Data Privacy Policy for 186ix Consult
Effective Date: April 1, 2025
Last Updated: March 2026
1. Introduction
186ix Consult (“we”, “our”, or “us”) is committed to protecting the privacy and personal data of our clients, partners, employees, and website users.
This Data Privacy Policy explains how we collect, process, store, protect, and share personal data in accordance with the requirements of the Nigeria Data Protection Act 2023 and the Nigeria General Application and Implementation Directive 2025 (GAID 2025) issued by the Nigeria Data Protection Commission (NDPC).
By using our website or services, you acknowledge that you have read and understood this policy.
2. Personal Data We Collect
We may collect personal data through our website, forms, email communications, consulting engagements, or other service interactions.
Types of personal data collected may include:
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Full name
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Email address
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Phone number
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Mailing or business address
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Organization or employer details
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Service engagement information
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Technical information such as IP address and browser data (where applicable)
We only collect personal data that is necessary, adequate, and relevant for the purposes stated in this policy.
3. Lawful Basis for Processing
Under the Nigeria Data Protection Act 2023, we process personal data based on the following lawful bases:
Consent
Where you have given explicit consent for specific processing activities.
Contractual Necessity
Where processing is necessary to perform a contract or service agreement.
Legal Obligation
Where processing is required to comply with regulatory or statutory obligations.
Legitimate Interest
Where processing is necessary for our legitimate business interests, provided your rights do not override those interests.
4. Purpose of Processing Personal Data
We process personal data for the following purposes:
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Deliver consulting and advisory services
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Manage client relationships and service delivery
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Respond to inquiries and customer support requests
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Send service-related communications
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Improve our website, products, and services
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Meet legal and regulatory compliance obligations
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Conduct internal analytics and business operations
5. Data Protection Principles
In accordance with GAID 2025, 186ix Consult processes personal data based on the following principles:
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Lawfulness, fairness, and transparency
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Purpose limitation
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Data minimization
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Accuracy
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Storage limitation
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Integrity and confidentiality
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Accountability
6. Data Security and Protection
We implement appropriate technical and organizational measures to safeguard personal data, including:
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Secure access controls
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Data encryption where appropriate
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Secure storage systems
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Staff confidentiality obligations
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Periodic data protection assessments
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Incident and breach management procedures
These measures are designed to prevent unauthorized access, alteration, disclosure, or destruction of personal data.
7. Data Retention
Personal data will only be retained for as long as necessary to:
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Fulfil the purpose for which it was collected
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Comply with legal or regulatory obligations
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Resolve disputes or enforce contractual agreements
Once personal data is no longer required, it will be securely deleted or anonymized.
8. Data Sharing and Third Parties
We may share personal data with:
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Service providers or partners supporting our operations
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Professional advisors or auditors
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Regulatory authorities where required by law
All third-party processors are required to comply with appropriate data protection and confidentiality obligations consistent with the Nigeria Data Protection Act 2023.
9. Cross-Border Data Transfers
Where personal data is transferred outside Nigeria, 186ix Consult will ensure:
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The recipient country provides adequate data protection, or
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Appropriate safeguards such as contractual data protection clauses are implemented
These transfers comply with NDPC requirements under GAID 2025.
10. Data Subject Rights
Under the Nigeria Data Protection Act 2023, you have the following rights:
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Right of Access – obtain confirmation and copies of your personal data
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Right to Rectification – correct inaccurate or incomplete data
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Right to Erasure – request deletion of personal data under certain conditions
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Right to Restrict Processing
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Right to Object to Processing
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Right to Data Portability
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Right to Withdraw Consent at any time where consent is the lawful basis
Requests relating to your rights may be submitted to our Data Protection Officer.
11. Data Breach Notification
In the event of a personal data breach that may pose a risk to data subjects, 186ix Consult will:
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Assess the impact of the breach immediately
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Notify the Nigeria Data Protection Commission within 72 hours of becoming aware of the breach
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Inform affected data subjects where there is a high risk to their rights and freedoms
12. Escalation and Complaint Procedure
186ix Consult maintains an internal complaint handling process for privacy-related concerns.
Step 1 — Internal Complaint
Data subjects should submit complaints to the Data Protection Officer using the contact details below.
Step 2 — Internal Investigation
The complaint will be reviewed and acknowledged within 5 business days, and a response will be provided within 30 days.
Step 3 — Escalation to Regulator
If the response is unsatisfactory, the complainant may escalate the matter to the Nigeria Data Protection Commission, the regulatory authority responsible for enforcing the Nigeria Data Protection Act 2023.
13. Data Protection Officer (DPO)
186ix Consult has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection laws and regulations.
DPO Contact Information
Data Protection Officer
186ix Consult
Email: dpo@186ixconsult.com
The DPO can be contacted regarding:
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Data subject rights requests
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Privacy complaints
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Data processing inquiries
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Data protection compliance matters
14. Changes to This Privacy Policy
186ix Consult reserves the right to update this policy from time to time to reflect:
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Regulatory changes
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Operational requirements
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Improvements in privacy practices
Updates will be published on our website with a revised effective date.
15. Contact Information
For general inquiries regarding this policy or our services, please contact:
186ix Consult
Email: info@186ixconsult.com
Address:
No. 9 Iweanya Ugbogoh Crescent,
Lekki Phase 1,
Lagos, Nigeria.
By using our website and services, you acknowledge that you have read and understood this Data Privacy Policy and agree to its terms and conditions.