Privacy Policy

1. Introduction

At IMMERSE Coaching Company (“IMMERSE” or “the Firm”), we are committed to safeguarding your privacy and ensuring the confidentiality and security of your personal information.

This Privacy Policy outlines how we collect, use, protect, retain, and share your personal data in line with applicable data protection laws, including the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) 2019.

By using our website https://immersecoaching.co or engaging with us through any of our services, platforms, events, or communication channels, you consent to the data practices described in this Policy.

2. Our Guiding Principles for Data Processing

In accordance with Section 24 of the Nigeria Data Protection Act (NDPA), IMMERSE is committed to upholding the highest standards in how we collect, use, and manage personal data. We ensure that all data processing activities are guided by the following core principles:

• Lawfulness, Fairness, and Transparency
  Personal data is processed lawfully, fairly, and in a transparent manner to ensure trust and accountability.
  
• Purpose Limitation
  Data is collected for specific, explicit, and legitimate purposes and is not further processed in a manner that is incompatible with those purposes.
  
• Data Minimization
  Only data that is adequate, relevant, and limited to what is necessary for the intended purpose is collected and processed.
  
• Accuracy
  Reasonable steps are taken to ensure that personal data is accurate and kept up to date. Inaccurate data is rectified or deleted without delay.
  
• Storage Limitation
  Personal data is retained only for as long as necessary to fulfill its intended purpose, in line with applicable legal and operational requirements.
  
• Data Subject Rights
  All processing activities are conducted in a manner that respects the rights of data subjects under the NDPA.
  
• Integrity and Confidentiality
  Appropriate technical and organizational measures are in place to safeguard personal data against unauthorized access, loss, misuse, damage, or destruction.

3. Use of Personal Data

The collection and processing of personal data are essential to delivering our coaching services and enabling smooth, personalized interactions across our programs, platforms, and events.

Depending on the specific purpose and context of processing, IMMERSE may collect and process personal data from the following categories:

Data Type	Description of Data
Identity Data	Information that uniquely identifies an individual to establish and verify the identity of clients and coaches, ensuring personalized and secure interactions.E.g, Full Name, Gender, Nationality
Contact Data	Information that facilitates communication with an individual essential for scheduling sessions, sending reminders, and maintaining ongoing communication with clients. Primarily email addresses and in some cases phone numbers, postal addresses, and social media profile
Financial Data	Information related to monetary transactions used for processing payments, managing subscriptions, and tracking financial transactions. E.g: payment history, bank details, credit card information, invoices and receipts, subscription/membership fees.
Transaction Data	Information generated from specific interactions or exchanges between parties. E.g: Session bookings and cancellations, courses purchase/enrollment.
Technical Data	Information related to the technology, systems used to access our website, during coaching interactions. (details to be confirmed from website manager).
Profile Data	Information that provides a comprehensive view of an individual’s characteristics, preferences, and background which helps in tailoring coaching sessions to align with the client’s personality, learning style, and objectives, ensuring a personalized and effective coaching experience. E.g, Industry, Occupation, Preferred coaching styles or methodologies, Learning preferences, assessments/personality test results, Career aspirations and personal development goals.
Job Application Data	Information collected from individuals applying for employment which facilitates the recruitment process by assessing the qualifications and suitability of candidates for roles within the Firm. E.g: Resume or Curriculum Vitae (CV), Cover letters, Educational qualifications and certifications, Work experience and references, Skill assessments/tests.
Usage Data	Information on how clients interact with our coaching services, platforms, or resources, which provides insights into client engagement and the effectiveness of coaching offerings, enabling continuous improvement and customization of service.
Marketing and Communications Data	Information related to the promotion and communication strategies employed by our coaching firm. This assists in evaluating the effectiveness of marketing campaigns and communication strategies, guiding future promotional efforts, and client outreach.
Others	User-generated content such as feedback responses and assesment results.Health/Allergies, Emergency Contact in cases of our full-day/International Retreats. Audio, Visual, or Similar Data, including session recordings in virtual coaching events, physical events,  one-on-one sessions, photographs, etc.

