Privacy Policy

1. Introduction

Ledgeris Ltd. (“Ledgeris,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information that you share with us. This Privacy Policy (“Policy”) explains how we collect, use, disclose, store, secure, and otherwise process your personal information when you visit or use ledgeris.com (the “Website”).

This Policy is intended to comply with and incorporate the requirements of:

  • The Nigerian Data Protection Regulation (NDPR, 2019);

  • The European Union General Data Protection Regulation (EU Regulation 2016/679) (GDPR);

  • The California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA);

  • The California Online Privacy Protection Act (CalOPPA).

By using the Website, you consent to the practices described in this Policy.

2. Collection of Personal Information

Ledgeris collects Personal Information only to the extent necessary for legitimate business purposes, in compliance with applicable data protection laws, and subject to appropriate security and confidentiality safeguards. Specifically:

  1. Direct Collection from Data Subjects
    Personal Information may be collected directly from you when you voluntarily provide it, including but not limited to when you complete online forms, register to receive communications, submit inquiries through the Website, or otherwise engage with Ledgeris in the ordinary course of business.

  2. Automated Collection through Secure Technologies
    Certain information is collected automatically when you interact with the Website. This may include IP addresses, browser type, device identifiers, and browsing behavior. Such collection occurs through cookies, session identifiers, local storage, analytics tools, and comparable tracking technologies deployed in accordance with Applicable Law. Automated collection is limited to data strictly necessary to ensure the security, functionality, and improvement of our Website and services.

  3. Collection from Authorized Third Parties
    Ledgeris may lawfully obtain Personal Information from third-party sources, including analytics providers, professional networks (such as LinkedIn), and other trusted partners. Where such data is collected, it is processed under contractual or legal assurances that the third party has obtained the data lawfully and in compliance with applicable privacy regulations.

Ledgeris expressly disclaims the use of covert, unauthorized, or deceptive methods of data collection. All Personal Information is collected in accordance with the principles of lawfulness, fairness, transparency, data minimization, and purpose limitation under NDPR, GDPR, CCPA, and CalOPPA.

3. What information do we collect?

The categories of information collected include:

  1. Identifiers and Contact Details – Name, email address, phone number, mailing address, work address, employer, and job title.

  2. Technical Information – IP address, browser type, operating system, device identifiers, and diagnostic data.

  3. Geolocation Information – Collected via tools such as Google Maps.

  4. Online Activity Data – Usage statistics, preferences, browsing behavior, cookies, sessions, and LinkedIn Insight Tag data.

  5. Communications Data – Content of emails, forms, and subscription requests.

  6. Children’s Data – The Website is publicly accessible; however, Ledgeris does not knowingly collect data from children under 13.

4. Use of Personal Information

Ledgeris processes Personal Information strictly in accordance with applicable data protection and privacy laws, and only for legitimate, specified, and lawful purposes. Without limitation, such purposes include the following:

  1. Provision and Enhancement of Services
    To operate, administer, maintain, and improve the Website and related services, including the deployment of technical measures designed to safeguard availability, integrity, and confidentiality.

  2. Communications and Notices
    To communicate with you by email or other electronic means, including service updates, newsletters, promotional materials, and administrative notices, subject always to applicable legal requirements for consent and opt-out rights.

  3. Personalization and User Experience
    To tailor and personalize the content, features, and functionality of the Website to individual preferences, and to measure the effectiveness of our communications and digital properties.

  4. Analytics, Research, and Business Intelligence
    To conduct lawful analytics, market research, usage monitoring, and business intelligence activities necessary to understand user behavior, improve service delivery, and maintain compliance with internal governance standards.

  5. Marketing and Retargeting Activities
    To lawfully engage in remarketing, retargeting, and campaign measurement across permitted third-party platforms (e.g., LinkedIn), ensuring such activities are conducted in compliance with NDPR, GDPR, CCPA, and CalOPPA.

  6. Legal, Regulatory, and Contractual Compliance
    To comply with obligations arising under applicable law, regulations, regulatory inquiries, or valid legal process, and to honor contractual obligations entered into with clients, partners, and third parties.

