Effective Date: 1st June 2026
Privacy Policy
Pufferfish Technology Ltd ("Pufferfish", "we", "our", or "us") is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, process, and protect personal data when you visit our website, engage our services, communicate with us, or otherwise interact with us.
This Privacy Policy has been developed in accordance with:
- Nigeria Data Protection Act (NDPA)
- General Data Protection Regulation (GDPR)
- UK GDPR
- Applicable international privacy laws and regulations
2. Information We Collect
Personal Information
- Full name
- Email address
- Phone number
- Company name
- Job title
- Business address
- Country and location information
Technical Information
- IP address
- Browser type
- Device information
- Operating system
- Website usage information
- Cookies and tracking data
Business Information
- Project requirements
- Service inquiries
- Contractual information
- Client communications
- Service delivery records
Recruitment Information
When applying for employment opportunities, we may collect:
- CVs and resumes
- Educational records
- Employment history
- Professional certifications
- References
3. How We Use Your Information
We process personal data for legitimate business purposes including:
- Providing requested services
- Responding to inquiries
- Managing client relationships
- Delivering cybersecurity, consulting, cloud, software development, and technology services
- Sending service updates
- Improving website functionality
- Conducting analytics
- Recruiting and hiring personnel
- Meeting legal and regulatory obligations
- Preventing fraud and unauthorized activities
4. Legal Basis for Processing
Where GDPR applies, we process personal data based on:
- Consent
- Performance of a contract
- Compliance with legal obligations
- Legitimate business interests
- Protection of vital interests
- Public interest requirements where applicable
5. Cookies and Tracking Technologies
Our website may use cookies and similar technologies to:
- Improve user experience
- Analyze website traffic
- Maintain security
- Remember user preferences
- Measure website performance
Users may control cookie preferences through their browser settings.
6. Information Sharing
We do not sell personal information.
We may share information with:
- Authorized employees
- Technology vendors
- Cloud service providers
- Cybersecurity partners
- Professional advisors
- Government or regulatory authorities where legally required
All third parties are required to maintain appropriate confidentiality and security measures.
7. International Data Transfers
As a technology services provider operating internationally, personal data may be processed in jurisdictions outside your country of residence.
Where such transfers occur, we implement appropriate safeguards including:
- Standard Contractual Clauses (SCCs)
- Contractual confidentiality obligations
- Security controls
- Data protection agreements
8. Data Security
We implement reasonable technical and organizational measures to protect information against:
- Unauthorized access
- Alteration
- Disclosure
- Loss
- Destruction
- Cybersecurity threats
These measures include access controls, encryption, monitoring, security policies, and cybersecurity best practices.
9. Data Retention
We retain personal information only for as long as necessary to:
- Fulfill contractual obligations
- Comply with legal requirements
- Resolve disputes
- Enforce agreements
- Maintain legitimate business records
Retention periods may vary depending on the nature of the information.
10. Your Privacy Rights
Subject to applicable laws, you may have the right to:
- Access your personal information
- Correct inaccurate information
- Request deletion
- Restrict processing
- Object to processing
- Withdraw consent
- Request data portability
- Lodge a complaint with a supervisory authority
Requests may be submitted to info@pufferfish.com.ng.
11. Children's Privacy
Our services are intended for businesses and professionals and are not directed toward children under the age of 18.
We do not knowingly collect personal information from children.
12. Third-Party Websites
Our website may contain links to external websites.
We are not responsible for the privacy practices or content of third-party websites.
13. Changes to this Privacy Policy
We may update this Privacy Policy periodically.
Changes become effective upon publication on our website.