Privacy Policy

Last updated:  |  Effective: 12 March 2026  |  Version 1.0

1. Company Identity & Contact

Data Controller:
Altos Alpha Solutions Ltd
RC Number: 9412847 (Corporate Affairs Commission, Nigeria)
TIN: 2622467489265
Lagos State, Nigeria
Email: info@altosalpha.com.ng
Phone: 0904 523 6189
Website: altosalpha.com.ng

2. Scope of This Policy

This Privacy Policy applies to all personal data collected by Altos Alpha Solutions Ltd through:

• Our website at altosalpha.com.ng and any subdomains
• Our AI products, platforms, and services
• WhatsApp Business communications via official Meta Business API
• Email, telephone, and any other direct communications
• Client onboarding, contracts, and service delivery

3. Legal Framework

We process personal data in compliance with:

• Nigeria Data Protection Regulation (NDPR) 2019, issued by the National Information Technology Development Agency (NITDA)
• Nigeria Data Protection Act 2023
• Consumer Protection Council Act (Nigeria)
• The Companies and Allied Matters Act 2020 (CAMA)
• Meta Platform Terms and WhatsApp Business Policy where applicable

4. Data We Collect

4.1 Information You Provide Directly

• Name, email address, phone number (including WhatsApp number)
• Company name, job title, industry
• Messages, enquiries, and communications submitted via forms or WhatsApp
• Payment information (processed securely via third-party payment processors; we do not store card details)
• Contract and onboarding documentation

4.2 Data Collected Automatically

• IP address, browser type, and device information
• Pages visited, time on site, referral source
• Cookies and similar tracking technologies (see our Cookie Policy)

4.3 Data from Third Parties

• Business contact information from publicly available sources (LinkedIn, company websites)
• Information provided by clients about their customers when we process data on their behalf (as a Data Processor)

We do not collect sensitive personal data (health, biometrics, religion, political opinion) unless strictly required for a specific service and with explicit consent.

5. How We Use Your Data

We use personal data for the following purposes and rely on the following lawful bases:

• Service delivery — To provide, operate, and maintain our AI services (Contractual necessity)
• Communication — To respond to enquiries, provide support, and send service updates (Contractual necessity / Legitimate interest)
• Marketing — To send relevant information about our services, case studies, and events (Legitimate interest; opt-out available at any time)
• Legal compliance — To comply with applicable Nigerian laws and regulations (Legal obligation)
• Fraud prevention & security — To protect our systems and users (Legitimate interest)
• Product improvement — To analyse usage and improve our services (Legitimate interest)

6. WhatsApp Business Communications

Altos Alpha Solutions Ltd uses the official Meta WhatsApp Business API for client communications and, in certain service contexts, for automated messaging on behalf of clients. By providing your WhatsApp number and communicating with us via WhatsApp, you consent to receiving messages via this channel.

You may opt out of WhatsApp communications at any time by replying STOP or contacting us at info@altosalpha.com.ng. We comply with Meta's WhatsApp Business Policy and do not send unsolicited bulk messages.

7. Data Sharing & Third Parties

We do not sell, rent, or trade your personal data. We may share data with trusted third parties only as necessary:

• Technology partners — Cloud infrastructure providers (e.g., Google Cloud, Microsoft Azure) under appropriate data processing agreements
• AI model providers — Where AI processing requires data submission (under strict data minimisation and processing agreements)
• Payment processors — For billing and payment facilitation
• Legal authorities — Where required by Nigerian law, court order, or regulatory authority
• Professional advisors — Lawyers, auditors, and accountants bound by confidentiality obligations

Any third party receiving personal data is bound by contractual data protection obligations consistent with NDPR requirements.

8. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy or as required by Nigerian law:

• Client and contractual records: 7 years (CAMA / FIRS requirements)
• Marketing contact data: Until opt-out or 3 years from last interaction
• Website analytics: 26 months
• Enquiry data (non-clients): 12 months

9. Your Rights Under NDPR

You have the following rights regarding your personal data:

• Right to be informed — You have the right to know how your data is used (this policy)
• 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 data (subject to legal retention obligations)
• Right to restrict processing — Request limitation on how we process your data
• Right to data portability — Receive your data in a structured, machine-readable format
• Right to object — Object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent — Where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact us at info@altosalpha.com.ng. We will respond within 30 days. You also have the right to lodge a complaint with NITDA at www.nitda.gov.ng.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• TLS/SSL encryption for all data in transit
• Encryption at rest for stored personal data
• Access controls and authentication requirements for staff
• Regular security assessments and monitoring
• Staff training on data protection obligations

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and NITDA within 72 hours of becoming aware.

11. International Transfers

Some of our cloud infrastructure providers are located outside Nigeria. When we transfer data internationally, we ensure appropriate safeguards are in place, including standard contractual clauses and adequacy assessments, consistent with NDPR requirements.

12. Children's Data

Our services are directed at businesses and individuals aged 18 and above. We do not knowingly collect personal data from children under 18. If you believe we have inadvertently collected such data, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or prominent notice on our website at least 14 days before taking effect. The date at the top of this page reflects the most recent update.

14. Contact Us

For any privacy-related questions, requests, or complaints:
Email: info@altosalpha.com.ng
Phone: 0904 523 6189
Website: altosalpha.com.ng