Privacy Policy
This policy explains what personal data ADC Digital (“we”, “us”), a division of ADC Systems Integrated Solutions Limited, collects, why we use it, who we share it with, and the rights you have under the Nigeria Data Protection Act 2023 (“NDPA”). ADC Systems Integrated Solutions Limited is the data controller.
1. Who we are and how to contact us
ADC Systems Integrated Solutions Limited, trading as ADC Digital.
Privacy contact: adcdigitalimited@gmail.com
2. What we collect
From publishers and advertisers (account holders)
- Account details: name, email address, company name, website, and your chosen role. Your password is stored only as a one-way hash, never in readable form.
- Payment details, if you provide them: your bank name, account name and account number, so that we can pay commissions by bank transfer. We also keep a record of each payment made to you (date, amount and transfer reference). Only the administrators who handle payments can see your full account number.
- Activity records: campaigns you create or promote, clicks and conversions linked to your account, commissions earned, and actions administrators take on your account (for example approval or suspension).
- Security records: sign-in attempts and password-reset requests, kept as scrambled identifiers so that we can limit abuse.
- Your agreement to these documents (which version, and when).
From people who click a tracking link (visitors)
When someone clicks a publisher’s tracking link we record: the time, the campaign and publisher, a randomly generated click ID, the browser’s user-agent text, the referring website (if any) and a hashed form of the IP address. We do not store the raw IP address and we do not ask visitors for their name or email. If a partner later reports a conversion, we link it to the click ID.
From people who subscribe to an airtime-billed service (subscribers)
If you subscribe to a service that is billed to your airtime, we collect your mobile number, your network, the service you chose, the date you agreed (and that you are 18 or over and accepted the price and terms), and a record of each charge, failed charge, refund and cancellation. We receive confirmations from our billing partner (an aggregator working with your mobile network). Your number is stored encrypted, and administrators normally see only its last four digits. If you arrived through a publisher’s link, we keep the click ID so the publisher can be credited. You can cancel at any time on our cancel page or by following the instructions in our messages, and you can ask us to erase your number by emailing adcdigitalimited@gmail.com. We keep charge records without your number for accounting.
3. Why we use it, and our legal basis
| Purpose | Legal basis (NDPA) |
|---|---|
| Creating and running your account, approving it, and sending service emails (sign-in, password reset, email confirmation) | Performance of our contract with you; your consent |
| Recording clicks and conversions, calculating and paying commissions, reporting to advertisers | Performance of a contract; our legitimate interest in running the network |
| Detecting bots, repeated or fake clicks and other fraud; protecting accounts | Our legitimate interest in preventing fraud and abuse |
| Keeping accounting, audit and regulatory records | Legal obligation |
| Keeping a record of what you agreed to | Legal obligation and legitimate interest |
We do not use your data for advertising profiles, and we do not make decisions about you solely by automated means that have legal or similarly significant effects. Automatic fraud checks only flag activity; a person reviews it before money is withheld or an account is closed.
4. Who we share it with
- Advertisers and their partners: receive click IDs and the information needed to confirm conversions. Publishers and advertisers see each other’s company and campaign information only as needed to run campaigns.
- Service providers (processors) that act on our instructions: web hosting (Vercel), database hosting (Supabase), email delivery (Resend, once enabled), payment processing (Paystack: advertiser payments in, and bank transfers out to publishers, for which your bank name, account number and verified account name are sent to Paystack) and, for administrator exports only, Google Drive and Google Sheets.
- Authorities or professional advisers, where the law requires it or to protect legal rights.
We do not sell personal data.
5. Transfers outside Nigeria
Our providers may store or process data on servers outside Nigeria. Where that happens we rely on the safeguards the NDPA allows, such as contracts with the provider that require them to protect the data and to use it only for our instructions.
6. How long we keep it
We keep account data while your account exists, and afterwards for as long as needed for accounting, fraud prevention, disputes and legal obligations. Click and conversion records are kept while they may be needed to verify or reverse a commission or to investigate fraud. We review records regularly and delete or anonymise data we no longer need. If you ask us to delete your data we will do so unless the law or a genuine dispute requires us to keep part of it, and we will tell you which part.
7. Cookies
We use a single strictly necessary cookie, named adc_session, to keep you signed in. It is HttpOnly (not readable by scripts), is used only on this site, and expires after 8 hours or when you sign out. We do not set advertising or analytics cookies. Websites you reach through a tracking link are run by advertisers and may use their own cookies under their own policies.
8. How we protect it
We protect personal data with measures such as hashed passwords, encrypted connections, access limited by administrator role, signed and time-limited conversion reports, rate limiting against password guessing, and records of administrator actions. No system is perfectly secure. If a breach is likely to put people at risk, we will notify the Nigeria Data Protection Commission and affected people as the NDPA requires.
9. Your rights
Under the NDPA you may:
- ask whether we hold your data and get a copy;
- have inaccurate data corrected;
- ask us to delete data we no longer need or have no right to keep;
- ask us to restrict our use of it, or object to uses based on our legitimate interests;
- receive your data in a common electronic format (portability);
- withdraw consent at any time, which does not affect what we did before you withdrew it.
Email adcdigitalimited@gmail.com from the address on your account. We will reply within 30 days and may need to confirm who you are first. If you are not satisfied you can complain to the Nigeria Data Protection Commission (ndpc.gov.ng).
10. Children
ADC Digital is for people and businesses aged 18 or over. We do not knowingly collect data from children. If you think a child has given us data, please tell us and we will delete it.
11. Changes
We may update this policy. The date at the top shows the latest version. If we make an important change we will tell account holders, and ask for agreement again where the law requires it.