Effective Date: 1 January 2024
Company: Tenth Code Media Limited
Website(s): [www.tenthcodemedia.com, www.innovation-village.com]
Contact Email: [info@tenthcodemedia.com]

1. Introduction

Tenth Code Media Limited respects your privacy and is committed to protecting the personal information you share with us.

This Privacy Policy explains how we collect, use, store, disclose, and protect your personal data when you visit our websites, subscribe to our newsletters, download our resources, register for our trainings, contact us, attend our events, or interact with any of our digital platforms.

This policy is designed to align with applicable data protection laws, including the Nigeria Data Protection Act, 2023, which established the Nigeria Data Protection Commission as Nigeria’s data protection regulator.

2. Who We Are

Tenth Code Media Limited is a media, training, consulting, and digital transformation company. We operate platforms, publish content, provide learning programmes, organise events, develop business resources, and offer consulting services to individuals, organisations, and corporate clients.

For the purpose of this Privacy Policy, “Tenth Code Media”, “we”, “us”, or “our” refers to Tenth Code Media Limited and its related brands, platforms, and services.

3. Information We Collect

We may collect the following types of personal information:

a. Personal Identification Information

This may include:

  • Full name
  • Email address
  • Phone number
  • Job title
  • Company or organisation name
  • Country or location
  • Social media profile details, where voluntarily provided

b. Training, Event, and Registration Information

When you register for a training, webinar, event, workshop, or course, we may collect:

  • Name and contact details
  • Organisation name
  • Role or department
  • Payment or billing details
  • Attendance records
  • Learning preferences
  • Feedback and evaluation responses

c. Newsletter and Marketing Information

When you subscribe to our newsletter or download a resource, we may collect:

  • Name
  • Email address
  • Areas of interest
  • Download history
  • Email engagement activity, such as opens and clicks
  • Preferences relating to the type of content you want to receive

d. Website and Technical Information

When you visit our website, we may automatically collect:

  • IP address
  • Browser type
  • Device type
  • Pages visited
  • Time spent on pages
  • Referral source
  • Cookies and similar tracking data

The NDPC notes that cookies and embedded technologies may process website engagement patterns and that users should be able to manage cookie settings where applicable.

e. Information You Voluntarily Provide

We may collect information you provide when you:

  • Fill out a contact form
  • Respond to a survey
  • Request a proposal
  • Apply for a programme
  • Comment on our platforms
  • Send us an email or direct message
  • Participate in interviews, events, or community discussions

4. How We Use Your Information

We may use your personal information to:

  • Provide access to our websites, newsletters, trainings, events, and digital resources
  • Send newsletters, updates, and relevant content
  • Respond to enquiries, requests, and proposals
  • Process event or training registrations
  • Deliver downloadable resources such as e-books, reports, guides, and templates
  • Improve our content, products, services, and user experience
  • Analyse website and campaign performance
  • Send marketing communications, where permitted
  • Manage customer relationships and business development activities
  • Comply with legal, regulatory, tax, accounting, and contractual obligations
  • Prevent fraud, misuse, or unauthorised access to our platforms

5. Lawful Basis for Processing Personal Data

We process your personal information based on one or more lawful grounds, including:

  • Consent: where you subscribe to our newsletter, download a resource, or agree to receive marketing communications
  • Contract: where we need your information to deliver a service, training, event, or paid programme
  • Legal obligation: where we are required to keep records or comply with applicable law
  • Legitimate interest: where we need to improve our services, communicate with business prospects, protect our platforms, or grow our business in a responsible way

The NDPC recognises lawful bases such as consent, legal obligation, and contract in the processing of personal data.

6. Marketing Communications

We may send you newsletters, event invitations, training announcements, research reports, offers, and other relevant communications.

You can opt out of marketing emails at any time by clicking the unsubscribe link in our emails or contacting us directly.

Even if you unsubscribe from marketing emails, we may still send you important service-related or transactional communications, such as training confirmations, payment receipts, event updates, or responses to your enquiries.

