Privacy Notice
Transforming Women and Youth Impact Foundation (TWYIF)
Last updated: Last-updated date pending · Version 1.0
1. Who we are
Transforming Women and Youth Impact Foundation ("TWYIF", "we", "us") is a foundation incorporated in Nigeria under Part F of the Companies and Allied Matters Act as Incorporated Trustees, registration numberRC number pending, with its registered office atRegistered office address pending.
For the purposes of the Nigeria Data Protection Act 2023 ("the Act"), TWYIF is the Data Controller in respect of the personal data described in this notice.
You can reach us about anything in this notice atPrivacy email pending orPhone pending.
2. What this notice covers
This notice explains what personal data we collect through twyif.org, why we collect it, what we do with it, how long we keep it, and the rights available to you under the Act. It applies to visitors to our website and to people who contact us through it. It does not cover any third-party website we link to.
3. The personal data we collect
When you complete a form on our website. Depending on the form, this may include your name, email address, telephone number, organisation, role, country, and the content of your message or enquiry.
When you subscribe to updates. Your name and email address, and a record of your subscription and any later withdrawal.
Automatically, when you visit. Our hosting and security providers record technical data including your IP address, browser type and version, device type, operating system, referring page, the pages you view, and the date and time of your visit. This is generated by the ordinary operation of the internet and is used to keep the site available and secure.
Cookies and similar technologies. See section 10.
We do not ask for, and ask that you do not send us, sensitive personal data, including data revealing health, religious or political beliefs, ethnic origin, or biometric or genetic data, through our website forms.
4. Why we process your data, and on what lawful basis
| What we do | Why | Lawful basis under section 25 of the Act |
|---|---|---|
| Respond to enquiries submitted through our forms | So that we can answer you | Your consent, and our legitimate interest in responding to people who contact us |
| Assess and follow up partnership, funding and collaboration enquiries | To evaluate and progress a possible working relationship | Legitimate interest; steps taken at your request prior to entering a contract |
| Send updates, newsletters or invitations where you have asked to receive them | To keep you informed about our work | Your consent, which you may withdraw at any time |
| Keep the website available, secure and free from abuse | To protect the site and its users | Legitimate interest in the security and integrity of our systems |
| Understand in aggregate how the website is used | To improve the site | Legitimate interest; consent where required for non-essential cookies |
| Keep records required of us by law or by a regulator | To meet our obligations | Compliance with a legal obligation |
We do not sell personal data. We do not use your personal data for automated decision-making that produces legal or similarly significant effects.
5. Who we share your data with
We share personal data only with service providers who process it on our behalf and under contract, and only as far as they need it to provide their service to us. These currently are:
- Vercel: hosts the website and its server logs
- Cloudflare: DNS, CDN and security, routes and protects traffic to the site
- Resend: delivers messages submitted through our forms to our inbox
- Mailbox provider: Mailbox provider not yet decided, hosts the mailbox those messages arrive in
We do not currently use any analytics or tracking provider.
We may also disclose personal data where we are required to do so by law, by a court, or by a competent regulator, or where it is necessary to establish, exercise or defend legal claims.
6. Transfers outside Nigeria
Some of the providers listed above store or process data outside Nigeria, principally in the United States and the European Union. Where personal data is transferred out of Nigeria we rely on the transfer conditions in sections 41 to 43 of the Act, and we satisfy ourselves that the recipient is bound by contractual terms, including standard contractual clauses where applicable, that give your data a level of protection comparable to that required in Nigeria.
You may ask us for details of the safeguards applying to any particular transfer using the contact details in section 1.
7. How long we keep your data
We keep personal data only for as long as we need it for the purpose it was collected for.
- Enquiries that do not lead to a relationship: up to twelve months from your last contact with us, after which they are deleted
- Partnership and funding correspondence: for the duration of the relationship and for Retention period pending confirmationyears afterwards, so that we can meet our accounting, audit and legal obligations
- Newsletter subscriptions: until you unsubscribe, and for a short period afterwards so that we can honour your withdrawal
- Server and security logs: as set by our providers, ordinarily no more than Retention period pending confirmation
Where no statutory retention period applies, we end processing no later than six months after the purpose it was collected for has been completed, in line with the General Application and Implementation Directive 2025.
8. Your rights
Under the Act you have the right to:
- be informed about how we use your personal data, which is the purpose of this notice
- access the personal data we hold about you, in a machine-readable format
- have inaccurate or incomplete data corrected
- have your data erased where we no longer have a reason to keep it
- restrict our processing of your data while a concern is being resolved
- receive your data, or have it transferred, where we process it on the basis of your consent or a contract
- object to processing carried out on the basis of legitimate interest, and to object at any time to direct marketing
- withdraw your consent at any time, where consent is the basis we rely on: withdrawing it does not affect anything we did lawfully before you withdrew
To exercise any of these, write to us atPrivacy email pending. We will respond within one month. We may ask you to confirm your identity before we act, so that we do not disclose your data to someone else.
9. How to complain
If you are unhappy with how we have handled your personal data, please tell us first atPrivacy email pending and we will try to resolve it.
You also have the right to lodge a complaint directly with the Nigeria Data Protection Commission (NDPC), and to seek civil remedies including compensation. The Commission's contact details are published at ndpc.gov.ng.
10. Cookies
We use only the cookies the website needs in order to function and remain secure.
You can block or delete cookies through your browser settings, though parts of the site may not work as intended if you do.
11. How we protect your data
We use encrypted connections (HTTPS) across the whole site, restrict access to enquiry data to the people who need it, and choose providers who maintain recognised security standards. No system is completely secure, but we take reasonable and appropriate measures to protect personal data against loss, misuse and unauthorised access, and we will notify the Commission and affected individuals of a breach where the Act requires it.
12. Children
Our website is not directed at children, and we do not knowingly collect personal data from anyone under 18 through it. Where our programmes involve young people, personal data is collected offline under separate arrangements with the appropriate consent. If you believe a child has given us personal data through the website, contact us and we will delete it.
13. Changes to this notice
We may update this notice from time to time. The date at the top shows when it was last changed. Where a change materially affects how we use your personal data, we will bring it to your attention.
Prepared for TWYIF, Prepared-date pending. To be reviewed by counsel before publication.