Privacy policy.

Privacy Policy

Document Title: COOLLINK Privacy Policy CLL-PrivPol-000
Version: 1.1
Effective Date: March 2024
Last Reviewed: June 2025
Approved by: Data Protection Officer

1. Introduction

Radical Technology Network Ltd (trading as “COOLLINK”, “we”, “our”, or “us”) is committed to protecting the confidentiality, integrity, and availability of all personal and information assets, in accordance with ISO/IEC 27001:2022 and applicable data protection regulations including the Nigeria Data Protection Act (NDPA), the General Data Protection Regulation (GDPR), and other relevant laws.

This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you access our website or use our services.

2. Scope

This policy applies to all personal information collected by COOLLINK via our website (www.coollink.ng), online forms, services, or other digital platforms. It also applies to users accessing our services from within and outside Nigeria.

3. Information We Collect

We may collect and process the following categories of personal data:

  • Contact information: Full name, phone number, email address

  • Account information: Login credentials, service usage data

  • Payment information: Billing details, payment history

  • Technical data: IP address, browser type, device identifiers, and cookies

  • Location data (if enabled by user)

  • Third-party login data (e.g., LinkedIn, Google)

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

  • Performance of a contract (e.g., to deliver services you subscribe to)

  • Legal obligations (e.g., regulatory compliance)

  • Legitimate interests (e.g., security monitoring, service improvement)

  • Consent, where applicable (e.g., marketing communications)

You can withdraw your consent at any time.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to improve user experience and measure marketing effectiveness. You may control cookies through your browser settings. For more details, refer to our Cookie Policy.

6. Use of Personal Information

Your personal information is used for:

  • Service provisioning and account management

  • Customer support and troubleshooting

  • Network and cybersecurity monitoring

  • Communication and marketing (opt-in only)

  • Legal, regulatory, or contractual obligations

7. Data Sharing and Transfers

We do not sell your personal information. However, we may share data with:

  • Service providers who support our IT, payment, and marketing functions

  • Law enforcement or regulators when required

  • Affiliated entities or in case of a corporate reorganization

Where applicable, cross-border transfers are subject to safeguards under international privacy laws (e.g., SCCs or DPF frameworks).

8. Data Retention

We retain personal data only for as long as necessary for the purposes stated in this policy or as required by law. After this period, data is securely deleted or anonymized.

9. Your Rights

Under applicable data protection laws, you may:

  • Access and request a copy of your data

  • Correct or update inaccurate data

  • Object to or restrict processing

  • Request data portability

  • Withdraw consent (if processing is based on consent)

  • Lodge a complaint with a data protection authority

To exercise your rights, contact us at: dataprivacy@coollink.ng

10. Data Security

COOLLINK implements robust technical and organizational controls to protect personal data from unauthorized access, alteration, or disclosure. These measures include:

  • Encryption

  • Firewalls and intrusion detection

  • Access controls

  • Employee training and awareness

Our security practices are aligned with ISO/IEC 27001:2022 standards.

11. Children’s Privacy

Our website and services are not intended for children under 13. We do not knowingly collect personal information from children.

12. External Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices. We recommend reviewing the privacy policies of any external sites you visit.

13. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in law or technology. Changes will be published on our website with the “Last Reviewed” date. Material changes will be notified via email or website notification.

14. Information Security Policy Statement

As part of our ISO/IEC 27001:2022 compliance, COOLLINK maintains a dedicated Information Security Policy Statement , which is summarized below:

“The Management of Coollink is committed to ensuring the confidentiality, integrity, and availability of all her assets and to the continual improvement of same in compliance with ISO 27001:2022 and applicable regulations. Information security protects information assets from a wide range of threats to ensure business continuity, minimize business damage, and maximize ROI.”

This commitment is communicated to all staff and made available to all stakeholders.

15. Contact Us

If you have questions or concerns about this policy or how we handle your data, please contact:

Data Protection Officer
Coollink – Radical Technology Network Ltd
Email: dataprivacy@coollink.ng
Address: 267a Etim Inyang Crescent, Victoria Island, Lagos, Nigeria