Privacy Policy

1. Introduction

LinkBridge Systems Limited (“LinkBridge”, “we”, “our”, or “us”) is a technology company incorporated in the Federal Republic of Nigeria. We provide digital transformation, artificial intelligence (AI), business process automation, systems integration, enterprise application development, managed technology services, and technology advisory services that help organizations improve operational efficiency and accelerate digital innovation.

We recognize that privacy is a fundamental right and are committed to protecting the personal data entrusted to us. This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you visit our website, engage our services, communicate with us, or otherwise interact with LinkBridge.

This Privacy Policy has been developed in accordance with the Nigeria Data Protection Act, 2023 (NDPA) and other applicable data protection and privacy laws where required by the nature of our operations or the jurisdictions in which we provide services.

By using our website or interacting with us, you acknowledge that you have read and understood this Privacy Policy.

2. Scope of this Privacy Policy

This Privacy Policy applies to the processing of personal data relating to:

• Visitors to our website;
• Prospective customers and business enquiries;
• Clients and authorized representatives of our clients;
• Vendors, suppliers, consultants and business partners;
• Individuals subscribing to newsletters, publications or marketing communications;
• Individuals attending our webinars, events or training programmes;
• Individuals communicating with us through email, telephone, social media or online forms; and
• Any other individual whose personal data is collected in connection with our business operations.

This Privacy Policy applies only to personal data processed by LinkBridge in connection with our website and business activities. It does not apply to third-party websites or services that may be linked from our website.

3. About LinkBridge

LinkBridge is a Nigerian technology company focused on enabling organizations to modernize operations through innovative digital solutions.

Our core service offerings include:

• Digital Transformation
• Artificial Intelligence (AI) Transformation
• Business Process Automation
• Systems Integration
• Enterprise Application Development
• Managed Technology Services
• Technology Advisory Services

Depending on the nature of our engagement, LinkBridge may act as:

• a Data Controller, where we determine the purposes and means of processing personal data; or
• a Data Processor, where we process personal data solely on behalf of our clients and in accordance with their documented instructions.

Where we process personal data as a Data Processor, our obligations are governed by applicable law and contractual agreements with our clients.

4. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings assigned to them below:

Consentmeans any freely given, specific, informed and unambiguous indication of a Data Subject’s wishes by which they signify agreement to the processing of their Personal Data.

Data Controller means a person or organization who, alone or jointly with others, determines the purposes and means of processing Personal Data.

Data Processor means a person or organization who processes Personal Data on behalf of a Data Controller.

Data Subject means an identified or identifiable natural person whose Personal Data is processed by LinkBridge.

Personal Data means any information relating to an identified or identifiable individual, whether directly or indirectly, including information that can reasonably be used to identify that individual.

Processing means any operation or set of operations performed on Personal Data, whether by automated or non-automated means, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, transmission, restriction, deletion or destruction.

Sensitive Personal Datameans Personal Data relating to an individual’s race or ethnic origin, religious or philosophical beliefs, health status, sex life, biometric or genetic data, trade union membership, or any other category of data classified as sensitive under applicable law.

Third Partymeans any natural or legal person, public authority, agency or other body other than the Data Subject, LinkBridge, or persons authorized to process Personal Data under LinkBridge’s direct authority.

5. Categories of Personal Data We Collect

The Personal Data we collect depends on how you interact with LinkBridge and the services you request. We collect only the Personal Data that is necessary for legitimate business purposes and in accordance with applicable law.

5.1 Information You Provide Directly

When you interact with us, you may provide information such as:

• Full name;
• Business or company name;
• Job title;
• Email address;
• Telephone number;
• Business address;
• The contents of enquiries, requests or correspondence submitted through our website, email or other communication channels; and
• Any other information you voluntarily provide to us.

5.2 Information We Collect Automatically

When you visit our website, certain information may be collected automatically through cookies and similar technologies, including:

• Internet Protocol (IP) address;
• Browser type and version;
• Device type;
• Operating system;
• Pages visited;
• Date and time of access;
• Referral source;
• Website usage patterns; and
• Other technical information necessary to improve the security, performance and functionality of our website.

Further information regarding our use of cookies is available in our Cookie Policy.

5.3 Information Collected During Business Engagements

Where you engage LinkBridge for consulting or technology services, we may process business-related Personal Data necessary for the performance of our contractual obligations, including:

• Contact details of client representatives;
• Project-related communications;
• User account information where applicable;
• Technical support requests;
• Training attendance records;
• System audit logs;
• Service delivery records; and
• Other information required to provide agreed services.

Where LinkBridge processes Personal Data on behalf of its clients, we do so strictly in accordance with contractual obligations and documented instructions from the relevant Data Controller.

