximum of 24 months to maintain commercial continuity and research follow-up.
- Advisory Project Records: Retained in accordance with commercial statutory audit periods (up to 6 years under Nigerian corporate law).
8. Your Statutory Rights as a Data Subject
Under the Nigeria Data Protection Act 2023, the NDPR, and international privacy laws, you possess the following enforceable rights:
To exercise any of these rights, transmit a formal request to privacy@itehq.org. We respond to verified data subject inquiries within thirty (30) calendar days.
9. Information Security & Encryption
We implement industry-standard physical, electronic, and procedural safeguards designed to protect personal and corporate data against unauthorized access, loss, misuse, or alteration. All web transmissions through itehq.org are encrypted via Transport Layer Security (TLS 1.3 / HTTPS). Access to our internal inquiry records is restricted strictly to designated researchers and commercial partners.
10. Regulatory Authority & Complaints
If you believe that your personal data has been handled inconsistently with the Nigeria Data Protection Act, you have the statutory right to file a formal complaint with the competent supervisory authority:
11. Policy Modifications
We reserve the right to amend this Privacy Policy periodically to reflect changes in our research practices, advisory operations, or legal developments. The date of the most recent revision will always be displayed at the top of this page. Continued interaction with our platform constitutes acknowledgment of the updated policy terms.
12. Data Protection Officer & Contact Desk
If you have any questions, inquiries, or formal notices regarding our data handling or confidentiality practices, please direct them to our legal and data protection desk: