Privacy & Data Governance Policy
How D-Global Growthfield Limited collects, safeguards, encrypts, and processes personal and telemetry data across our LMS portals, broadcast platforms, campus nodes, and corporate service suites.
01. Governance & Regulatory Framework
D-Global Growthfield Limited (“DGG,” “Company,” “we,” “us,” or “our”) prioritizes the fundamental right to privacy for every learner, corporate client, intern, and community member.
This Privacy Policy delineates our protocols for collecting, processing, storing, and safeguarding your information in full compliance with the Nigeria Data Protection Act (NDPA 2023) and the Nigeria Data Protection Regulation (NDPR). This policy covers all digital touchpoints including learning.dglobalgrowthfield.com, live.dglobalgrowthfield.com, seo.dglobalgrowthfield.com, and our physical facilities in Lagos and Abeokuta.
02. Categories of Information Collected
Depending on how you engage with the DGG ecosystem, we process the following categories of data:
Direct Identity Data
Full legal names, email addresses, phone numbers, state of residence, portfolio GitHub URLs, and government ID numbers (where required for CAC or talent verification).
Academic & Technical Telemetry
LMS lesson progress, quiz scores, automated assessment logs, codebase submissions, attendance records, and tutor milestone grading.
Transaction & Billing Data
Payment timestamps, currency amounts, payment gateway reference tokens (Paystack/Flutterwave/Monnify), and invoicing billing addresses.
Broadcast & Community Data
Radio call-in phone logs, giveaway beneficiary mobile lines, campus radio chat handles, and Telegram/Discord community IDs.
03. Purpose & Legal Basis of Processing
We process your personal information exclusively under legitimate legal grounds recognized by data protection statutes:
- Contractual Execution: Provisioning LMS portal access, allocating cohort tutors, and administering the 4-month practical incubation curriculum.
- Legitimate Interests: Hardening software infrastructure against malicious brute-force attempts, optimizing low-bandwidth performance, and tracking learner completion benchmarks.
- Legal & Regulatory Compliance: Filing statutory Corporate Affairs Commission (CAC) incorporations, generating tax invoices, and satisfying accounting audits.
- Explicit Consent: Broadcasting promotional learner spotlights, distributing airtime/data rewards, and sharing portfolios with corporate hiring partners.
04. LMS Analytics, Assessments & Code Repositories
Our proprietary learning management system tracks student activity to guarantee program rigor and deliver actionable insights:
Evaluation Logs & Milestone Rubrics:
We store assessment records, capstone project repositories, and peer code reviews to generate cryptographically verifiable digital transcripts. These transcripts remain accessible via unique identifier queries on our public verification endpoints.
05. Employer Disclosure & Placement Matching
During the talent placement phase of our 4-month loop, DGG acts as a curated bridge connecting graduates to vetted tech executives, startups, and international freelance channels:
- We only transmit technical portfolios, project builds, and verified skill scores to hiring partners with prior student consent.
- We do not sell candidate contact lists to third-party marketing brokers.
- Hiring companies engaging via our 10% placement model are contractually mandated to use student records solely for recruitment evaluations.
06. Broadcast Media & Radio Giveaways
DGG broadcasts live interactive programs across regional radio channels (Top Radio 90.9 FM Lagos, Sweet FM 107.1 Abeokuta) and our digital campus streaming network:
Phone numbers submitted during on-air call-ins or SMS quiz entries are used strictly to disburse mobile internet data bundles, airtime credits, or LMS scholarship tokens. These contact details are not repurposed for unsolicited external campaigns.
07. Enterprise Clients & CAC Document Handling
For commercial clients contracting DGG for Corporate Affairs Commission (CAC) filings, TIN setups, or custom enterprise software development:
- Government identity numbers, director resolutions, and signature cards are transmitted solely via encrypted pipelines to statutory portals.
- Enterprise source code, API keys, and database credentials provided for system development remain strictly isolated within zero-knowledge workspaces.
08. Cryptographic Security & Data Storage
We maintain high-standard security architectures across our server infrastructure:
Encryption Standards
All data in transit is protected using TLS 1.3 encryption. Sensitive user authentication keys and passwords are encrypted at rest with industry-standard bcrypt hashing.
Role-Based Access Control
Database rows are partitioned logically with role-based access rules, ensuring tutors, students, and administrators only access permissible data slices.
09. Data Retention & Transcript Archives
Student academic performance logs and certificate hashes are retained permanently in cold storage to facilitate third-party credential verification by prospective employers throughout the learner's career. Marketing contact logs and unverified accounts are purged after 24 months of total inactivity.
10. User Rights Under Nigeria Data Protection Act
Under the NDPA 2023 and NDPR, you possess fundamental rights regarding your data:
- Right to Access: Request a full digital export of all personal data held in our systems.
- Right to Rectification: Update or correct inaccurate profile details or portfolio records.
- Right to Erasure (“Right to be Forgotten”): Request total account deletion, subject to statutory accounting and legal retention prerequisites.
- Right to Object: Opt out of marketing notifications and weekly ecosystem newsletters at any time.
12. Data Protection Officer (DPO) Contact
To exercise any of your statutory data rights, report a data concern, or request record modification, contact our dedicated compliance desk:
Data Protection & Privacy Desk
D-Global Growthfield Limited • Compliance Department