5.4 Information We Do Not Intentionally Collect

Our website is not intended to collect Sensitive Personal Data unless such information is necessary for a specific business purpose or is voluntarily provided by you.

We request that you do not submit Sensitive Personal Data through our website unless expressly requested by LinkBridge or required for the provision of a specific service.

6. How and Why We Use Your Personal Data

LinkBridge processes Personal Data only where there is a lawful basis to do so and only for specified, explicit, and legitimate purposes. Depending on your interaction with us, we may process your Personal Data for the following purposes:

Where we rely on your consent as the lawful basis for processing, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

Where we rely on our legitimate interests, we ensure that such interests are balanced against your rights and freedoms and that appropriate safeguards are implemented.

We will not process your Personal Data for purposes that are incompatible with the purpose for which it was originally collected unless permitted by applicable law or with your consent.

7. How We Collect Personal Data

We collect Personal Data through a variety of lawful channels, depending on the nature of your interaction with us. These include:

Information You Provide Directly

We collect Personal Data when you:

• complete forms on our website;
• contact us by email, telephone or other communication channels;
• request information about our products or services;
• subscribe to newsletters or other communications;
• register for events, webinars or training programmes;
• submit employment applications; or
• otherwise communicate with us.

Information Collected Automatically

When you visit our website, certain technical information may be collected automatically through cookies and similar technologies, including website usage information, browser information, device identifiers and IP addresses. Further details are provided in our Cookie Policy.

Information Received from Third Parties

Where permitted by law, we may receive Personal Data from:

• our clients;
• business partners;
• publicly available sources;
• professional advisers;
• recruitment platforms;
• service providers acting on our behalf; and
• other third parties where you have authorised the sharing of your Personal Data.

We take reasonable steps to ensure that Personal Data obtained from third parties has been collected lawfully.

8. Cookies and Similar Technologies

Our website uses cookies and similar technologies to improve functionality, enhance user experience, analyse website traffic and maintain the security of our online services.

Cookies are small text files that are stored on your device when you visit a website. Some cookies are essential for the operation of our website, while others help us understand how visitors use our website or remember user preferences.

We use the following categories of cookies:

• Strictly Necessary Cookies – Required for the operation and security of our website.
• Functional Cookies – Enable enhanced functionality and remember user preferences.
• Analytics Cookies – Help us understand how visitors interact with our website so that we can improve its performance.
• Marketing Cookies – Used only where applicable and with your consent to deliver relevant communications or measure the effectiveness of marketing activities.

Where required by law, non-essential cookies will only be placed on your device after you have provided your consent through our cookie preference management tool. You may manage or withdraw your cookie preferences at any time through our cookie settings or by adjusting your browser settings. Further information about the cookies we use is available in our Cookie Policy.

9. Sharing and Disclosure of Personal Data

LinkBridge treats your Personal Data as confidential and does not sell, rent or trade your Personal Data to third parties. We may disclose your Personal Data only where necessary and in accordance with applicable law, including the Nigeria Data Protection Act, 2023.

Your Personal Data may be shared with the following categories of recipients:

9.1 Service Providers

We may engage carefully selected third-party service providers to support our business operations. These providers process Personal Data only on our documented instructions and are contractually required to implement appropriate technical and organizational measures to protect your information. Such service providers may include:

• Cloud hosting providers;
• Email and communication service providers;
• Website hosting providers;
• Customer relationship management (CRM) platforms;
• IT support and managed service providers;
• Payment service providers (where applicable);
• Professional advisers including auditors, accountants and legal advisers.

9.2 Business Partners

Where necessary for the delivery of our services, we may share Personal Data with trusted implementation partners, subcontractors or consultants who are engaged to support a project on our behalf.

9.3 Regulatory Authorities and Law Enforcement

We may disclose Personal Data where required to:

• comply with applicable laws or regulations;
• respond to lawful requests from government authorities;
• comply with court orders or other legal processes;
• protect our legal rights;
• investigate suspected fraud or unlawful activities; or
• protect the rights, property or safety of LinkBridge, our clients or other individuals.

9.4 Corporate Transactions

If LinkBridge undergoes a merger, acquisition, corporate restructuring, investment transaction or sale of assets, Personal Data may be transferred as part of that transaction, subject to appropriate confidentiality and data protection safeguards.

10. International Transfer of Personal Data

As a Nigerian technology company, LinkBridge primarily processes Personal Data within Nigeria. However, certain service providers or technology platforms that support our operations may process Personal Data outside Nigeria.

Where Personal Data is transferred to another country, we will ensure that appropriate safeguards are implemented in accordance with the Nigeria Data Protection Act, 2023. Such safeguards may include:

• transferring Personal Data only to jurisdictions that provide an adequate level of data protection;
• entering into legally binding contractual arrangements with recipients;
• implementing appropriate technical and organizational security measures; or
• relying on another lawful transfer mechanism recognised under applicable law.

