Privacy Policy
Last Updated:
1. Who We Are
1.1 This Privacy Policy explains how SOAVM Tech (“we”, “us”, “our”) collects and uses personal data when you visit the Website, contact us, or apply for a role.
1.2 SOAVM Tech is the data controller for the personal data described in this Policy. We operate from delivery hubs in Lagos, Nigeria; the European Union; and the United States.
1.3 For any privacy question or request, contact us at soavmtech@gmail.com.
1.4 This Policy does not cover personal data we process on behalf of clients during an engagement. In that case the client is the controller, we act as its processor, and the processing is governed by the data processing terms in the applicable MSA.
2. Personal Data We Collect
2.1 Information You Give Us
- Briefs and enquiries: your name, company, email address, role or title, the service you are interested in, and the content of your brief. The brief form prepares an email in your own mail client, so we receive this as an email you choose to send.
- Job applications: your name, contact details, CV, and anything else you include in an application email.
- Correspondence: anything you send us by email, phone, or social media.
2.2 Information Collected Automatically
- Server and security logs: IP address, timestamp, requested URL, response code, and user-agent string, generated by our hosting, CDN, and firewall on every request.
- Device storage: a single preference, your light or dark theme choice, stored in your browser. See our Cookie & Telemetry Policy.
We do not currently use analytics, advertising, or cross-site tracking technologies on the Website.
2.3 Information From Other Sources
Where you are introduced by a referee or partner, or apply through a recruitment platform, we receive the details they share with us. We may also consult professional profiles you have made public, such as LinkedIn, when assessing an application.
3. How and Why We Use Your Data
3.1 We use personal data only for the purposes below, and only where we have a lawful basis to do so.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Responding to briefs and scoping engagements | Brief and contact details | Steps at your request before entering a contract; legitimate interests |
| Assessing job applications | Application details | Steps before entering an employment contract; legitimate interests |
| Operating and securing the Website | Server and security logs | Legitimate interests in a secure, available service |
| Remembering your theme preference | Theme setting in browser storage | Strictly necessary to provide the feature you chose |
| Meeting legal and regulatory obligations | Any of the above, as required | Legal obligation |
3.2 We do not use personal data for automated decision-making that produces legal or similarly significant effects, and we do not build marketing profiles.
5. International Transfers
5.1 Because we deliver from Nigeria, the European Union, and the United States, personal data may be accessed across those regions.
5.2 Where data leaves the European Economic Area or the United Kingdom, we rely on an adequacy decision or on the European Commission’s Standard Contractual Clauses, with supplementary measures where needed. Transfers out of Nigeria are made in line with Part VIII of the Nigeria Data Protection Act 2023.
6. How Long We Keep It
| Data | Retention |
|---|---|
| Briefs that do not lead to an engagement | 24 months from last contact |
| Unsuccessful job applications | 12 months, unless you ask us to keep it longer |
| Server and security logs | 90 days, longer only while investigating an incident |
| Client and contract records | For the contract term plus the statutory period |
6.1 When a retention period ends we delete or irreversibly anonymise the data.
7. Children’s Data
7.1 The Website is directed at businesses and professionals and is not intended for anyone under 18 (see Clause 2 of our Terms).
7.2 We do not knowingly collect personal data from children under 13. If we learn that we have received such data, we will delete it without undue delay and will not use it for any purpose.
7.3 If you believe a child has provided us with personal data, contact soavmtech@gmail.com.
8. Security
8.1 We protect personal data with measures appropriate to the risk, including encryption in transit, access controls on a least-privilege basis, logging, and regular review.
8.2 No system is completely secure. If a breach affects your personal data and is likely to result in a risk to you, we will notify you and the relevant regulator as required by law.
9. Your Rights
9.1 EU and UK (GDPR)
You have the right to access, rectify, erase, restrict, and port your personal data, to object to processing based on legitimate interests, and to withdraw consent at any time where processing relies on it.
9.2 Nigeria (NDPA 2023)
You have the right to be informed, to access, rectify, and erase your data, to restrict or object to processing, to data portability, and to withdraw consent.
9.3 California (CCPA/CPRA)
You have the right to know what personal information we collect and how we use it, to delete and correct it, and to limit the use of sensitive personal information. We do not sell or share personal information, so there is nothing to opt out of — and we will never discriminate against you for exercising a right.
10. Exercising Your Rights and Complaints
10.1 To make a request, email soavmtech@gmail.com. We may need to verify your identity first. We respond within one month (GDPR and NDPA) or 45 days (CCPA), and will tell you if we need longer.
10.2 You may complain to a supervisory authority — the Nigeria Data Protection Commission, the data protection authority in your EU member state, or the California Privacy Protection Agency — though we would welcome the chance to resolve your concern first.
11. Changes to This Policy
11.1 We update this Policy when our processing changes — for example, if we add a form backend or an analytics tool. The “Last Updated” date shows the current version, and material changes will be highlighted on the Website.
12. Contact
12.1 Privacy questions and requests: soavmtech@gmail.com.