Draft · for review and adoption

Privacy Policy

Version 1.0 — draft for review and adoption · Effective from the date of adoption

The Epiphany ’06 Set, the alumni association of the Class of 2006 of Command Secondary School, Ibadan (“we”, “our”, “the Set”), respects your privacy. This policy explains what personal information we collect through our website and forms, why we collect it, and what you can do about it. It is written in line with the Nigeria Data Protection Act 2023.

1.Who we are

We are a volunteer-run alumni association. For the purposes of data protection law, the Set is the controller of the personal information described here. Our contact details are in section 9.

2.Information we collect

  • When you join the Set through our membership form: your name, phone number, email address, WhatsApp handle, graduation details and city of residence.
  • When you give through our Give Back form: your name — or nothing at all if you choose to give anonymously — and the amount of your gift. We do not collect card or bank details on the website; gifts are made by transfer to the Set’s account and we record only the promise and the confirmation.
  • When you register for a reunion or event: the details needed to organise it, such as your name, contact details and preferences.
  • When you appear in photographs or stories we publish: your image, name and the words you share, published only with your consent.
  • Basic technical data when you browse the site, such as your browser type and which pages you visit, to keep the site working.

3.How we use your information

We use your information to:

  • run the alumni network — keeping in touch, sharing Set news, and inviting you to meetings and events;
  • organise reunions and events you register for;
  • acknowledge and account for gifts to the Set and to the school;
  • publish stories and photographs of the Set’s life where you have agreed;
  • keep our website safe and working.

We do not sell your information, and we do not use it for advertising.

4.Our legal bases

We rely on: legitimate interests, to run an alumni association you have chosen to be part of; contract, to organise events you register for; consent, for photographs, stories and optional communications, which you may withdraw at any time; and legal obligation, where records must be kept for accounting purposes.

5.Sharing your information

We share personal information only with:

  • the service providers that run our website, forms and messaging, who process it only on our instructions;
  • banks and payment channels, strictly for reconciling gifts and event payments;
  • authorities, only where the law requires it.

We never sell or rent your information to anyone.

6.Cookies and analytics

Our website uses only the cookies and local storage it needs to function and, where analytics are enabled, to count page visits in aggregate. No advertising or tracking cookies are used.

7.How long we keep information

  • Membership details: while you remain a member, and removed on request; records of members we lose contact with are deleted or anonymised within 24 months.
  • Giving records: 7 years, for financial record-keeping.
  • Event registration data: deleted within 12 months after the event.
  • Photographs and stories: while consent stands; removed on request.

8.Your rights

You have the right to:

  • ask for a copy of the information we hold about you;
  • ask us to correct anything that is wrong;
  • ask us to delete your information where the law allows;
  • object to or restrict how we use your information;
  • withdraw consent at any time — for example, ask us to remove a photograph.

Write to us and we will respond within 30 days. There is no charge and you need not explain your reason.

9.How to reach us

For any question or request about your privacy, contact the Epiphany ’06 Set: email [to be added] · phone [to be added]. If you are not satisfied with our response, you may complain to the Nigeria Data Protection Commission.

10.Keeping in touch and changing this policy

If you no longer wish to receive Set communications, tell us and we will stop. We may update this policy from time to time; the current version is always on our website, and significant changes will be announced to members.

This draft is published for the Executive Council and members of the Epiphany ’06 Set to review. Adopted versions replace the draft wording and the contact details marked [to be added].