1. Introduction
Emmtol Consult Limited ("Emmtol," "we," "us," or "our"), located at 7 Oluseun Crescent, Gbagada Phase 1, Lagos, Nigeria, respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our website (emmtol.org) and services, in compliance with the Nigeria Data Protection Act 2023 (NDPA) and other applicable data protection laws.
By using our website or services, you agree to the terms of this Privacy Policy.
2. Information We Collect
2.1 Information you provide directly
- Contact details (name, email address, phone number)
- Academic records, transcripts, and test scores (for study abroad services)
- Passport and identity document details (where required for admission or visa support)
- CV and professional history (for PR and second passport services, at launch)
- Business and procurement details (for supply chain clients)
- Payment information (processed securely through our payment partners)
- Any messages or enquiries you send us
- Waitlist registration details (name, email, phone)
2.2 Information collected automatically
- IP address, browser type, and device information
- Pages visited, time spent, and navigation patterns (via cookies and analytics tools)
- Referral source (how you arrived at our website)
2.3 Information from third parties
- Educational institutions and verification bodies (during admission processing)
- Professional referees (where required)
- Public business registries (for supply chain due diligence)
3. How We Use Your Information
- Assess eligibility and provide study abroad consulting services
- Prepare and submit university applications on your behalf
- Provide visa guidance and support
- Notify waitlist members when the PR and second passport service launches
- Process supply chain enquiries, quotations, and deliveries
- Process payments and send invoices
- Send service updates and marketing communications (you may opt out at any time)
- Improve our website and services through analytics
- Comply with legal and regulatory obligations
4. Legal Basis for Processing
Under the NDPA, we process your personal data on the following bases:
- Consent: Where you have given clear consent, for example to join the waitlist or receive marketing communications.
- Contract: Where processing is necessary to deliver a service you have requested.
- Legitimate interest: Where processing supports our business operations, provided your rights do not override our interests.
- Legal obligation: Where we must comply with Nigerian law or regulatory requirements.
5. How We Share Your Information
We do not sell your personal data. We may share it with:
- Universities and educational institutions: As required to process your applications, only with your authorization.
- Embassy and visa support partners: Only where required for your application, with your knowledge.
- Suppliers and logistics partners: Business contact and delivery details needed to fulfill supply orders.
- Service providers: Payment processors, hosting providers, email platforms, and analytics tools, under data processing agreements.
- Authorities: Where disclosure is required by law, court order, or regulatory obligation.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including access controls, secure storage, and staff confidentiality obligations. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.
7. Data Retention
- Enquiry and contact data: up to 2 years after last interaction
- Application files (successful or unsuccessful): up to 5 years, for reference and future applications with your consent
- Waitlist data: until the service launches plus 12 months, or until you unsubscribe
- Supplier and procurement records: as required by Nigerian tax and company law
When data is no longer needed, we securely delete or anonymize it.
8. Your Rights
Under the NDPA, you have the right to access, correct, delete, or restrict processing of your personal data; to withdraw consent; to data portability; and to lodge a complaint with the Nigeria Data Protection Commission (NDPC).
To exercise these rights, contact us at privacy@emmtol.org. We will respond within 30 days.
9. Cookies
Our website uses essential cookies required for basic operation. We do not use non-essential analytics or marketing cookies unless you consent. See our Cookie Policy for details.
10. International Data Transfers
Some processing (such as university applications or international sourcing) involves transferring data outside Nigeria. Where this occurs, we ensure appropriate safeguards consistent with the NDPA.
11. Children's Privacy
Our services are not directed at persons under 18. Where a prospective student is a minor, applications must be made by or with the consent of a parent or legal guardian.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date reflects the most recent revision. Material changes will be communicated via our website or email.
13. Contact Us
Emmtol Consult Limited
7 Oluseun Crescent, Gbagada Phase 1, Lagos, Nigeria
Email: privacy@emmtol.org