  7. Fraud Prevention, Security, and Enforcement of Rights
    To detect, investigate, and prevent unauthorized access, fraudulent activity, or other unlawful conduct; to protect the security of our systems and data; and to establish, exercise, or defend Ledgeris’s legal rights and interests.

Ledgeris shall not use Personal Information in a manner inconsistent with the purposes described in this Policy, and shall apply the principles of lawfulness, fairness, transparency, purpose limitation, and data minimization to all processing activities.

5. Use of email addresses

Ledgeris collects and processes email addresses solely in accordance with applicable data protection laws and in furtherance of legitimate business purposes. Specifically:

  1. Communications and Notices – Your email address may be used to transmit administrative notices, service-related communications, newsletters, and other information that Ledgeris reasonably considers relevant to your relationship with us.

  2. Consent-Based Marketing – Where you have expressly consented, your email address may also be used for marketing communications concerning Ledgeris’s services, promotions, or events. You retain the right to withdraw such consent at any time by following the opt-out instructions provided in each communication or by contacting us directly.

  3. Retargeting and Campaign Management – Ledgeris may utilize email addresses, in hashed or pseudonymized form where appropriate, for remarketing and retargeting activities through approved platforms (including, without limitation, LinkedIn), in compliance with GDPR, NDPR, CCPA, and other applicable regulations.

  4. Prohibited Uses – Ledgeris does not rent, sell, or otherwise disclose email addresses to unaffiliated third parties for their independent marketing purposes. All disclosures, where necessary, are limited to service providers bound by contractual obligations of confidentiality and data protection.

  5. Safeguards – All email addresses collected are stored securely and subject to appropriate administrative, technical, and organizational safeguards to protect against unauthorized access, alteration, or misuse.

6. How long do we keep your information?

We retain your personal information only as long as necessary to fulfill the purposes described in this Policy. For active client relationships, we retain data throughout the duration of our business relationship. For marketing communications, we retain information until you unsubscribe or withdraw consent. For legal compliance, we retain data as required by applicable laws and regulations. For business records, we maintain information according to our document retention policies.

When retention is no longer necessary, we will securely delete personal information from our systems, anonymize data so it can no longer identify individuals, destroy physical records containing personal information, and ensure that third parties also delete or return your data as appropriate.

7. How do we protect your information?

Ledgeris implements a variety of administrative, technical, and organizational safeguards to protect the confidentiality, integrity, and availability of your Personal Information when you submit, access, or otherwise interact with our Website.

  • Secure Transmission: All data exchanged with the Website is protected using Secure Socket Layer (SSL) encryption or equivalent secure protocols to prevent interception.

  • Access Controls: Personal Information is accessible only to authorized personnel who are required to keep such information confidential and are bound by contractual and legal obligations of non-disclosure.

  • Data Storage and Encryption: Personal Information is stored in secure systems protected by firewalls, intrusion detection, and monitoring tools. Sensitive data, where applicable, is encrypted at rest and in transit.

  • Physical Safeguards: Access to facilities and servers where Personal Information is stored is restricted and monitored.

  • Organizational Measures: Employees and contractors undergo privacy and security awareness training and are subject to role-based access controls.

Ledgeris does not collect or store payment card information, social security numbers, or other highly sensitive financial identifiers.

Despite our safeguards, no system of transmission over the internet or method of electronic storage can be guaranteed to be 100% secure. Accordingly, Ledgeris cannot and does not warrant or guarantee the absolute security of any information you transmit to us or that may be stored in our systems. In the event of a data breach, Ledgeris will comply with all applicable notification obligations under NDPR, GDPR, CCPA, and other relevant privacy laws.

8. Your consent

By continuing to use the Website, registering for services, or otherwise providing Personal Information, you consent to the collection, processing, and use of your data in accordance with this Policy.