IMMERSE collects and processes personal data only for specific, legitimate, and clearly defined purposes. These purposes include:

• Delivering our coaching products, programs, and services tailored to your needs
  
• Fulfilling our contractual obligations to you or third parties
  
• Enhancing your customer service experience and support interactions
  
• Managing and improving our internal business operations
  
• Maintaining meaningful client relationships
  
• Complying with applicable legal and regulatory obligations
  
• Sharing relevant information with clients, coaches, and approved stakeholders
  
• Updating client records and generating analytics and statistics to inform business decisions
  
• Communicating with clients, team members, and stakeholders when necessary
  

IMMERSE is committed to collecting and using personal data only for these clearly stated purposes and will not process your data in a way that is incompatible with them.

4. Legal Grounds for Processing Personal Data

Before processing any personal data, IMMERSE ensures that the purpose is clearly identified and that there is a valid legal basis for the processing, in line with applicable data protection laws.

The legal bases may include:

• Consent: You have given clear, informed, and voluntary permission for your data to be processed for a specific purpose.
  
• Contractual necessity: The processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract.
  
• Legal obligation: Processing is required to comply with a legal or regulatory obligation.
  
• Vital interests: Processing is necessary to protect your vital interests or those of another person, particularly in emergencies.
  
• Public interest or official authority: Processing is carried out in the public interest or under official authority vested in IMMERSE.
  
• Legitimate interests: Processing is necessary for the legitimate interests pursued by IMMERSE or a third party, provided these interests do not override your rights and freedoms.

Consent

By voluntarily providing your personal information — whether through online forms, physical documents, or third-party platforms — you consent to the collection, use, and processing of your data in accordance with this Privacy Policy.

Consent may be obtained through:

• Signed forms and contracts
  
• Digital acceptance (e.g., ticking a checkbox or submitting an online form)
  
• Verbal agreement in recorded sessions (where applicable and lawful)
  

You may withdraw your consent at any time by contacting info@immersecoaching.co. Withdrawal does not affect the lawfulness of any prior processing based on consent.

5. Security of Personal Data

At IMMERSE, we take the protection of your personal data seriously and implement both technological and organizational measures to ensure its confidentiality, integrity, and availability. Our security framework includes:

1. Strict Access Controls
   
   • Role-based access permissions to ensure only authorized personnel can view or process personal data.
     
   • Multi-factor authentication (MFA) on sensitive systems.
     
2. Data Encryption
   
   • Encryption of personal data both in transit (e.g., during video sessions, email communication) and at rest (e.g., on databases, cloud storage).
     
3. Secure Data Storage
   
   • Use of reputable, NDPA-compliant cloud service providers with robust data protection infrastructure.
     
4. Security Incident Management
   
   • Defined protocols to detect, report, and respond to security breaches, with rapid mitigation and client notification procedures.
     
5. Regular System Updates and Patch Management
   
   • Continuous monitoring of systems and applications with prompt application of updates and patches to address vulnerabilities.
     
6. Data Anonymization and Minimization
   
   • Limiting personal data collection to what is necessary for coaching engagement and anonymizing where possible.
     
7. Staff Training and Confidentiality
   
   • Ongoing training for all staff on data privacy, cybersecurity, and safe handling of client information.
     
   • Signed confidentiality agreements and data protection obligations.
     
8. Secure Communication Channels
   
   • Use of encrypted communication platforms (e.g., Zoom with passcodes, secure email, private coaching portals).
     
9. Backups and Disaster Recovery Plans
   
   • Regular data backups and tested recovery processes to ensure service continuity in the event of system failure.
     
10. Third-Party Risk Management
    

• Vetting and regular review of third-party service providers who process or store client data, ensuring compliance with data protection standards.
  

Customer Responsibility:

If you have been provided with authentication or authorization credentials (such as usernames, passwords, access codes, or links) to access any of our products, services, or platforms, you are responsible for maintaining the confidentiality and security of those credentials.

You agree not to:

• Share your login details with others.
  
• Allow unauthorized access to your account or sessions.
  
• Use someone else’s access credentials to engage with our services.
  

IMMERSE will not be liable for any loss or damage arising from your failure to protect your access details. If you suspect any unauthorized use of your credentials, you must notify us immediately so we can secure your account.

