PRIVACY POLICY

1. Who We Are

Innovative Consolidated Solutions (ICS) is a Nigerian digital agency and technology platform registered in Nigeria, with offices in Abuja (FCT), Port Harcourt (Rivers State), and Warri (Delta State). We operate the website at innovativeconsolidatedsolutions.com and associated platforms.

Contact our Data Protection Officer: info@innovativeconsolidatedsolutions.com

2. Information We Collect

We collect the following categories of personal data:

• Account data: Full name, email address, phone number, company name, password (hashed), profile photo.
• Transaction data: Payment references, invoice amounts, escrow records, withdrawal requests, bank account details (for freelancer withdrawals).
• Usage data: Pages visited, browser type, IP address, device information, session duration, referral source.
• Communications: Messages sent via our platform, contact form submissions, support tickets.
• Marketplace data: Job postings, proposals submitted, contract details, reviews and ratings.
• Identity verification data: National Identification Number (NIN) or Bank Verification Number (BVN) when you opt into verification (freelancers only).
• Push notification tokens: Browser push subscription objects for notification delivery.

3. How We Use Your Information

We use your personal data for the following purposes:

• To provide, operate, and improve our services and platform.
• To process payments, manage escrow, and facilitate marketplace transactions.
• To send transactional emails (account registration, invoice receipts, project updates).
• To send marketing communications where you have given consent (opt-out available at any time).
• To verify freelancer identities and prevent fraud.
• To comply with legal obligations under Nigerian law.
• To contact you about your enquiries, projects, and support requests.
• To improve our AI assistant responses (anonymised interaction data only).

4. Legal Basis for Processing

Under the NDPR and Nigeria Data Protection Act 2023, we process your data based on:

• Contract performance: Processing necessary to provide services you have requested.
• Legitimate interests: Platform security, fraud prevention, service improvement.
• Consent: Marketing communications, push notifications. You can withdraw consent at any time.
• Legal obligation: Compliance with Nigerian financial regulations, tax obligations, and anti-fraud requirements.

5. How We Share Your Information

We do not sell your personal data. We share data only with:

• Service providers: Brevo (email delivery), Paystack (payment processing), ElevenLabs (AI voice), Twilio (telephony), Dojah (identity verification). Each is bound by data processing agreements.
• Marketplace counterparties: When you engage in a contract, your professional profile (name, rating, skills) is visible to the other party.
• Legal authorities: When required by Nigerian law, court order, or to prevent fraud or harm.

6. Data Retention

• Account data: Retained while your account is active and for 3 years after closure.
• Transaction records: Retained for 7 years to comply with Nigerian financial regulations.
• Contact form submissions: Retained for 2 years.
• Identity verification data: Retained for 5 years after your last transaction.
• Push notification tokens: Deleted immediately on unsubscribe.

7. Your Rights Under the NDPR

You have the following rights regarding your personal data:

• Access: Request a copy of the data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your data, subject to legal retention requirements.
• Portability: Request your data in a machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Withdraw consent: Withdraw consent for marketing at any time via the unsubscribe link in any email.

To exercise any right, email: info@innovativeconsolidatedsolutions.com. We will respond within 30 days.

8. AI and Voice Interactions

Our AI Concierge (text chat) and Voice Assistant use Claude AI (Anthropic) and ElevenLabs respectively. Conversation transcripts may be stored for up to 90 days to improve service quality. No personally identifiable information is used to train external AI models. AI phone calls made by our automated agent system are disclosed to the recipient at the start of the call.

9. Cookies and Tracking

We use:

• Essential cookies: Session management, authentication (cannot be disabled).
• Analytics: Google Analytics (anonymised IP) to understand site usage.
• Preferences: Theme (dark/light mode), language settings stored in localStorage.

You can disable non-essential cookies in your browser settings at any time.

10. Security

We implement appropriate technical and organisational measures to protect your data, including: TLS encryption in transit, bcrypt password hashing, JWT authentication, rate limiting, Content Security Policy headers, and regular security reviews. Escrow funds and payment processing are handled by Paystack, a PCI-DSS compliant payment processor.

11. International Transfers

Some service providers (Anthropic/Claude, ElevenLabs, Brevo) may process data outside Nigeria. Where this occurs, we ensure appropriate contractual safeguards are in place per NDPR requirements.

12. Children's Privacy

Our services are not directed at persons under 18 years of age. We do not knowingly collect data from minors. If you believe we have collected data from a minor, contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be notified via email to registered users 14 days before taking effect. Continued use of our platform after the effective date constitutes acceptance.

14. Contact Us

For privacy enquiries, data access requests, or complaints:

• Email: info@innovativeconsolidatedsolutions.com
• Address: Abuja, FCT, Nigeria
• Regulator: NITDA (National Information Technology Development Agency) — ndpr@nitda.gov.ng