9. Use of cookies and related technologies

Ledgeris employs cookies, local storage objects, session identifiers, and comparable tracking technologies (“Cookies”) in order to ensure the secure, efficient, and lawful operation of the Website. The use of such technologies is limited to the following purposes:

  1. Authentication and Session Management
    To maintain secure login sessions, recognize repeat visits, and distinguish one user from another, thereby safeguarding account integrity and preventing unauthorized access.

  2. Functionality and User Experience
    To store user preferences and facilitate navigation, thereby improving the quality, responsiveness, and personalization of the Website.

  3. Analytics and Performance Monitoring
    To lawfully collect anonymized or aggregated information regarding Website traffic, performance, and usage patterns through tools such as Google Analytics. Such information assists Ledgeris in identifying technical issues, improving system resilience, and enhancing user experience.

  4. Retargeting and Campaign Effectiveness
    To deploy lawful remarketing and retargeting activities, including through the LinkedIn Insight Tag and comparable platforms, subject to all applicable consent requirements under NDPR, GDPR, CCPA, and CalOPPA.

Users retain the right to manage, restrict, or disable Cookies through their browser or device settings. However, disabling Cookies may impair the functionality, security, and overall user experience of the Website.

Ledgeris does not use Cookies or comparable technologies for covert surveillance, unauthorized profiling, or any purposes inconsistent with the principles of lawfulness, fairness, transparency, and data minimization.

10. Remarketing services

Ledgeris uses lawful remarketing technologies to present tailored advertising to users who have previously interacted with the Website. These activities are subject to all applicable consent and opt-out rights under NDPR, GDPR, CCPA, and CalOPPA.

11. Third-party services

The Website may contain links to, or integrate with, third-party services such as Google Maps or LinkedIn. Ledgeris is not responsible for the privacy practices of such third parties. Users are encouraged to review third-party privacy policies.

12. Information About the General Data Protection Regulation (GDPR)

12.1 Applicability of GDPR

If you are located in the European Economic Area (EEA), we may collect, process, and use your Personal Data in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”). This section of our Privacy Policy explains how and why such data is collected and the measures we employ to ensure that it is protected against unauthorized replication, misuse, or disclosure.

12.2 What is GDPR?

The GDPR is an EU-wide privacy and data protection law that regulates how organizations collect, store, use, and protect the Personal Data of individuals residing in the EEA. It enhances the control that EU residents have over their Personal Data by granting them specific rights and imposing strict obligations on organizations that process such data.

The GDPR applies not only to EU-based businesses but also to any globally operating company that processes the Personal Data of EU residents. At Ledgeris, we have chosen to adopt GDPR-compliant standards as our baseline standard worldwide, regardless of the user’s location.

12.3 What is Personal Data?

Under GDPR, Personal Data refers to any information relating to an identified or identifiable natural person. This definition is broad and extends beyond obvious identifiers such as names or email addresses. Personal Data may include, but is not limited to:

  • Financial information;

  • Political opinions;

  • Genetic or biometric data;

  • IP addresses and device identifiers;

  • Physical or mailing address;

  • Sexual orientation;

  • Racial or ethnic origin;

  • Religious or philosophical beliefs.

Any combination of data points that allows for the identification of an individual constitutes Personal Data.

12.4 GDPR Data Protection Principles

Ledgeris processes Personal Data in accordance with the following GDPR principles:

  1. Lawfulness, Fairness, and Transparency – Data must be processed in a lawful, fair, and transparent manner.

  2. Purpose Limitation – Data must be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.

  3. Data Minimization – Data collected must be adequate, relevant, and limited to what is necessary for the intended purposes.

  4. Accuracy – Data must be accurate and, where necessary, kept up to date. Inaccurate data must be rectified or erased without delay.

  5. Storage Limitation – Data must not be kept longer than necessary to fulfill the purpose for which it was collected.

  6. Integrity and Confidentiality – Data must be processed in a manner ensuring appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage.

