Privacy Policy

The Boltcliq Company is a technology partner delivering digital services, artificial intelligence, UX engineering, consulting, marketing, HR management, cybersecurity, blockchain, and related transformation programmes. Protecting personal data is part of how we build trust with the people, teams, and organisations we serve.

This Privacy Policy describes what information we collect, why we use it, who we share it with, how long we keep it, and the choices available to you. It applies to visitors of our website, prospective and existing clients, partners, job applicants, programme participants, and other individuals whose personal data we process in connection with our business.

Where we process personal data on behalf of a client-for example, within a software platform, HR workflow, or AI system we build-the client is usually the data controller and Boltcliq acts as a data processor. In those cases, the client’s privacy notice governs the end-user relationship, and we process data only under our contract with that client and applicable law.

The data controller responsible for personal information covered by this policy is The Boltcliq Company, operating primarily from Nigeria and serving organisations across Africa and other markets.

• Legal name: The Boltcliq Company
• Website: https://boltcliq.com
• Privacy enquiries: privacy@boltcliq.com
• General legal enquiries: legal@boltcliq.com
• Primary market: Nigeria and wider Africa

The information we collect depends on how you interact with us. We collect only what is reasonably necessary for the purposes described in this policy.

Website and marketing interactions

• Identity and contact details such as your name, email address, phone number, company name, job title, and country when you submit an enquiry, book a consultation, subscribe to updates, or start a project conversation.
• Technical and usage data such as IP address, browser type, device information, pages viewed, referral source, approximate location derived from IP, and interaction events on our website.
• Communications you send to us, including email, forms, support messages, and meeting notes where relevant to a business relationship.

Client and delivery relationships

• Business contact details and billing information for the individuals who manage contracts, approvals, and project communication on behalf of a client organisation.
• Project, product, and operational data needed to deliver consulting, software engineering, AI, UX, marketing, HR, cybersecurity, or blockchain services-including access credentials, workflow content, and configuration data provided by authorised client users.
• Records of proposals, statements of work, invoices, support tickets, and service performance where those records contain personal data.

HR, talent, and people systems

• Recruitment and assessment information when we support hiring, onboarding, or talent programmes for clients, or when you apply to work with Boltcliq directly.
• Professional history, skills, evaluation results, interview notes, and related documentation where permitted by law and disclosed to candidates or employees.
• Foundation and accelerator programme data-for example, application details, training progress, and employer-partnership records for initiatives such as youth talent and work-integrated learning programmes in Nigeria.

Products and platforms we build or operate

• Account, profile, transaction, and activity data within client-facing products such as lending, payroll, commerce, investment, learning, or workforce platforms, where Boltcliq or an affiliated entity operates the service or provides processing support.
• Security, audit, and fraud-prevention logs generated by systems we engineer or maintain.
• AI and automation inputs and outputs where personal data is included in prompts, documents, chat logs, or model-assisted workflows-processed only for the contracted purpose and with appropriate safeguards.

We do not intentionally collect special categories of personal data (such as health, biometric, or religious information) unless there is a clear business need, a lawful basis, and appropriate safeguards. Where required, we will provide additional notice before collecting such information.

• Directly from you when you fill in forms, contact us, sign agreements, attend meetings, apply for roles, or participate in programmes.
• Automatically through cookies, analytics tools, server logs, and similar technologies when you browse our website.
• From client organisations that provide authorised user or candidate information for project delivery.
• From service providers that support hosting, communications, analytics, payments, identity verification, or security-only where permitted and necessary.
• From publicly available professional sources such as company websites or professional networks, where relevant to legitimate business development and always in accordance with applicable law.

We use personal data for specific, documented purposes and only where we have a valid legal basis. Depending on context, that basis may include performance of a contract, legitimate interests, compliance with legal obligations, or your consent where consent is required.

• Responding to enquiries, preparing proposals, and delivering the services you or your organisation request.
• Designing, building, hosting, securing, and improving websites, applications, AI systems, dashboards, integrations, and digital products.
• Providing consulting, UX research, marketing, HR, cybersecurity, and transformation support tied to agreed scope.
• Operating analytics and product measurement to understand website performance, feature usage, and service quality.
• Managing billing, accounting, tax, compliance, and record-keeping obligations.
• Protecting our systems, users, and clients through access controls, monitoring, incident response, and fraud prevention.
• Sending service-related notices and, where permitted, marketing communications about Boltcliq services, events, or insights. You can opt out of marketing at any time.
• Supporting foundation, education, and talent initiatives that expand access to skills, employment pathways, and community impact.
• Establishing, exercising, or defending legal claims where necessary.

Our website uses cookies and similar technologies to keep the site functioning, remember preferences such as theme selection, measure traffic, and understand how visitors use our pages.

• Essential cookies and local storage needed for core site functionality, security, and preference management.
• Analytics services that help us measure visits and page performance. We currently use privacy-oriented analytics (Umami) to understand aggregate usage rather than to build individual advertising profiles.
• Session recording on a sampled basis with masking configured to reduce capture of sensitive field content. Recording is used to improve usability and diagnose issues, not for unrelated profiling.

You can control cookies through your browser settings. Blocking certain cookies may affect site functionality. Where required by law, we will request consent before placing non-essential cookies or similar technologies.

