1. Who We Are
DYEN provides skills training, mentorship, community programs, events, admissions support, and related youth empowerment services in Nigeria. For this policy, "DYEN", "we", "us", and "our" refer to the organisation operating this website and its programs.
Our campus is at Holy Trinity Close, Opposite Uti Junction (Ugbomro), behind NNPC Filling Station/Delta Procare Hospital, by Platinum Banquet Place, Effurun, Warri, Delta State.
2. Nigerian Privacy Law
We handle personal data in line with applicable Nigerian privacy law, including the Nigeria Data Protection Act, 2023, and guidance from the Nigeria Data Protection Commission. We aim to process personal data fairly, lawfully, transparently, for clear purposes, and only for as long as necessary.
3. Personal Data We Collect
- Identity details such as name, date of birth, gender, photograph, and government-issued identification where a program requires it.
- Contact details such as email address, phone number, residential address, state, city, and emergency contact.
- Application details such as education, employment status, program choice, guarantor details, interview records, attendance, assessment results, and admission status.
- Payment or transaction details where a paid program, acceptance item, merchandise, donation, sponsorship, or similar transaction applies.
- Website and device information such as IP address, browser type, pages visited, referral codes, cookies, and analytics events.
- Messages you send to us through forms, email, social media, calls, SMS, WhatsApp, or other support channels.
4. How We Collect Data
We collect data directly from you when you complete forms, apply for a program, attend an interview, make a payment, subscribe, contact us, or take part in a DYEN activity. We may also receive information from guarantors, parents or guardians, referees, partners, payment providers, website analytics tools, and referral links.
5. How We Use Personal Data
- Process applications, interviews, admissions, scholarships, program placements, internships, referrals, and alumni support.
- Contact applicants, students, guarantors, partners, donors, volunteers, sponsors, and event participants.
- Run classes, attendance, assessments, certificates, student support, program reporting, and internal administration.
- Verify eligibility, prevent fraud, protect our students, enforce program rules, and keep accurate records.
- Send relevant updates about DYEN programs, events, opportunities, deadlines, and community activities.
- Improve the website, forms, communications, and program experience.
- Meet legal, tax, accounting, regulatory, audit, safeguarding, and dispute-resolution obligations in Nigeria.
6. Lawful Bases For Processing
Depending on the activity, we rely on one or more recognised lawful bases under Nigerian data protection law:
- Consent, where you clearly agree to a specific use, such as receiving optional updates.
- Contract or steps before a contract, where we process information to review an application, provide a program, issue a certificate, or handle a transaction.
- Legal obligation, where Nigerian law requires us to keep or disclose certain records.
- Legitimate interest, where the processing is necessary for administration, security, fraud prevention, student support, program improvement, or communication, and does not override your rights.
- Vital interest or public interest, where needed for safety, emergency response, safeguarding, or lawful cooperation with authorities.
7. Cookies And Analytics
We use cookies, referral tracking, pixels, and analytics tools to understand website visits, measure campaigns, keep forms working, and improve our services. Some cookies are necessary for the website to work. Others help us understand performance and referrals.
You can control cookies through your browser settings. Blocking some cookies may affect referral tracking, forms, and website performance.
8. Sharing Personal Data
We do not sell personal data. We may share it with:
- Training facilitators, interviewers, mentors, volunteers, staff, and approved service providers who need the information to support DYEN activities.
- Technology, hosting, email, SMS, payment, analytics, database, and form providers that help us operate the website and programs.
- Partner organisations, sponsors, internship hosts, or donors, but only where the sharing is relevant to a program, placement, sponsorship, reporting obligation, or opportunity.
- Guarantors, parents, guardians, emergency contacts, or referees where this is necessary for application review, student support, safety, or verification.
- Government, regulators, law enforcement, courts, auditors, professional advisers, or other parties where disclosure is required by law or necessary to protect rights and safety.
Anyone who receives personal data from us must use it only for the agreed purpose and protect it with reasonable security measures.
9. International Transfers
Some website, hosting, email, analytics, payment, or communication providers may process data outside Nigeria. Where this happens, we take reasonable steps to use providers that apply appropriate data protection and security safeguards.
10. Data Retention
We keep personal data only for as long as needed for the purpose it was collected, including program administration, student records, legal compliance, accounting, reporting, safety, dispute handling, and audit requirements. If data is no longer needed, we delete it, anonymise it, or archive it securely.
11. Security
We use reasonable administrative, technical, and organisational measures to protect personal data from unauthorised access, loss, misuse, alteration, or disclosure. No website, email, or online system is completely secure, so please avoid sending unnecessary sensitive information through open channels.
12. Children And Young Applicants
Some DYEN programs may involve young people. Where an applicant is legally a minor or where a program requires it, we may ask for parent, guardian, guarantor, or emergency contact information. We use that information for eligibility, consent, safety, safeguarding, communication, and program administration.
13. Your Rights
Subject to Nigerian law and any valid reason for us to keep certain records, you may:
- Ask what personal data we hold about you.
- Request a copy of your personal data.
- Ask us to correct inaccurate or incomplete information.
- Withdraw consent where consent is the lawful basis for processing.
- Object to certain processing or ask us to restrict it.
- Ask us to delete personal data where there is no lawful reason for us to keep it.
- Ask for portability of information you gave to us, where this applies.
- Complain to the Nigeria Data Protection Commission if you believe your rights have been breached.
14. Marketing Messages
We may send updates about applications, programs, events, deadlines, student opportunities, alumni activities, partnerships, and fundraising. You can opt out of optional marketing messages. We may still send service messages about applications, admissions, classes, payments, safety, or important program notices.
15. Contact Us
To ask a privacy question, request access, correction, deletion, or withdrawal of consent, contact us at [email protected].
If you are not satisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission.
16. Changes To This Policy
We may update this policy when our services, laws, systems, or internal processes change. The latest version will be posted on this page with the updated date.