Data Protection Policy
Effective Date: June 1, 2025 | Last Updated: June 1, 2025
Regulatory Compliance: This policy is prepared in accordance with the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act (NDPA) 2023, issued by the Nigeria Data Protection Commission (NDPC).
1. Our Commitment
Marque Technologies Engineering Academy is committed to processing personal data lawfully, fairly, and transparently. We treat data protection as a fundamental right of our users and embed privacy principles into all aspects of our platform design and operations.
2. Data Controller Information
- Organisation: Marque Technologies Engineering Academy
- Address: Lagos, Nigeria
- Data Protection Officer (DPO): privacy@marquetechacademy.com
- Regulatory Body: Nigeria Data Protection Commission (NDPC) ndpc.gov.ng
3. Data Protection Principles
We process all personal data in accordance with the following principles:
- Lawfulness, Fairness & Transparency: We process data on a valid legal basis and are open about how we use it.
- Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and not processed in ways incompatible with those purposes.
- Data Minimisation: We only collect data that is adequate, relevant, and limited to what is necessary.
- Accuracy: We take reasonable steps to ensure personal data is accurate and kept up to date.
- Storage Limitation: Data is kept only as long as necessary for the stated purpose.
- Integrity & Confidentiality: Data is processed with appropriate security measures against unauthorised access, accidental loss, or destruction.
- Accountability: We are responsible for and can demonstrate compliance with these principles.
4. Categories of Personal Data Processed
| Category | Examples | Retention |
|---|---|---|
| Identity | Full name, profile photo | Account lifetime + 30 days after deletion |
| Contact | Email address, phone number | Account lifetime + 30 days after deletion |
| Authentication | Hashed passwords, session tokens | Session / 7 days for tokens |
| Financial | Payment records, transaction IDs | 7 years (Nigerian tax law) |
| Usage | Course progress, lesson completions | Account lifetime |
| Technical | IP address, device info, logs | 90 days (security logs) |
5. Technical & Organisational Security Measures
- Encryption in Transit: All data transmitted between your browser and our servers uses TLS 1.2+.
- Encryption at Rest: Database contents are encrypted at rest using AES-256.
- Password Security: Passwords are never stored in plain text. We use bcrypt hashing via Supabase Auth.
- Row-Level Security (RLS): Database access is governed by Supabase RLS policies ensuring users can only access their own data.
- Access Control: Internal staff access to production data is role-based and logged.
- Security Headers: We deploy HTTP security headers including CSP, HSTS, X-Frame-Options, and others.
- Incident Response: We have a documented process to identify, contain, and report data breaches within 72 hours to the NDPC where required.
6. Data Subject Rights
As a data subject under Nigerian law, you are entitled to:
- Request access to your personal data (Subject Access Request)
- Request correction of inaccurate data
- Request deletion of your data (right to erasure)
- Object to processing or request restriction
- Receive your data in portable format (data portability)
- Withdraw consent at any time (where consent is the legal basis)
- Lodge a complaint with the NDPC
Submit data requests to our DPO at privacy@marquetechacademy.com. We will respond within 30 days as required under the NDPA 2023.
7. Third-Party Data Processors
We engage the following sub-processors who handle data on our behalf:
- Supabase Inc. Database, authentication, and file storage. Data Processing Agreement in place. See Supabase Privacy Policy.
- Payment Provider Payment processing. PCI-DSS compliant. We do not store card data.
All sub-processors are bound by data processing agreements consistent with NDPR/NDPA requirements.
8. Data Breach Response
In the event of a personal data breach, we will:
- Assess and contain the breach immediately upon discovery.
- Notify affected data subjects without undue delay if the breach poses a high risk to their rights.
- Notify the NDPC within 72 hours where required by law.
- Maintain an internal breach register.
To report a suspected data breach or security vulnerability, contact us at security@marquetechacademy.com.
9. Policy Review
This Data Protection Policy is reviewed at least annually or when significant changes occur to our data processing activities, applicable law, or regulatory guidance from the NDPC.