1. Who we are
EquaCore Digital Ltd ("EquaCore", "we", "us", "our") is a digital operations consulting firm incorporated in the Federal Republic of Nigeria, with global operations. This Privacy Policy explains how we collect, use, and protect personal information when you use equacoredigital.com, submit our enquiry or talent pool forms, or otherwise interact with us.
Because our operations are global and we engage with candidates, clients, and partners across multiple jurisdictions, we hold ourselves to the higher of the applicable standards. Specifically, we comply with:
- The Nigeria Data Protection Act 2023 (NDPA), enforced by the Nigeria Data Protection Commission (NDPC) — our primary regulatory framework
- The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 — for data subjects in the United Kingdom
- The EU General Data Protection Regulation (EU GDPR) — for data subjects in the European Economic Area
- Other applicable data-protection laws of the jurisdiction in which a data subject is resident, where stricter
2. Information we collect
2.1 When you submit our contact form
- Name, email address, organisation
- Platform of interest (optional)
- The content of your message
2.2 When you join our Talent Pool
- Full name, email, phone number
- Country / location
- LinkedIn profile URL
- Primary specialism, years of experience, availability, engagement preferences
- ServiceNow / HaloITSM certifications (optional)
- Cover note (optional)
- How you heard about us (optional)
- CV (PDF) and passport-style photograph submitted via email
2.3 When you visit our website
- Standard analytics data via Google Analytics 4: anonymised IP, page views, device type, referral source, session duration
- No advertising cookies, no cross-site tracking
3. How we use your information
| Purpose | Lawful basis (NDPA 2023 / GDPR equivalents) |
| Respond to your enquiry | Legitimate interests — responding to direct enquiries |
| Maintain our talent pool and match registrations to client opportunities | Consent (granted via the registration form) and legitimate interests |
| Share your candidate profile with a specific potential employer | Explicit consent obtained per opportunity, before any sharing |
| Maintain operational and accounting records | Legitimate interests — business administration; legal obligation where applicable |
| Improve the website and our services | Legitimate interests — analytics |
4. How long we keep your data
| Data type | Retention period |
| Contact form enquiries | 24 months from last contact |
| Talent pool registrations (bio, CV, photo) | 12 months from last contact |
| Website analytics (Google Analytics 4) | 14 months (Google default) |
| Records required by law (e.g. accounting) | As long as legally required |
You may request earlier deletion at any time by emailing Info@equacoredigital.com.
5. Who we share your data with
We share your information only with the parties below, and only to the extent necessary:
- Formspree — processes form submissions on our behalf. Based in the United States, GDPR-compliant via Standard Contractual Clauses (SCCs).
- Microsoft 365 — we use Microsoft’s email and document storage to receive and store enquiries, talent pool registrations, CVs, and photographs in our private organisational tenant.
- Google Analytics 4 — anonymised website analytics only. GDPR-compliant via Google’s Data Processing Addendum.
- Potential employers (talent pool only) — we share your candidate profile with a specific employer only after obtaining your explicit consent for that specific opportunity. We never share talent pool data to a general database.
We do not sell your data, ever. We do not use your data for advertising or profile-based targeting.
6. International transfers
EquaCore is incorporated in Nigeria and our operations are global. Some of our service providers (Formspree, Google, Microsoft) are based outside Nigeria, the United Kingdom, and the European Economic Area — principally in the United States and the European Union. Where data is transferred internationally, we rely on:
- For all data subjects: contractual safeguards (Standard Contractual Clauses) with each processor, in line with Sections 41–43 of the Nigeria Data Protection Act 2023
- For UK data subjects: the UK International Data Transfer Agreement or addendum to EU SCCs, as approved by the UK Information Commissioner’s Office (ICO)
- For EU/EEA data subjects: European Commission’s Standard Contractual Clauses (SCCs)
- Adequacy decisions issued by the NDPC, the UK ICO, or the European Commission, where applicable
We review these arrangements regularly to ensure your data continues to receive equivalent protection regardless of where it is processed.
7. Your rights
Under the Nigeria Data Protection Act 2023, and where applicable the UK GDPR and EU GDPR, you have the following rights regarding your personal data:
- Access — request a copy of the personal data we hold about you
- Rectification — correct inaccurate or incomplete data
- Erasure — request deletion of your data ("the right to be forgotten")
- Restriction — ask us to limit how we process your data
- Objection — object to processing based on legitimate interests
- Withdraw consent — at any time, where consent is the lawful basis (e.g. talent pool)
- Portability — receive your data in a structured, machine-readable format
- Lodge a complaint — with the Nigeria Data Protection Commission (ndpc.gov.ng); UK data subjects may complain to the Information Commissioner’s Office (ico.org.uk); EU/EEA data subjects may complain to their national supervisory authority
To exercise any of these rights, email Info@equacoredigital.com. We will respond within 30 days. There is no charge unless your request is manifestly unfounded or excessive.
8. Cookies
We use only essential cookies and Google Analytics. Specifically:
- Essential cookies — required for the website to function (none are set unless strictly necessary).
- Analytics cookies — Google Analytics 4 (
_ga, _ga_*) for anonymised usage statistics. IP anonymisation is enabled.
We do not use advertising cookies, social-media tracking, or cross-site profiling. You can disable cookies in your browser without affecting site functionality.
9. Security
We protect your data using:
- TLS / HTTPS encryption for all data in transit
- Microsoft 365 enterprise security for stored data (encryption at rest, access logging)
- Role-based access controls limiting which EquaCore personnel can view your data
- Regular review of our security and data-handling practices
No system is perfectly secure. If you become aware of a security incident affecting your data, please email Info@equacoredigital.com immediately. In the event of a personal data breach, we will notify the Nigeria Data Protection Commission (and, where applicable, the UK ICO or relevant EU supervisory authority) and affected individuals within 72 hours, as required by the Nigeria Data Protection Act 2023 and the UK/EU GDPR.
10. Children’s data
This website and our services are not directed to individuals under 16. We do not knowingly collect data from anyone under 16. If you believe we have, please contact us and we will delete it.
11. Changes to this policy
We may update this Privacy Policy as our practices evolve or as required by law. The "last updated" date at the top of the page reflects the most recent change. Material changes affecting how we use existing data will be communicated by email where we have your contact details.
12. Contact us
For privacy questions, data subject requests, or complaints:
If you are not satisfied with our response, you have the right to complain to your supervisory authority:
- Nigeria (primary): Nigeria Data Protection Commission — ndpc.gov.ng
- United Kingdom: Information Commissioner’s Office — ico.org.uk · phone 0303 123 1113
- European Union / EEA: your national data protection authority (find yours at edpb.europa.eu)