7. Cookies and Tracking Technologies

Our websites may use cookies, pixels, analytics tools, and similar technologies to:

  • Improve website functionality
  • Understand visitor behaviour
  • Measure content performance
  • Analyse advertising campaigns
  • Personalise content and user experience
  • Support remarketing or retargeting campaigns

You can manage cookies through your browser settings or any cookie preference tool available on our website.

Please note that disabling cookies may affect some website features.

8. How We Share Your Information

We do not sell your personal data.

However, we may share your information with trusted third parties where necessary, including:

  • Email marketing platforms
  • Website hosting providers
  • Payment processors
  • Training facilitators or programme partners
  • Event management platforms
  • Customer relationship management tools
  • Analytics and advertising platforms
  • Professional advisers such as lawyers, auditors, or accountants
  • Regulators or public authorities where required by law

Where we use third-party service providers, we take reasonable steps to ensure they process your data securely and only for authorised purposes.

9. International Data Transfers

Some of the platforms and service providers we use may store or process personal data outside Nigeria.

Where this happens, we take reasonable steps to ensure that your personal information is protected in line with applicable data protection requirements, including appropriate safeguards for cross-border data transfers.

10. Data Retention

We will keep your personal information only for as long as necessary for the purpose for which it was collected, including to meet legal, accounting, reporting, contractual, or business requirements.

For example:

  • Newsletter subscription data may be retained until you unsubscribe or request deletion.
  • Training and event records may be retained for administrative, reporting, certification, or legal purposes.
  • Business enquiry records may be retained for follow-up and client relationship management.
  • Financial and transaction records may be retained as required by law.

When your personal data is no longer needed, we will delete, anonymise, or securely archive it.

11. Data Security

We take reasonable technical, administrative, and organisational measures to protect personal data against unauthorised access, loss, misuse, disclosure, alteration, or destruction.

These measures may include:

  • Secure website hosting
  • Access controls
  • Password protection
  • Data minimisation
  • Restricted internal access
  • Staff awareness and confidentiality obligations
  • Use of reputable third-party platforms

However, no method of online transmission or storage is completely secure. We therefore cannot guarantee absolute security but will take reasonable steps to protect your information.

12. Your Data Protection Rights

Subject to applicable law, you may have the right to:

  • Request access to the personal data we hold about you
  • Ask us to correct inaccurate or incomplete data
  • Request deletion of your personal data
  • Withdraw consent where processing is based on consent
  • Object to certain types of processing
  • Request restriction of processing
  • Request transfer of your data where applicable
  • Lodge a complaint with the appropriate data protection authority

To exercise any of these rights, please contact us using the details provided in this policy.

13. Children’s Privacy

Our websites, newsletters, trainings, and services are not primarily directed at children.

We do not knowingly collect personal information from children without appropriate parental or guardian consent. If we become aware that we have collected personal data from a child without proper consent, we will take reasonable steps to delete such information.

14. Links to Other Websites

Our websites and newsletters may contain links to third-party websites, platforms, or resources.

We are not responsible for the privacy practices, content, or security of those third-party websites. We encourage you to read their privacy policies before sharing personal information with them.

15. User-Generated Content and Public Comments

Where our platforms allow comments, guest contributions, interviews, testimonials, or public submissions, please note that any information you voluntarily make public may be visible to other users.

You should avoid posting sensitive personal information in public areas of our websites or social media platforms.

16. Media, Interviews, and Event Content

Where you participate in our interviews, events, webinars, podcasts, videos, or public programmes, we may record, photograph, publish, or distribute content featuring your name, image, voice, job title, organisation, or comments, where appropriate and with necessary consent or notification.

Such content may be used for editorial, educational, promotional, archival, or reporting purposes.

17. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our operations, services, legal obligations, or data protection practices.

When we update this policy, we will revise the effective date at the top of the page.

We encourage you to review this Privacy Policy periodically.

18. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Tenth Code Media Limited
Email: info@tenthcodemedia.com
Address: 15b Adedeji Adekola Street, Off Freedom way, Lekki Phase 1, Lagos, Nigeria
Website: www.tenthcodemedia.com

You may also contact the Nigeria Data Protection Commission if you believe your data protection rights have been violated.