We take reasonable steps to ensure that any recipient of Personal Data outside Nigeria maintains an appropriate standard of privacy and security.

11. Retention of Personal Data

LinkBridge retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable law, regulation or contractual obligation. When determining appropriate retention periods, we consider:

• the purpose for which the Personal Data was collected;
• legal and regulatory requirements;
• contractual obligations;
• business operational needs; and
• the need to resolve disputes or enforce our legal rights.

Once Personal Data is no longer required, it will be securely deleted, anonymized or destroyed using appropriate technical and organizational measures. The table below provides indicative retention periods for common categories of Personal Data processed by LinkBridge.

Where retention is required by law, LinkBridge will retain the information for the applicable statutory period.

12. Security of Personal Data

LinkBridge maintains appropriate technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access. Our security programme includes measures such as:

• access controls based on business need;
• authentication and identity management controls;
• encryption of Personal Data where appropriate;
• secure network and infrastructure management;
• endpoint protection and malware prevention;
• vulnerability management and system monitoring;
• secure software development and change management practices;
• regular backup and recovery procedures;
• employee confidentiality obligations and privacy awareness training; and
• incident detection, response and recovery procedures.

While we implement appropriate safeguards to protect Personal Data, no method of electronic transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security.

Where a Personal Data breach is likely to result in a risk to the rights and freedoms of affected individuals, LinkBridge will respond in accordance with applicable legal and regulatory requirements, including notification to the Nigeria Data Protection Commission and affected Data Subjects where required.

13. Your Rights as a Data Subject

Subject to applicable law, you have the following rights regarding your Personal Data processed by LinkBridge:

Right to be Informed

You have the right to receive clear and transparent information about how we collect, use, disclose and protect your Personal Data.

Right of Access

You may request confirmation as to whether we process your Personal Data and, where applicable, obtain a copy of the Personal Data we hold about you.

Right to Rectification

You have the right to request that inaccurate, incomplete or outdated Personal Data be corrected or updated without undue delay.

Right to Erasure

You may request the deletion of your Personal Data where:

• the Personal Data is no longer necessary for the purpose for which it was collected;
• you withdraw your consent and there is no other lawful basis for processing;
• the Personal Data has been unlawfully processed; or
• deletion is required by applicable law.

This right is subject to any legal, regulatory or contractual obligations requiring LinkBridge to retain certain information.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

Right to Restrict Processing

You may request that we temporarily suspend the processing of your Personal Data in circumstances permitted by law.

Right to Object

You may object to the processing of your Personal Data where processing is based on our legitimate interests or where your Personal Data is processed for direct marketing purposes.

Right to Data Portability

Where technically feasible and legally applicable, you may request that your Personal Data be provided to you or another organization in a structured, commonly used and machine-readable format.

Right to Lodge a Complaint

If you believe that LinkBridge has not handled your Personal Data in accordance with applicable law, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or any other competent supervisory authority.

Exercising Your Rights

To exercise any of the rights described in this Privacy Policy, you may contact us using the details provided in the Contact Us section below. To protect your privacy and prevent unauthorized disclosure of Personal Data, we may request information necessary to verify your identity before processing your request.

We will respond to requests within the timeframes prescribed by applicable law. We will not charge a fee for responding to legitimate requests unless a request is manifestly unfounded, excessive or repetitive, in which case we reserve the right to charge a reasonable administrative fee or decline the request where permitted by law.

14. Personal Data of Children

Our website and services are not directed at children.

We do not knowingly collect or process the Personal Data of children except where such processing is expressly authorized by applicable law or carried out with the consent of a parent or legal guardian, where required.

If we become aware that Personal Data has been collected from a child without the required legal basis, we will take reasonable steps to delete such information promptly. Parents or legal guardians who believe that a child has provided Personal Data to LinkBridge without appropriate authorization may contact us using the details provided in this Privacy Policy.

15. Third-Party Websites

Our website may contain links to websites or services operated by third parties for your convenience or information.

LinkBridge is not responsible for the privacy practices, security or content of third-party websites. We encourage you to review the privacy policies of any third-party websites you visit before providing your Personal Data.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business operations, legal obligations, technology or data processing practices.

Where material changes are made, we will take appropriate steps to notify users through our website or other suitable communication channels where required by law. The “Last Updated” date at the beginning of this Privacy Policy indicates when it was most recently revised.

Your continued use of our website following the publication of any updates constitutes your acknowledgement of the revised Privacy Policy, except where additional consent is required by law.

17. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns regarding the processing of your Personal Data, please contact us using the details below.

Where you are dissatisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).