Privacy Policy

Last Updated: April 1, 2026

1. Introduction

The Chain of Good ("TCOG", "we", "us", or "our") is a non-profit organisation founded by visionary young Africans committed to empowering youth and building a more conscious, responsible and inclusive society.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share and safeguard your information when you engage with us through our website, digital platforms, mentorship programmes, curriculum initiatives, events or partnerships.

This Policy complies with the Nigeria Data Protection Act (NDPA) 2023 and reflects internationally accepted data protection principles, including elements of the GDPR where applicable.

By interacting with TCOG, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

3. Information We Collect

We collect only the personal data necessary to deliver our mission effectively.

3.1 Personal and Contact Data

  • Full name
  • Email address
  • Phone number
  • Date of birth (where relevant)
  • Gender
  • Country or location

3.2 Programme and Engagement Data

  • Educational background
  • Career interests and aspirations
  • Mentorship preferences and progress
  • Participation in programmes, events or workshops
  • Feedback and survey responses

3.3 Digital Platform Data

  • IP address and device information
  • Browser type and usage data
  • Login details (where accounts exist)
  • User-generated content (posts, comments, submissions)

3.4 Communication Data

  • Emails, messages, or inquiries sent to us
  • Records of mentorship or coaching interactions

3.5 Financial Data (Where Applicable)

  • Donation records and transaction references

(Note: Payments are processed securely via third-party providers; we do not store full financial details.)

3.6 Sensitive Data

In limited cases (e.g., youth welfare or program assessments), we may collect sensitive data. We will only do so with explicit consent and apply enhanced safeguards.

4. How We Collect Data

We collect data through:

  • Programme registration forms
  • Website and digital platform interactions
  • Direct communication (email, phone, social media, in-person)
  • Surveys, applications and feedback forms
  • Partnerships (e.g., schools, organisations)
  • Cookies and analytics tools

5. How We Use Your Information

We use personal data to:

  • Deliver mentorship, coaching, and youth development programmes
  • Facilitate participation in events and initiatives
  • Communicate updates, opportunities, and relevant information
  • Develop and improve digital tools and engagement platforms
  • Build and manage strategic partnerships
  • Process donations and maintain records
  • Conduct research and measure impact
  • Ensure the safety and wellbeing of participants
  • Comply with legal and regulatory obligations

We do not sell or use your data for commercial advertising.

6. Legal Basis for Processing

We rely on the following lawful bases:

  • Consent – for communications, programme participation, and optional data
  • Legitimate interests – for improving services and outreach
  • Contractual necessity – where participation creates obligations
  • Legal obligations – where required by law
  • Explicit consent – for sensitive data and children's data

You may withdraw your consent at any time.

7. Sharing Your Information

We do not sell or rent personal data.

We may share data with:

7.1 Service Providers

Trusted third-party providers (e.g., hosting, communication, analytics) are bound by data processing agreements (DPAs) and confidentiality obligations.

7.2 Programme Partners

Schools, NGOs, or institutions collaborating with us—only where necessary and with appropriate safeguards.

7.3 Legal Authorities

Where required by law, regulation, or court order.

7.4 Protection of Rights

Where necessary to protect the safety, rights, or integrity of TCOG, participants, or the public.

8. International Data Transfers

As a pan-African organisation with global engagement, your data may be processed outside your country of residence.

Where this occurs, we ensure appropriate safeguards in line with the Nigeria Data Protection Act and applicable international standards.

9. Data Retention

We retain personal data only for as long as necessary:

  • Programme records: up to 5 years after last engagement
  • Financial records: up to 7 years (legal compliance)
  • Communication records: up to 3 years
  • Platform usage up to 12 months

Retention periods are based on legal requirements, operational needs, and best practices. Data is securely deleted or anonymised after this period.

10. Data Security

We implement appropriate technical and organisational measures, including:

  • Secure data storage systems
  • Access controls and authentication
  • Encryption where applicable
  • Staff training on data protection

While we take reasonable steps, no system is completely secure.

11. Children's Privacy

TCOG engages with young people, including individuals under 18.

Where we collect children's data:

  • We obtain verifiable parental or guardian consent (e.g., signed forms or validated digital consent mechanisms);
  • We limit data collection to what is strictly necessary;
  • We apply enhanced security and confidentiality safeguards;
  • We do not subject children's data to profiling or automated decision-making.

Parents or guardians may:

  • Request access to a child's data
  • Request correction or deletion
  • Withdraw consent at any time

Requests may be made via: support@tcogfoundation.org

12. Your Rights

Under applicable data protection laws, you have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Request deletion of your data
  • Withdraw consent
  • Object to certain processing
  • Lodge a complaint with the Nigeria Data Protection Commission

Requests should be sent to: support@tcogfoundation.org

We will respond within applicable legal timelines.

13. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Enable essential website functionality
  • Analyse usage and improve performance
  • Support user experience and engagement

Types of cookies we may use:

  • Essential cookies (required for functionality)
  • Analytics cookies (to understand usage patterns)

Where required, we obtain consent before deploying non-essential cookies. Users may manage cookie preferences through browser settings.

14. Third-Party Links

Our platforms may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their policies.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify users via our website or direct communication.

The "Last Updated" date reflects the most recent revision.

16. Contact and Complaints

For questions, requests, or complaints:

The Chain of Good (TCOG)

You may also lodge complaints with the Nigeria Data Protection Commission.

(TCOG will designate a Data Protection Officer where required by law or operational scale.)

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