Privacy Policy
This policy is a draft pending legal review. Bracketed items (e.g. registered entity name and address) must be confirmed before publication.
TheValueChain ("we", "us", "our") operates the news and media app at thevaluechainng.com (the "Service"). We publish news articles, e-copy editions, and video, including a live stream. The Service is free and does not offer user accounts, logins, or payments.
This policy explains what personal data we process, why, the legal bases we rely on, and the rights you have. We handle data in line with the Nigeria Data Protection Act 2023 (NDPA) and, for readers in the EU and UK, the GDPR and UK GDPR. Questions: privacy@thevaluechainng.com.
Who is responsible for your data
The data controller is TheValueChain (registered name and address: [to be confirmed]). Contact: privacy@thevaluechainng.com.
What personal data we collect
We collect very little. We do not ask for your name, email, or account details, because the Service has no accounts.
- App-session cookie (
tvc_pwa_access). A first-party cookie marking an app session and keeping the installed-app experience distinct from the public website. It contains a signed timestamp, not your identity, and is not used for advertising. It expires after up to 30 days. - Technical logs (IP address & request data). When your browser requests content through our server routes, our hosting provider processes your IP address, request time, user agent, and the resource requested, to deliver content and keep the Service secure. IP addresses are treated as personal data.
- Embedded YouTube videos. Video is delivered via embedded YouTube players, loaded only when you choose to play a video. At that point Google/YouTube may set its own cookies under Google's privacy policy.
We do not knowingly collect special-category data (health, biometric, etc.) and do not collect payment data.
How we use your data
- To deliver articles, e-copy editions, and video to your device.
- To operate and secure the Service and prevent abuse of our endpoints.
- To comply with legal obligations and respond to lawful requests.
We do not sell or rent your personal data, and do not use it for cross-site advertising.
Legal bases for processing
We rely on our legitimate interests (operating a secure service, the functional app-session cookie, and server logs) and on your consent for non-essential cookies and third-party tracking, including embedded YouTube video, for readers in the EU and UK. Where we rely on consent, you may withdraw it at any time.
Sharing and third parties
We share data only with service providers that help us run the Service:
- Vercel — hosting and content delivery.
- Google / YouTube — video playback (only when you play a video).
- Our publishing back end — source of articles and e-copy content.
We may also disclose data where required by law or to protect our rights, users, or the public.
International data transfers
Our hosting and some processors (e.g. Vercel, Google) may store and process data on servers outside Nigeria, including in the United States. Where we transfer personal data across borders, we rely on appropriate safeguards under the NDPA and, for EU/UK readers, the GDPR/UK GDPR.
Data retention
- App-session cookie: up to 30 days, then it expires.
- Server/access logs: retained no longer than [retention window to be confirmed], then deleted or anonymised.
Your rights
Under the NDPA (and GDPR/UK GDPR for EU/UK readers), you have the right to:
- Access the personal data we hold about you;
- Rectify inaccurate data;
- Erase your data;
- Restrict or object to processing;
- Data portability, where applicable;
- Withdraw consent, where we rely on it;
- Lodge a complaint with a supervisory authority.
To exercise a right, email privacy@thevaluechainng.com. You may complain to the Nigeria Data Protection Commission (NDPC) or, for EU/UK readers, your local Data Protection Authority or the UK ICO.
Cookies and consent
We use a small number of cookies: the strictly necessary tvc_pwa_access cookie, and third-party YouTube cookies set only when you play a video. You can manage cookies in your browser settings. For visitors in the EU/UK, non-essential cookies (including YouTube) are set only after you consent.
Data security
We use reasonable technical and organisational measures, including HTTPS encryption, restricted infrastructure access, rate limiting and request validation, and dependency scanning. No method of transmission or storage is completely secure.
Breach notification
If a personal-data breach is likely to result in a risk to your rights, we will notify the NDPC within 72 hours of becoming aware of it, and notify affected individuals where required.
Children's privacy
The Service is a general-audience news publication and is not directed at children. We do not knowingly collect personal data from children.
Links to other sites
The Service links to and embeds third-party content. We are not responsible for the privacy practices of those third parties.
Changes to this policy
We may update this policy from time to time, posting the new version here with an updated date and, for material changes, a prominent notice.
Governing law
This policy is governed by the laws of the Federal Republic of Nigeria, without prejudice to data-protection rights available to readers in other jurisdictions.
Contact
Questions, requests, or complaints: privacy@thevaluechainng.com.