6. Sharing of Personal Data

IMMERSE may share your personal data with trusted third parties in limited circumstances, and only when necessary to support our services or comply with legal obligations. These include:

• Service Providers and Technical Partners
  Providers who support our digital platforms, IT infrastructure, cloud storage, email systems, scheduling tools, and data analytics.
  
• Coaches and Mentors
  Certified professionals within our network who require relevant information to deliver personalized coaching and mentorship services.
  
• Professional Advisors
  Including legal, financial, and compliance consultants who advise IMMERSE in the course of our operations.
  
• Law Enforcement or Regulatory Authorities
  Where required by applicable law, regulation, or legal process, or to protect the rights, property, or safety of IMMERSE, its clients, or others.

Data Protection Agreements:

In all applicable cases, we enter into data-sharing or data-processing agreements with third parties to ensure your personal data remains protected, secure, and used only for the intended purpose in compliance with relevant data protection laws.

7. Automated Processing

IMMERSE may, at times, use automated systems and software to support decision-making processes involving your personal data. This may include:

• Identity verification and security checks
  
• Fraud detection and prevention
  
• Anti-money laundering (AML) screenings
  
• Eligibility or suitability assessments for specific products, services, or programs
  

These systems help us ensure efficiency, accuracy, and compliance with legal and regulatory obligations. However, we do not make solely automated decisions that have a legal or similarly significant effect on you without appropriate human oversight.

If an automated decision affects you significantly, you have the right to request human intervention, express your point of view, or contest the decision in accordance with applicable data protection laws.

8. Use of Cookies

The IMMERSE website uses cookies, including those provided by trusted third parties such as Google Analytics, to enhance your browsing experience and help us understand how our website is used.

Cookies are small data files placed on your device to collect standard internet log information and visitor behavior data. These cookies allow us to:

• Recognize your device when you return to our website
  
• Track user navigation to understand how visitors interact with our content
  
• Improve the website’s usability and performance in real time
  
• Analyze traffic patterns and site usage (e.g., number of daily visits)
  
• Manage site operations and optimize content delivery

Managing Cookies

You can choose to disable cookies by adjusting your browser settings. Please note that disabling cookies may affect the functionality and features of our website, and some parts of the site may not function as intended.

For more detailed information on how we use cookies and how you can control them, please see our Cookie Policy.

9. Data Retention

IMMERSE retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to:

• Comply with legal, regulatory, or contractual obligations
  
• Address customer service requests, disputes, or claims
  
• Meet internal business operations, audit, and record-keeping requirements
  

Once your personal data is no longer required for these purposes, we take appropriate steps to ensure it is securely deleted, anonymized, or destroyed in accordance with applicable data protection laws and industry best practices.

Where data retention periods are defined by law (e.g., tax or accounting regulations), we retain data for the duration required.

10. Children’s Privacy

Our core coaching services are designed for individuals aged 18 and above. We do not knowingly collect or process personal information from children under the age of 13, in compliance with applicable privacy laws such as the Children’s Online Privacy Protection Act (COPPA) and similar regulations.

However, from time to time, IMMERSE may offer specific events, workshops, or programs tailored to minors (under the age of 18). In such cases:

• Verifiable parental or guardian consent will be required before collecting any personal data or permitting participation.
  
• All personal information collected from minors will be handled with strict confidentiality, and used solely for the purpose of delivering the relevant service.
  
• We do not use children’s data for marketing or profiling purposes.
  

If you are a parent or guardian and believe your child has submitted personal information to us without your consent, please contact us immediately at info@immersecoaching.co. We will take prompt and appropriate action to review and delete the information, where necessary.

11. Storage of Personal Data

Your personal data is securely stored on IMMERSE’s internal storage systems and through globally recognized, NDPA-compliant cloud service providers, ensuring both security and seamless service delivery.

In some cases, your data may be transferred and stored outside Nigeria, particularly when using international platforms or tools. When this occurs, we take all necessary safeguards to:

• Ensure your data remains protected and confidential
  
• Comply with applicable data protection laws and this Privacy Policy
  
• Use only service providers that offer adequate data protection standards, such as those covered under data transfer agreements, standard contractual clauses (SCCs), or similar legal mechanisms
  

We continuously review our data storage and transfer practices to ensure your personal information remains secure, regardless of location.

