Contents
1. Data controller
The controller of your personal data is:
- Daily More Ltd.
- RC 1234567 (Corporate Affairs Commission, Nigeria)
- Office: No 1 P Umeigbo Lane, Amichi, Nnewi South LGA, Anambra State
- Email: angecia.dilu@gmail.com
- Data Protection Officer (DPO): angecia.dilu@gmail.com
2. What data we collect
We collect only what is strictly necessary for the purposes below. Personal data we may process includes:
- Identification data: name, company, tax number (only for billing), billing address.
- Contact data: email, phone, social profiles when shared.
- Project data: brief, content shared with us, technical credentials (stored in an encrypted password manager).
- Browsing data: IP address, browser type, operating system, pages visited, referrer. Anonymised whenever possible.
- Cookies and similar technologies: see our Cookie Policy.
We do not collect special categories of data (race, religion, health, sexuality, etc.) unless strictly necessary and with explicit consent.
3. Purposes and legal bases
We process your data for the following purposes, with the legal bases indicated:
- Responding to contact and quote requests โ execution of pre-contractual measures.
- Delivering contracted services โ performance of contract.
- Invoicing and tax compliance โ legal obligation.
- Newsletter โ consent. You may withdraw at any time.
- Anonymous site analytics โ legitimate interest, observing the principle of data minimisation.
- Handling complaints and exercising rights โ legitimate interest and legal compliance.
4. Retention periods
- Contact requests not converted to contracts: up to 12 months.
- Contractual and project data: during the contract and up to 5 years afterwards (civil prescription period).
- Tax data (invoices): 10 years, per applicable tax law.
- Newsletter subscriptions: until consent is withdrawn.
- Server logs and access records: up to 12 months.
5. Sharing with third parties and processors
We do not sell your data. We work with processors who handle data on our behalf, all bound by contract and auditable:
- Servers and hosting: Cloudflare, Inc. (US/EU โ DPF certified)
- Transactional email: Postmark (Wildbit LLC, US โ DPF certified)
- Compliant invoicing: local providers (Nigeria)
- Payments: Stripe (Ireland), Paystack and Flutterwave (Nigeria)
- Analytics: Plausible Analytics (EU, no cookies)
- Internal support: Notion Labs (US โ DPF) and 1Password (Canada)
We may also share data with competent authorities upon a justified order.
6. International transfers
Some transfers involve countries outside the EEA or Nigeria. When they happen, they are based on European Commission adequacy decisions (Data Privacy Framework) or Standard Contractual Clauses, complemented by additional technical measures (encryption at rest and in transit).
7. Your rights
Under applicable data protection law, you have the following rights:
- Right of access to your data
- Right to rectify inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object
- Right not to be subject to automated decisions
- Right to withdraw consent at any time
To exercise any of these rights, contact angecia.dilu@gmail.com. We respond within 30 days, extendable by 60 more in justifiably complex cases.
8. Information security
We implement technical and organisational measures appropriate to the risk:
- TLS 1.3 in transit and AES-256 at rest
- Mandatory multi-factor authentication across the team
- Principle of least privilege on access
- Encrypted, geographically redundant backups
- Annual security audit (penetration test)
- Incident response plan with notification to authorities within 72h
9. Minors
Our services are not aimed at minors under 16. We do not knowingly collect minors' data. If you become aware that a minor has provided us with data without consent, contact us and we will delete it immediately.
10. Changes to this policy
We may update this policy to reflect legal, technical or business changes. Material changes are communicated by email to active contacts at least 15 days in advance.
11. Complaints and DPO contact
If you consider that the processing of your personal data violates the law, you have the right to lodge a complaint with the competent supervisory authority:
- Nigeria Data Protection Commission (NDPC)
- ndpc.gov.ng
We recommend, however, that you first try to resolve the matter with us at angecia.dilu@gmail.com.