Privacy, explained with clarity.

Scope of this policy

This Privacy Policy applies when you visit our website, contact us, join our mailing list, book or pay for a session, attend a counseling or coaching service, or otherwise interact with Sparkshift Solutions.

Sparkshift Solutions acts as the data controller for personal information collected through these activities. We process personal data in line with applicable Nigerian data-protection requirements, including the Nigeria Data Protection Act 2023.

Information we collect

Depending on how you interact with us, we may collect:

• Identity and contact details, including your name, email address and telephone number.
• Booking details, such as the service or package selected, preferred scheduling information and session format.
• Payment information, including transaction references, payment status and invoice details. Card details are processed by our payment provider and are not stored by us.
• Communications you send through forms, email, telephone, social media or other channels.
• Session-related information you choose to share during counseling or coaching, which may include sensitive personal information.
• Technical information, such as IP address, browser type, device information, pages visited and essential cookie data.

How and why we use information

We use personal information to:

• respond to enquiries and provide requested counseling or coaching services;
• manage bookings, scheduling, payments, receipts and service communications;
• maintain appropriate service and administrative records;
• send newsletters or updates where you have chosen to receive them;
• protect our clients, team, website and services from misuse or security threats;
• meet legal, regulatory, safeguarding and professional obligations; and
• improve our website, resources and client experience.

Our legal bases may include your consent, performance of a contract with you, compliance with a legal obligation, protection of vital interests, and our legitimate interests in operating and securing our services. You may withdraw consent at any time where consent is the basis for processing.

When information may be shared

We do not sell or rent your personal information. We may share only the information needed with trusted providers that support our website, email delivery, hosting, administration and payment processing, including Paystack for online payments. These providers process information under their own terms and applicable data-protection obligations.

We may also disclose information when required by law, to establish or defend legal rights, to respond to a valid request from an authority, or where disclosure is reasonably necessary to prevent serious harm. Confidentiality relating to counseling services may be subject to safeguarding, legal and professional exceptions.

Retention, transfers and security

We retain information only for as long as reasonably necessary for the purpose it was collected, including service delivery, financial record-keeping, dispute resolution, safeguarding and legal compliance. Retention periods vary according to the type and sensitivity of the record.

Some service providers may process information outside Nigeria. Where this occurs, we take reasonable steps to use providers and safeguards that offer appropriate protection.

We use reasonable organisational and technical safeguards to protect personal information. However, no internet transmission or storage system can be guaranteed to be completely secure.

Your data-protection rights

Subject to applicable law and relevant exceptions, you may ask us to:

• confirm whether we process your personal information and provide access to it;
• correct information that is inaccurate or incomplete;
• delete information that we no longer have a lawful reason to retain;
• restrict or object to certain processing;
• provide eligible information in a portable format; or
• withdraw consent and stop direct marketing communications.

We may need to verify your identity before completing a request. You may also raise a concern with the Nigeria Data Protection Commission if you believe your data-protection rights have not been respected.

Children and third-party links

Our website and general booking services are not directed to children acting independently. A parent, guardian or other authorised adult should contact us before personal information about a minor is submitted.

Our website may link to third-party websites or social platforms. Their privacy practices are governed by their own policies, and we encourage you to review them before providing information.

Changes to this policy

We may update this policy as our services, technology or legal obligations evolve. The revised version will be posted on this page with a new “last updated” date.