Effective Date: April 2026 | Last Updated: April 2026
MIND+ Facilitation Limited (“MIND+,” “we,” “our,” or “us”) is committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains how we collect, use, store, share, and protect your information when you visit our website (www.mindplus.biz), use our services, or otherwise interact with us.
This policy is issued in compliance with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC).
1. Data Controller
The data controller responsible for your personal data is:
MIND+ Facilitation Limited
Lagos, Nigeria
Email: info@mindplus.biz
Website: www.mindplus.biz
2. Information We Collect
2.1 Information You Provide Directly
- Contact information: name, email address, phone number, organisation name
- Enquiry details: messages submitted through our contact form, service of interest, and any information you include in your correspondence
- Training and event registration: participant names, job titles, dietary requirements (where applicable), and payment details
- WhatsApp communications: messages, enquiries, and files exchanged via our WhatsApp Business channel
2.2 Information Collected Automatically
- Usage data: pages visited, time spent on pages, referring URL, browser type, and device information
- Cookies and similar technologies: we may use essential cookies to ensure core website functionality and optional analytics cookies to understand how visitors use our site (see Section 8 below)
- IP address: collected automatically by our web hosting provider for security and analytics purposes
3. Purpose and Legal Basis for Processing
We process your personal data only for specific, legitimate purposes, as required by the NDPA. These include:
- Performance of a contract: to deliver training, consulting, coaching, and facilitation services you have engaged us for
- Consent: to send you newsletters, event invitations, or marketing communications (you may withdraw consent at any time)
- Legitimate interest: to respond to enquiries, improve our website and services, and maintain business records
- Legal obligation: to comply with applicable laws, regulations, or lawful requests from authorities
4. How We Use Your Information
- To respond to your enquiries and provide requested information
- To deliver and administer training programmes, workshops, and consultancy services
- To process registrations and payments for open courses and bespoke programmes
- To send service updates, follow-up materials, and (with your consent) promotional content
- To improve our website functionality and user experience
- To comply with legal and regulatory obligations
5. Data Sharing and Disclosure
We do not sell, rent, or trade your personal data. We may share your information only in the following circumstances:
- Service providers: trusted third-party providers who assist us with website hosting, email delivery, payment processing, or analytics — bound by data processing agreements
- Professional obligations: where required to issue certifications (e.g., ILO certificates for SIYB programmes), relevant data may be shared with the certifying body
- Legal requirements: where disclosure is required by law, regulation, court order, or lawful request from a government authority
6. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Specifically:
- Enquiry data: retained for up to 24 months after the last communication, then deleted
- Client and training records: retained for up to 6 years in accordance with applicable tax and business record-keeping obligations
- Marketing consent records: retained for as long as consent remains active, and for 12 months after withdrawal for audit purposes
7. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include secure hosting, access controls, encrypted communications, and regular review of our data handling practices.
8. Cookies
Our website may use cookies — small text files stored on your device — to ensure essential functionality and, with your consent, to gather anonymised analytics data. You can control cookie preferences through your browser settings. Essential cookies required for core website functions do not require consent; all other cookies require your opt-in consent before activation, in line with the NDPC’s GAID.
9. Your Rights
Under the NDPA 2023, you have the following rights regarding your personal data:
- Right of access: request a copy of the personal data we hold about you
- Right to rectification: request correction of inaccurate or incomplete data
- Right to erasure: request deletion of your personal data where there is no compelling reason for continued processing
- Right to restrict processing: request that we limit how we use your data
- Right to data portability: receive your data in a structured, commonly used format
- Right to object: object to processing based on legitimate interest or for direct marketing purposes
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing
To exercise any of these rights, please contact us at info@mindplus.biz. We will respond within 30 days of receiving your request.
10. Cross-Border Data Transfers
Where your personal data is transferred outside Nigeria (for example, through our use of international hosting or email service providers), we ensure that adequate safeguards are in place as required by the NDPA, including data processing agreements that protect your data to a standard consistent with Nigerian law.
11. Children’s Privacy
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact us immediately so we can take appropriate steps to delete such information.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Any material changes will be posted on this page with an updated effective date. We encourage you to review this page periodically.
13. Complaints
If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.