Draft Document
Privacy Policy (Draft)
This Document Is Not Yet in Effect
This page sets out the structure of the final document and the matters each section will address. It contains no binding terms. The final text will be prepared and approved by Suburban Cloud's legal counsel and published on this page. Enquiries may be directed to support@suburbancloud.ng.
The final policy will explain how Suburban Cloud collects, uses, stores and protects personal data in accordance with the Nigeria Data Protection Act 2023 and related regulations. The sections below set out the structure that legal counsel has been asked to complete.
1.Who We Are
This section will address:
- Legal entity name, registration number and registered address
- Data controller identity and contact details
- Data Protection Officer contact
2.Scope of This Policy
This section will address:
- Website visitors, console account holders and their end users
- Distinction between data Suburban controls and customer data Suburban processes on a customer's behalf
3.Personal Data We Collect
This section will address:
- Account, billing and identity data
- Usage, log and device data
- Support communications
- Data from third parties (payment providers, registries)
4.Purposes and Lawful Basis
This section will address:
- Each processing purpose mapped to an NDPA 2023 lawful basis
- Consent handling and withdrawal
7.Data Residency and Cross-Border Transfers
This section will address:
- Where personal data is stored
- Any cross-border transfers and the NDPA safeguards relied on
8.Retention
This section will address:
- Retention periods per data category
- Deletion and anonymisation on account closure
9.Security Measures
This section will address:
- Technical and organisational measures
- Breach notification approach and timelines under the NDPA
10.Your Rights
This section will address:
- Access, rectification, erasure, restriction, portability and objection
- How to make a request and response timelines
- Right to complain to the Nigeria Data Protection Commission
11.Children
This section will address:
- Age restrictions on use of the service
12.Changes and Contact
This section will address:
- How updates are notified
- Effective date and version history
- Contact details for privacy questions
Related document: Terms of Service (Draft)