Privacy Policy

1. Who we are

This Privacy Policy explains how Japafirst ("we", "us", "our") collects and uses your personal data when you use our website or contact us about studying, touring, relocating abroad, or scheduling flights. We are the data controller responsible for your personal data.

• Registered name: [Registered business name]
• RC number: [CAC RC number]
• Registered office: [Registered office address, Abuja, Nigeria]
• Email: hello@japafirst.ng
• WhatsApp: [WhatsApp / phone number]

2. What this policy covers

It covers personal data we collect through our website forms, our WhatsApp conversations with you, our email communications, and the analytics and cookies on our site. It does not cover third-party websites we link to, such as airlines, universities, embassies, or insurers, which have their own privacy policies.

3. The personal data we collect

Information you give us when you book a consultation, submit a flight enquiry, or request our Budapest checklist:

• Your name
• Your email address
• Your WhatsApp number or phone number
• The service you are interested in (study, visa support, or flights)
• Travel, study, or visa details you choose to share, such as your destination, intended travel dates, departure city, number of travellers, and budget range
• Any message or notes you send us

Information we collect automatically when you visit the site:

• Device and browser information, approximate location, and pages viewed
• Cookies and similar technologies, and analytics data (see section 9)

We do not ask for your passport number, financial account details, or other sensitive data through the website. Please do not send sensitive documents through the website forms. If documents are needed during a consultation, we will tell you the secure way to share them.

4. How we use your data, and our lawful basis

Under the NDPA we must have a lawful basis for using your data. We rely on the following:

• To respond to your enquiry and provide our services (taking steps at your request before and during any agreement). This covers replying to your consultation or flight enquiry, advising you, and coordinating your study, visa, or flight plans.
• Your consent, where you ask us to send you the Budapest checklist, marketing updates, or travel tips. You can withdraw consent at any time.
• Our legitimate interests, in running and improving our service, keeping our site secure, preventing fraud and spam, and keeping records of our dealings with you, provided these interests do not override your rights.
• Legal obligation, where we must keep or disclose data to comply with Nigerian law.

We will not use your data for a new, unrelated purpose without telling you and, where required, asking for your consent.

5. Who we share your data with

We do not sell your personal data. We share it only as needed:

• Service providers (processors) who help us run the business, including our website and database hosting provider, our email delivery provider, our analytics provider, and WhatsApp, which we use to communicate with you. These providers process data on our instructions.
• Partners you ask us to engage on your behalf during a consultation, such as airlines, universities, or insurance providers, and only with your knowledge.
• Authorities or advisers where we are required to share data by law, or to establish, exercise, or defend legal claims.

6. Transfers outside Nigeria

Some of our service providers store or process data outside Nigeria. Where your data is transferred abroad, we take steps required under Part VIII of the NDPA to ensure it is protected, by relying on an adequate-protection basis or putting appropriate safeguards in place with the provider. You can contact us for more detail on these safeguards.

7. How long we keep your data

We keep enquiry and client data for as long as needed to provide our services and to keep reasonable business and legal records, after which we delete or anonymise it. Marketing data is kept until you unsubscribe or ask us to delete it.

8. Your rights

Under the NDPA you have the right to:

• Access the personal data we hold about you
• Ask us to correct inaccurate or incomplete data
• Ask us to delete your data, where the law allows
• Object to, or ask us to restrict, certain processing
• Receive your data in a portable format
• Withdraw consent at any time, where we rely on consent
• Lodge a complaint with the NDPC

To exercise any of these, email us at hello@japafirst.ng. We will respond within the time the NDPA requires. You will not be charged for a reasonable request.

9. Cookies and analytics

Our site uses cookies and similar technologies to make the site work, understand how it is used, and measure our marketing. Where required, we ask for your consent through a cookie notice before setting non-essential cookies, and you can change your choice at any time in your browser settings. We may use tools such as web analytics and a marketing pixel to understand traffic and improve our adverts.

10. Marketing and WhatsApp messages

If you opt in, we may send you helpful travel and visa updates by email or WhatsApp. You can opt out at any time by replying STOP on WhatsApp, using the unsubscribe link in our emails, or emailing hello@japafirst.ng. We will still send you messages needed to answer your enquiry or deliver a service you asked for.

11. Children

Our services and website are intended for people aged 18 and over. We do not knowingly collect data from children under 18 without the consent of a parent or guardian. If you believe a child has given us data without consent, contact us and we will delete it.

12. How we protect your data

We use reasonable technical and organisational measures to protect your data, including access controls and secure, reputable hosting. No system is completely secure, but we work to keep your data safe and to act quickly if anything goes wrong.

13. Registration and contact point

Where the law requires it, we register with the NDPC as a data controller and, where needed, appoint a contact for data protection matters. For any privacy question or request, contact:

• Email: hello@japafirst.ng
• WhatsApp: [WhatsApp / phone number]
• Address: [Registered office address, Abuja, Nigeria]

You may also contact the Nigeria Data Protection Commission if you are not satisfied with how we handle your data.

14. Changes to this policy

We may update this policy from time to time. We will post the updated version here with a new effective date, and for significant changes we will take reasonable steps to let you know.

Effective date: [Effective date]

This document is drafted to align with applicable Nigerian law, including the NDPA 2023 and the NDPC GAID 2025, as understood at the date of drafting. It is not legal advice. Please have it reviewed by a Nigerian-qualified legal practitioner before publishing.