ADM CREATIVE MEDIA’s PRIVACY POLICY
Effective Date: 1st April, 2023
Who we are: ADM Creative Media Ltd. (“ADM”, “we”, “our”, “us”) 11, Dunkofia Street, Garki, Abuja Nigeria.
Contact: privacy@admcreativemedia.com • +234 909 711 7066
Supervisory authority: Nigeria Data Protection Commission (NDPC) — ndpc.gov.ng
Quick summary
- We comply with the Nigeria Data Protection Act, 2023 (NDPA) and NDPC guidance.
- We collect only what we need to provide our services (PR, communications, media production, consulting).
- Our lawful bases include contract, consent, legal obligation, vital interests, public interest, and legitimate interests (we do an LIA where needed).
- Your rights: access, rectify, erase, restrict, object, portability, no solely automated decisions, complain to the NDPC.
- We may transfer data outside Nigeria only with adequacy or appropriate safeguards (e.g., SCCs/BCRs).
- Children: our services aren’t directed to persons under 18; if processing is needed, we use parent/guardian consent and age-verification.
- For client work, ADM may act as data controller or data processor; processor activities are governed by contract.
1) What we collect
We collect the minimum personal data needed to operate:
- Identity & contact: name, email, phone/WhatsApp, job title, organization, address.
- Business context: project briefs, statements of work, approvals, interview schedules, appearance releases.
- Payment & compliance: invoicing details, TIN, bank info you provide (we don’t store card numbers).
- Usage & device: IP address, device/browser, pages viewed, timestamps, cookies/analytics.
- Media assets (if relevant): photos, video, audio recorded with informed consent and releases.
- Recruitment: CV, portfolio, references; for employees/contractors, only what HR/payroll legally requires.
Sources: you (forms, email, meetings), your organization, public sources (official sites, social profiles used for business), and service providers (analytics, hosting, email, payments).
2) Why we use your data (purposes & lawful bases)
We match each purpose to at least one lawful basis under NDPA:
- Provide services (strategy, PR, production, consulting), manage accounts, deliverables, support.
Basis: Contract; Legitimate interests. - Communications (project updates, service messages, scheduling).
Basis: Contract; Legitimate interests. - Marketing (newsletters, case studies, event invites) where you opt in or where permitted for B2B.
Basis: Consent; Legitimate interests (you can opt out anytime). - Recruitment & talent management.
Basis: Contract (pre-contractual steps); Legitimate interests; Legal obligation. - Security & fraud prevention (access logs, incident investigation).
Basis: Legitimate interests; Legal obligation; Vital interests. - Legal & compliance (tax/audit, regulatory requests).
Basis: Legal obligation; Public interest.
Where we rely on legitimate interests, we balance them against your rights using a Legitimate Interest Assessment. You can object at any time.
3) Cookies & analytics
We use essential cookies for site functionality and optional analytics (e.g., Google Analytics) to understand usage and improve content.
- On first visit, you’ll see a cookie banner to accept or manage preferences.
- You can change preferences or disable cookies in your browser at any time.
- Analytics data is aggregated; we don’t build individual behavioral profiles.
4) When we share data
We share personal data only with:
- Vetted processors who help us run the business (hosting, email, CRM, analytics, payment, transcription/subtitles, storage/MAM).
- Project partners (e.g., broadcasters, event organizers, printers) when necessary to deliver your agreed scope.
- Legal/regulators when required by law or to protect rights and safety.
All processors are bound by data protection agreements and may only act on our instructions.
5) International transfers
We may transfer data outside Nigeria (e.g., to cloud providers). We do so only where one of the following applies:
- The destination is deemed adequate by the NDPC; or
- We use appropriate safeguards (e.g., Standard Contractual Clauses, Binding Corporate Rules, approved codes/certifications); or
- Another ground permitted by NDPA (e.g., your explicit consent, performance of a contract, public interest, or vital interests).
You can request copies or a description of relevant safeguards at privacy@admcreativemedia.com.
6) Children’s data
Our services are not directed to persons under 18. If we must process a child’s data (e.g., filmed participation at an event), we will use verifiable parent/guardian consent, apply age-appropriate explanations, and minimize data collection.
7) How long we keep data
We keep personal data only as long as necessary for the purpose collected, then delete or anonymize it. Typical periods:
- Client files & contracts: 6–7 years (tax/audit limitation periods).
- Media releases & production files: for the life of the project and as required by rights/contract.
- Marketing contacts: until you unsubscribe or after 24 months of inactivity.
- Recruitment: 12 months after role closure (unless you consent to talent pool).
- Website analytics: 14–26 months (aggregate, non-identifying).
If you ask us to delete your data, we’ll do so unless a legal obligation requires retention.
8) Security & data breaches
We use administrative, technical, and physical safeguards: access controls, encryption in transit, least-privilege access, logging, regular updates, and vetted vendors.
If a breach is likely to risk your rights and freedoms, we will notify the NDPC within 72 hours and inform affected individuals when required by NDPA.
9) Your rights (Nigeria)
Under the NDPA, you have the right to:
- Be informed about how your data is used.
- Access your data and get a copy.
- Rectify inaccurate or incomplete data.
- Erase data (“right to be forgotten”) where applicable.
- Restrict or object to processing, including direct marketing.
- Portability (receive your data in a machine-readable format).
- Not be subject solely to automated decisions that have legal or similarly significant effects.
- Withdraw consent at any time (this won’t affect past lawful processing).
To exercise any right, email privacy@admcreativemedia.com with enough detail to identify you and your request. We’ll respond within NDPC timelines.
If unresolved, you may complain to the NDPC (ndpc.gov.ng).
10) Controller vs. processor roles
- When ADM determines the purpose and means of processing (e.g., our website, marketing, recruitment), ADM is the data controller.
- When we process personal data on behalf of a client (e.g., handling interview footage, event registrations, PR lists), we act as a data processor and follow the client’s lawful instructions and data processing agreement.
11) Third-party links
Our site may link to partners or social platforms. Their privacy practices are their own—please review their policies before sharing personal data.
12) Changes to this notice
We’ll update this policy when needed. Material changes will be highlighted on this page with a new effective date. Continued use of our services after changes means you accept the updated terms.
13) Contact & DPO
Data controller: ADM Creative Media Ltd., 11, Dunkofia Street, Garki, Abuja..
General privacy contact: privacy@admcreativemedia.com • +234 909 711 7066.
For EEA/UK Visitor
Where applicable, we rely on GDPR lawful bases comparable to those listed above and use SCCs/UK Addendum for transfers. You may contact your local supervisory authority.
California residents: We do not sell personal information. If you’re a California resident and interact with ADM, you can request access/deletion in line with the CCPA. (Only include this section if you truly target CA.)
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Kindly contact us if you have any questions via the following channels:
– Email: hi@admcreativemedia.com
– Phone Number: 09097117066