12. Your Privacy Rights

As a data subject, you have specific rights regarding your personal data while it is being collected, processed, or stored by IMMERSE. You have the right to:

• Access: Request a copy of the personal data we hold about you.
  
• Rectification: Ask us to correct any inaccurate or incomplete data.
  
• Erasure: Request that your data be deleted from our records and systems, where legally permissible.
  
• Restriction: Request a restriction on the processing of your personal data under certain conditions.
  
• Data Portability: Ask that your data be transferred to another organization, where technically feasible.
  
• Objection: Object to specific types of data processing, such as direct marketing.
  
• Automated Decisions & Profiling: Object to decisions made solely through automated processing (including profiling) and request human review where such processing has legal or significant effects on you.
  

If your data is processed by third parties on our behalf, we will forward your request to the relevant party as required.

These rights can be exercised by:

• Writing to us, or
  
• Filling out our Data Subject Access Request (DSAR) form and sending it to: info@immersecoaching.co 

Click here to download the DSAR form

If you believe your data protection rights have been violated, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at info@ndpc.gov.ng or email us directly at info@immersecoaching.co

You also have the right to withdraw your consent to data processing at any time. Please note that any processing carried out prior to your withdrawal will remain lawful.

13. Transfer of Personal Data to Foreign Countries

IMMERSE may, in limited cases, transfer your personal data to countries outside Nigeria in order to deliver our services effectively, especially when using global platforms or service providers.

All such transfers are carried out in compliance with the Nigeria Data Protection Act (NDPA) and relevant international data protection laws. Personal data will only be transferred under one or more of the following conditions:

• You have given explicit consent to the transfer
  
• The transfer is necessary for the performance of a contract between you and IMMERSE, or to take steps at your request before entering into a contract
  
• The transfer is necessary for important reasons of public interest
  
• It is required for the establishment, exercise, or defence of legal claims
  
• It is necessary to protect your vital interests, especially where you are physically or legally incapable of giving consent
  
• The receiving country or entity offers adequate data protection safeguards that are consistent with this Privacy Policy
  

We ensure appropriate safeguards such as Data Protection Agreements (DPA), Standard Contractual Clauses (SCCs), and the use of reputable, secure platforms that uphold international data privacy standards.

14. Accuracy of Personal Data

At IMMERSE, we rely on you to ensure that the personal data we hold is accurate, complete, and up to date. You are responsible for notifying us of any changes to your personal information.

You may update your details at any time by contacting us through our official customer service channels or by emailing us at info@immersecoaching.co

Maintaining accurate data helps us serve you better and ensures compliance with legal and operational requirements.

15. Third-Party Websites and Services

IMMERSE platforms may contain links to third-party websites, tools, or services (such as payment gateways, video conferencing platforms, or social media channels) that are not operated or controlled by IMMERSE.

Please note that we are not responsible for the privacy practices, content, or policies of these third-party services. We strongly encourage you to review their privacy policies independently before providing any personal data through those platforms.

Your use of any linked third-party site is at your own risk, and this Privacy Policy applies only to data collected directly by IMMERSE.

16. Opting Out of Promotional Communications

We may occasionally send you newsletters, updates, or promotional content about IMMERSE programs, events, and offerings.

You have the right to opt out of receiving marketing communications at any time. You can do so by:

• Clicking the “Unsubscribe” link at the bottom of any promotional email you receive from us
  
• Sending an email to info@immersecoaching.co clearly stating your preference to no longer receive marketing messages
  

Please note that even if you opt out of promotional communications, we may still contact you regarding important administrative or service-related matters, such as appointment confirmations, program updates, or legal notices.

17. Changes to This Privacy Policy

IMMERSE may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or service offerings.

Any revisions will be posted on our website and will take immediate effect upon publication. Where applicable, we may also notify you via email or through our platforms.

We encourage all users to review this policy periodically to stay informed about how we protect your personal data and uphold your rights.

18. Contact Information

If you have any questions, concerns, complaints, or data protection inquiries regarding this Privacy Policy or how we handle your personal data, please contact us at: 

IMMERSE COACHING COMPANY 

📍 70 Queens Street Alagomeji-Yaba, Lagos Nigeria

📞 +234 916 152 2138 

 📧 info@immersecoaching.co