Privacy Policy

This Privacy Policy describes how PELPortal (operated by Patrick Enwerem Limited, RC No. 9180331, Bodija, Ibadan, Oyo State, Nigeria; "PEL", "we", "us") collects, uses, and safeguards information in connection with our websites, the PELPortal application, and our professional services (the "Services"). We are the data controller for personal data processed under this Policy.

1. Information We Collect

• Account and contact data you provide when submitting a brief, booking a session, or signing into PELPortal (name, work email, company, phone number).
• Engagement and SOW data shared during a Statement of Work: project documents, system context, and API credentials you authorize us to use on your behalf.
• Usage and telemetry generated when you interact with the Services: timestamps, IP address, browser type, and route paths visited.
• Professional network data from LinkedIn and similar platforms, only when a client authorizes a connection through our designated processor as part of a SalesLever or PELPortal engagement.

2. Lawful Bases and How We Use Information

We process personal data on the following lawful bases under the Nigeria Data Protection Act 2023 (NDPA):

• Contract: to deliver the Services and fulfil our obligations under an SOW.
• Legitimate interests: for B2B operations, fraud prevention, and security monitoring, where these interests are not overridden by your rights.
• Consent: where we send marketing email. You may withdraw consent at any time.
• Legal obligation: to meet tax, regulatory, or record-keeping requirements imposed by Nigerian and applicable law.

We do not sell personal data.

3. Security

We apply industry-standard administrative, technical, and physical safeguards. Data in transit is protected with TLS. Customer data at rest is encrypted using AES-256 at our cloud database provider, with role-based access control and row-level security applied throughout.

For security and fraud prevention, we log sign-in events including approximate IP-based location and device type. We retain these logs for up to 90 days, then anonymize them.

4. Subprocessors

We engage a limited set of vetted subprocessors for hosting, database services, email delivery, payments (Paystack), booking (Zoho), and communications processors that individual clients authorize as part of their engagement. A current list is available on request to info@penwerem.com.

5. Data Retention

We retain personal data for as long as needed to provide the Services and comply with legal obligations. Engagement data is deleted or returned per the applicable SOW upon termination. Sign-in and security logs are kept for up to 90 days and then anonymized.

6. Your Rights

Under the Nigeria Data Protection Act 2023 and comparable laws, you have the right to: access your personal data, correction of inaccurate data, deletion (erasure), portability, restriction of processing, objection to processing based on legitimate interests, and withdrawal of consent at any time where processing is based on consent.

To exercise any of these rights, email info@penwerem.com. We respond within the timeline required by the NDPA. We may need to verify your identity before acting on a request.

7. International Transfers

The Services are hosted in the cloud. Personal data may be transferred to and stored in infrastructure outside Nigeria. Where such transfers occur, we rely on lawful transfer mechanisms and apply appropriate safeguards consistent with the NDPA 2023 to protect your data.

8. Cookies

We use a small number of strictly necessary browser storage items to run this site and keep you signed in. Your session is stored in your browser using local storage managed by our authentication provider (Supabase Auth) rather than in cookies. We do not use analytics, advertising, or tracking cookies. A short banner records your acknowledgement; you can clear this storage at any time through your browser settings.

9. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted on this page with an updated effective date. Continued use of the Services after the effective date constitutes acceptance of the revised Policy.

10. Contact

Patrick Enwerem Limited, operating as PELPortal. RC No. 9180331. Bodija, Ibadan, Oyo State, Nigeria. Email info@penwerem.com.

For NDPA-specific enquiries, including data subject rights requests and DPO correspondence, use the same email address. See also our Nigeria Data Protection Act notice.