Privacy Policy

1. Introduction

The Farmers & Traders Welfare Association of Rivers State, Nigeria (“FTWA,” “we,” “us,” or “our”) is a non-governmental organisation registered with the Corporate Affairs Commission of Nigeria under RC/CAC/IT/No. 77029, dedicated to the welfare, empowerment, and development of farmers, traders, women, youths, and students in Rivers State and the wider South-South and South-East regions of Nigeria.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (the “Site”), register for membership, make a donation, or otherwise interact with us. It applies to all visitors, members, donors, and users of the Site.

By using the Site, you agree to the collection and use of information in accordance with this Policy. If you do not agree with our practices, please do not use the Site.

2. Information We Collect

2.1 Information You Provide Directly

Contact Form. When you submit a message through our Contact Us page, we collect your full name, email address, subject, and message content. This information is stored securely in our database (Google Firebase / Cloud Firestore) and used solely to respond to your enquiry.

Membership Registration. When you register as a member, we may collect your full name, email address, phone number, category of membership, and supporting documents (e.g., valid means of identification, passport photograph) as described in our Membership Registration Policy. Where registration involves an online payment, your payment is processed by our third-party payment processor, Paystack; FTWA does not directly collect or store your card, bank account, or other sensitive payment credentials — these are handled exclusively by Paystack in accordance with its own privacy and security practices.

Donations. The Site displays our official bank account details (Zenith Bank PLC) to facilitate direct bank transfers. FTWA does not collect personal or financial information from donors who choose to transfer funds directly through their own bank; such transactions are governed by the donor’s bank and Zenith Bank PLC’s own privacy practices.

Communications. If you contact us directly by phone, WhatsApp, or email (including the Legal Department), we may retain a record of that correspondence and any information you choose to share with us.

2.2 Information Collected Automatically

When you visit the Site, certain information may be collected automatically, including:

• Device and browser information (e.g., browser type, operating system, device type);
• Log data such as IP address, access times, pages viewed, and referring URLs;
• Usage analytics, where enabled, through Google Firebase Analytics, to help us understand how visitors use the Site and improve our services.

We do not currently use advertising or third-party marketing cookies. If this changes, this Policy will be updated accordingly.

2.3 Information from Third-Party Services

Where applicable, we may receive limited information from third-party services we use to operate the Site (see Section 5), such as payment confirmation details from Paystack or hosting/delivery metadata from our cloud service providers.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to enquiries submitted through the Contact Us form;
• To process and manage membership registrations, including verification and issuance of membership ID cards;
• To process online payments for membership registration and, where applicable, donations, via Paystack;
• To communicate with members, donors, partners, and the public regarding FTWA programmes, events, and initiatives;
• To maintain accurate records of our membership database as described in our Membership Registration Policy;
• To monitor, analyse, and improve the performance, security, and content of the Site;
• To comply with applicable legal, regulatory, and reporting obligations, including those of the Corporate Affairs Commission and relevant government agencies.

4. Legal Basis for Processing

We process personal data in reliance on one or more of the following legal bases, consistent with the Nigeria Data Protection Act 2023 (NDPA):

• Consent — where you voluntarily submit information through our forms or registration process;
• Performance of a contract — where processing is necessary to provide membership services you have requested;
• Legitimate interest — where processing helps us operate, secure, and improve the Site and our programmes, provided this does not override your fundamental rights; and
• Legal obligation — where processing is required to comply with applicable Nigerian law.

5. How We Share Your Information

FTWA does not sell, rent, or trade your personal information to third parties. We may share information with the following categories of recipients, strictly as necessary to operate the Site and deliver our services:

• Google Firebase / Google Cloud Platform — for secure storage of contact form submissions and (where applicable) membership records, and for website analytics;
• Paystack — for processing online membership registration payments and, where applicable, donations;
• Cloudinary — for hosting and delivering images displayed in our Photo Gallery;
• Professional advisers — including our Legal Department, auditors, or regulators, where necessary for governance, compliance, or dispute resolution;
• Government authorities — where required by law, regulation, court order, or to protect the rights, property, or safety of FTWA, our members, or the public.

Each of these third parties processes information under its own privacy policy and terms, and we encourage you to review them where relevant.

6. Third-Party Services and Embedded Content

The Site incorporates the following third-party services and embedded content, which may independently collect information or set cookies in accordance with their own privacy policies:

• YouTube — embedded video content on our homepage;
• Google Maps — an embedded map of our office location on the Contact Us page;
• Cloudinary — image hosting for our Photo Gallery;
• Paystack — online payment processing for membership registration;
• Google Firebase — database storage and, where enabled, website analytics.

We encourage you to review the privacy policies of these providers to understand how they collect and process information.

7. Cookies and Tracking Technologies

The Site may use cookies and similar tracking technologies (including those set by embedded third-party content such as YouTube and Google Maps, and by analytics tools such as Firebase Analytics) to operate correctly, remember preferences, and understand how visitors use the Site. You can control or disable cookies through your browser settings; however, doing so may affect the functionality of certain features of the Site.

8. Data Storage, Security, and Retention

Information submitted through our Contact Us form is stored in Google Cloud Firestore, protected by access-control rules that permit only the creation of new messages from the Site and restrict reading, updating, or deleting that information to authorised FTWA administrators.

We implement reasonable technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, or destruction. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

We retain personal information only for as long as necessary to fulfil the purposes described in this Policy, including any legal, accounting, or reporting requirements, after which it will be securely deleted or anonymised.

9. Children’s Privacy

Certain FTWA programmes, such as the FTWA School Project and Talent Hunt initiatives, involve engagement with school-age children through their schools, patron teachers, and guardians. Where FTWA collects information relating to a child (for example, as part of the Student Member category under our Membership Registration Policy), such information is collected with the involvement and consent of a parent, guardian, or school administrator, and is subject to our Child Safeguarding commitments under FTWA’s Governance & Ethics Policy. The Site itself is not directed at children under the age of 13 for independent, unsupervised use, and we do not knowingly collect personal information directly from unaccompanied children through the Site.

10. Your Rights

Subject to applicable law, including the Nigeria Data Protection Act 2023, you have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion of your personal information, subject to our legal and legitimate retention needs;
• Object to, or request that we restrict, certain processing of your information;
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal;
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Legal Department using the details in Section 13 below.

11. International Data Transfers

Some of our service providers (including Google Firebase/Google Cloud and Paystack) may process or store information on servers located outside Nigeria. Where this occurs, we take reasonable steps to ensure such providers maintain adequate data protection safeguards consistent with the Nigeria Data Protection Act 2023.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The updated version will be indicated by a revised “Last updated” date at the top of this page. We encourage you to review this Policy periodically.