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Privacy Policy

Effective 12 November 2026

This policy explains what personal information WINNOWHQ ("we", "us") collects, why we collect it, who we share it with and what rights you have. WINNOWHQ is operated by Ayomide Emmanuel Olabisi and will be operated through a registered company once incorporation is complete; this policy will then transfer to that company. We aim to follow the Nigeria Data Protection Act 2023 (NDPA), and, where you are in the United Kingdom or European Economic Area, the UK GDPR and EU GDPR.

1. Who is responsible for your data

The data controller is WINNOWHQ. Contact us for anything in this policy at ayomide@winnowhq.com.

2. What we collect

3. Why we use it, and our lawful basis

4. Who we share it with

We do not sell personal data. We share it only with service providers that help us run the business, under their own data protection terms: Cloudflare (website hosting, security and email routing), Resend (sending email), Google or Zoho (business email, documents, invoicing where you use them), Meta (WhatsApp, when you message us there) and payment providers where you pay us. We may also disclose information when the law requires it.

5. Transfers outside your country

Our providers operate globally, so your data may be processed outside Nigeria, the UK or the EEA. We use providers that apply recognised safeguards, such as standard contractual clauses, for these transfers.

6. How long we keep it

Enquiries that do not become a project: up to 12 months. Client records, contracts and invoices: as long as the work continues and then for the period tax and accounting law requires, normally six years. We delete or anonymise data when it is no longer needed.

7. Your rights

You may ask us to access, correct, delete or export your personal data, to restrict or object to how we use it, and to withdraw consent at any time. Email ayomide@winnowhq.com and we will respond within 30 days. If you are unhappy with our answer you may complain to the Nigeria Data Protection Commission, or to your local data protection authority if you live in the UK or EEA.

8. Security

We use encrypted connections (HTTPS), access controls and reputable providers. No system is perfectly secure. If a breach affecting your data occurs, we will notify you and the relevant authority as the law requires.

9. Client data we handle for you

When we build or run a system for a client, the client decides why and how their customers' data is used and we act as their processor. We process that data only on the client's instructions and we are happy to sign a data processing agreement on request.

10. Children

Our services are for businesses and are not directed at children. We do not knowingly collect data from anyone under 18.

11. Changes

We may update this policy. The effective date at the top shows the latest version, and material changes will be announced on this page.