  7. Accountability – Ledgeris is responsible for, and must be able to demonstrate compliance with, these principles.

12.5 GDPR Data Subject Rights

Individuals covered by the GDPR have the following rights:

  • The right of access to obtain a copy of their Personal Data held by Ledgeris;

  • The right to rectification of inaccurate or incomplete data;

  • The right to erasure (“right to be forgotten”) where lawful grounds apply;

  • The right to restrict processing under certain conditions;

  • The right to data portability, enabling individuals to receive their data in a structured, machine-readable format and transmit it to another controller;

  • The right to object to processing, including for direct marketing purposes;

  • The right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;

  • The right to lodge a complaint with a supervisory authority in the EEA.

13. California Residents

TExcellent — I’ll transform that into a formal, lawyer-grade “California Residents” section that integrates directly into the Ledgeris Privacy Policy, while keeping it consistent with the CCPA/CPRA requirements.

13.1 Categories of Personal Information Collected

In the preceding twelve (12) months, Ledgeris has collected the categories of Personal Information described in Section 2 of this Policy, including identifiers (e.g., name, email address, phone number), professional and employment-related information, technical data (e.g., IP address, browser type), and geolocation data.

13.2 Sources of Personal Information

We collect Personal Information from:

  • Directly from you when you provide it through forms, communications, or subscriptions.

  • Automatically when you use our Website via cookies, sessions, analytics, and tracking technologies.

  • From third parties such as analytics providers and social media platforms (e.g., LinkedIn Insight Tag).

13.3 Use of Personal Information

We use Personal Information for the purposes set forth in Section 3 of this Policy, including providing services, analytics, communications, personalization, remarketing, and compliance with legal obligations.

13.4 Disclosure of Personal Information

We disclose Personal Information only as described in Section 7 of this Policy. We do not sell Personal Information, as defined under California Privacy Law.

13.5 Rights of California Residents

Subject to certain exceptions and limitations, California residents have the following rights under California Privacy Law:

  1. Right to Know and Access – You may request disclosure of:

    • The categories of Personal Information we have collected about you;

    • The categories of sources from which the Personal Information was collected;

    • The purposes for which the Personal Information is used;

    • The categories of third parties with whom we share Personal Information;

    • The specific pieces of Personal Information we have collected about you.

  2. Right to Delete – You may request that we delete Personal Information we have collected about you, subject to exceptions provided by law (e.g., compliance with legal obligations).

  3. Right to Correct – You may request correction of inaccurate Personal Information we hold about you.

  4. Right to Opt-Out of Sale/Sharing – Ledgeris does not sell or share Personal Information as defined under California Privacy Law. If that ever changes, we will provide notice and a mechanism to exercise this right.

  5. Right to Limit Use of Sensitive Personal Information – To the extent Ledgeris processes any “sensitive personal information” as defined under California Privacy Law, you may direct us to limit its use to only what is necessary to perform our services or comply with law.

  6. Right to Equal Service and Non-Discrimination – We will not deny goods or services, charge different prices, or provide a different level or quality of services if you exercise your privacy rights.

13.6 Exercising Your Rights

California residents may exercise their rights by contacting us:

We are required to verify your identity before fulfilling your request and may ask you to provide sufficient information to reasonably verify that you are the person about whom we collected Personal Information.

We will respond to verifiable consumer requests within forty-five (45) days, with the possibility of a one-time extension of an additional forty-five (45) days when reasonably necessary, as permitted under California Privacy Law.

14. Complaints and Enforcement

  • Nigeria: Complaints may be lodged with the Nigeria Data Protection Commission (NDPC).

  • EEA: Complaints may be filed with relevant supervisory authorities.

  • California: Concerns may be raised with the California Attorney General.

Ledgeris will investigate complaints in good faith and respond in accordance with Applicable Law.

15. Changes to this Policy

Ledgeris may amend this Policy at any time. Updates will be posted on the Website with a revised effective date. Continued use of the Website after such updates constitutes acceptance.

16. Contact Information

Privacy Officer
Ledgeris Ltd.
4 Euphrates Street, Maitama, Abuja, Nigeria
Email: info@ledgeris.com
Web Form: https://ledgeris.com/contact