We do not sell personal data. We share information only when necessary and under appropriate safeguards:

• Service providers and subprocessors that help us with cloud hosting, email, analytics, customer relationship management, development tools, payments, background checks, or security-bound by contract and limited to authorised purposes.
• Client organisations, where you are a user of a platform or programme operated for or with that client and sharing is required for service delivery.
• Professional advisers such as lawyers, auditors, or insurers where reasonably necessary and subject to confidentiality duties.
• Regulators, courts, or law enforcement when we are legally required to disclose information or when disclosure is necessary to protect rights, safety, or the integrity of our services.
• Successors in the event of a merger, acquisition, reorganisation, or sale of assets, subject to continued protection consistent with this policy.

A current list of key subprocessors can be provided on request for enterprise clients. We assess vendors for security and data-protection expectations before engagement.

Boltcliq is based in Nigeria and may use infrastructure or service providers in other countries. When personal data is transferred outside Nigeria or your country of residence, we implement safeguards appropriate to the transfer, which may include contractual clauses, vendor assessment, encryption, access controls, and data-minimisation practices.

For international clients and visitors, we aim to align our practices with widely recognised standards such as the EU/UK GDPR framework, even where those laws do not apply directly, so that cross-border delivery remains accountable and transparent.

We retain personal data only for as long as necessary for the purposes described in this policy, unless a longer period is required or permitted by law.

• Website analytics and security logs: typically for a limited rolling period appropriate to the purpose, unless needed for an investigation.
• Sales and enquiry records: for the duration of the relationship and a reasonable period afterwards to manage follow-up, disputes, or legal claims.
• Client project and contract records: for the life of the agreement and thereafter as required by commercial, tax, or regulatory obligations.
• HR, recruitment, and programme records: in line with employment law, client instructions, and programme requirements.
• Marketing preferences: until you opt out or we no longer have a lawful basis to contact you.

When data is no longer needed, we delete or anonymise it using commercially reasonable methods.

We apply administrative, technical, and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. Measures may include role-based access, encryption in transit, secure development practices, environment separation, logging, backup controls, and staff confidentiality obligations.

Cybersecurity is part of our service offering as well as our internal practice. No method of transmission or storage is completely secure; if we become aware of a personal data breach likely to affect your rights, we will notify affected individuals and regulators where required by law.

Depending on your location and applicable law, you may have some or all of the following rights in relation to your personal data:

• Access: request confirmation of whether we process your data and obtain a copy of the information we hold about you.
• Correction: request correction of inaccurate or incomplete personal data.
• Erasure: request deletion of personal data in certain circumstances.
• Restriction: request that we limit processing in specific situations.
• Objection: object to processing based on legitimate interests or direct marketing.
• Portability: receive certain data in a structured, commonly used format where processing is automated and based on consent or contract.
• Withdraw consent: where processing is based on consent, withdraw it at any time without affecting prior lawful processing.
• Complaint: lodge a complaint with a supervisory authority.

To exercise your rights, email privacy@boltcliq.com with enough detail for us to verify your identity and locate relevant records. We respond within the timeframe required by applicable law.

As a company operating in Nigeria, we align our privacy programme with the Nigeria Data Protection Act 2023 (NDPA) and guidance from the Nigeria Data Protection Commission (NDPC), successor to the NDPR framework administered by NITDA.

• We process personal data lawfully, fairly, and transparently, and for specified purposes connected to our services and operations.
• We implement appropriate technical and organisational measures to safeguard personal data.
• We respect data-subject rights under Nigerian law, including access, rectification, erasure, restriction, and objection where applicable.
• Where we act as a data processor for a client, we process personal data only on documented instructions and support the client in meeting its obligations to data subjects.

If you are located in another African jurisdiction with local data-protection requirements, we will honour applicable rights and contractual commitments to the extent required for the services we provide.

Boltcliq designs and deploys AI-assisted workflows, analytics, chat experiences, and automation for clients and internal operations. Where these involve personal data, we aim to apply human oversight, purpose limitation, data minimisation, and security controls appropriate to the risk of the use case.

• We do not use website analytics or session recordings to make solely automated decisions that produce legal or similarly significant effects about you without appropriate safeguards and notice.
• Client AI systems may involve automated scoring, recommendations, or classification. Those features are governed by the client’s policies and contractual terms when Boltcliq acts as processor.
• You may contact us for more information about how automated processing affects you in Boltcliq-operated contexts.

Our corporate website and general business services are not directed at children under 16. We do not knowingly collect personal data from children through boltcliq.com without appropriate consent and parental or guardian involvement where required.

Foundation and education programmes may involve younger participants under formal programme rules, school partnerships, or guardian consent. In those cases, additional notices and safeguards apply and are communicated through the relevant programme channel.

Our website may link to third-party sites such as our blog, partner platforms, social networks, or client applications. Those sites are governed by their own privacy policies. We encourage you to review them before providing personal information.

We may update this Privacy Policy from time to time to reflect changes in law, technology, or our services. When we make material changes, we will update the “Last updated” date at the top of this page and, where appropriate, provide additional notice on our website or by direct communication.

If you have questions, concerns, or requests relating to this Privacy Policy or our handling of personal data, contact:

• Email: privacy@boltcliq.com
• Legal enquiries: legal@boltcliq.com
• Subject line: “Privacy request - [your name]”

If you are not satisfied with our response, you may contact the Nigeria Data Protection Commission (NDPC) or the relevant supervisory authority in your country, where applicable.