Privacy Notice


Last Updated 14 May 2021

Welcome to the Bold Fusion’s Privacy Notice.


This Privacy Notice explains how Bold Fusion (“we”, “us”, or “our”) processes users’ Personal Information—that is, information that identifies or can identify our website visitors, customers and prospective customers, business partners, recipients of marketing communications, and event attendees . Please see our Terms of Use for more information about our online terms and policies in general.

This Privacy Notice also details what purposes we use your Personal Information for and what rights you have as a data subject under applicable data protection laws.

It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data.

1.      Who we are

 We are a management consulting firm with expertise in digital transformation, brand design and strategy, organisation modelling, corporate documentation, and advisory. We are incredibly passionate about helping our clients tell their story, find their voice, and take bold steps. As a creative outfit, we take pride in our ability to create powerful brands, develop interactive marketing strategies and lasting experiences, and implement projects that produce real value.

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please send us an email at

Changes to the Privacy Notice and your duty to inform us of changes

We will continually assess our privacy and data protection practices to ensure that your privacy is guaranteed. To this end, we keep our Privacy Notice under regular review. In the event that changes are made, we will indicate at the top of this Privacy Notice when it was most recently updated or send you a notification that the Privacy Notice has been updated. Either way, your continued use of the website will signify that you agree to any such changes. Please be assured that we will not use any previously collected Personal Information, to the extent that it is not collected under the new Privacy Notice, in a manner materially different than represented at the time it was collected.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

Third-party links

The website may include links to third-party platforms, plug-ins, portals or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of the Sites, we encourage you to read the Privacy Notice of every platform you visit.

2.     The data we collect about you

Personal Information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes physical address, email address and telephone numbers.
  • Transaction Data includes financial data anddetails about payments to and from youand other details of products and services you have requested from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, type of device used and other technology on the devices you use to access this website.
  • Profile Data includesyour username and password, requests or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use the website.
  • Communications Data includes your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Information but is not considered Personal Information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Information about you—this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

If you fail to provide Personal Information

Where we need to collect Personal Information by law, or under the terms to provide a service or product to you, and you fail to provide that data when requested, we may not be able to provide the service or product we have or are trying to provide to you. In this case, we may have to cancel a service we are otherwise obliged to provide to you but may still notify you if this is the case at the time.

3.      How is your Personal Information collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you:
  • contract us to provide a service or set of services;
  • create a client account with us; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We will receive Personal Information about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based inside or outside Nigeria;
    • search information providers based inside or outside Nigeria.
  • Contact and Transaction Data from providers of technical, payment and delivery services based inside or outside Nigeria.
  • Identity and Contact Data from data brokers or aggregators based inside or outside Nigeria.
  • Identity and Contact Data from publicly available sources.


4.     How we use your Personal Information

We process your Personal Information only where at least one of the following legal bases applies:

(x) where you have given us consent to process your Personal Information; or
(xi) where it is necessary to process your Personal Information to perform a contract or provide a service that you have requested; or
(xii) where it is necessary to respond to a lawful request from a law enforcement or regulatory authority, body or agency; in the defense of legal claims or for the violations of any of our website’s terms; or
(xiii) where it is necessary to protect an interest which is essential for your life, health and bodily safety; or
(xiv) where it is necessary for the performance of a task carried out in the public interest or in order to fulfil a public mandate; or
(xv) where we have a legitimate interest.

5.     Cookie and Other Tracking Technologies

A cookie is a small text file that includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet-enabled device when you visit an on-line site. Cookies and other tracking technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”.

We also use web beacons—electronic images (or single-pixel gifs) that we use to help deliver cookies on the website. We may also use web beacons in our emails. So when we send emails to you, we may track behaviour such as who opened the emails. This allows us to measure the performance of our emails.

       i.      Withdraw Your Cookies Consent at Any Time

By consenting to this Privacy Notice, you also consent to the use of cookies on your devices. If you do not wish to accept cookies in connection with your use of our website, you may delete and block or disable cookies via your browser settings; see below for more information on how to do this. Please note that disabling cookies—especially strictly necessary cookies—will likely affect the functionality of our website.

       ii.      How to Manage and Delete Your Cookies

Most internet browsers are initially setup to automatically accept cookies.  Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you direct your browser to our website.  You can refuse to accept cookies by activating the appropriate setting on your browser. Depending on your browser, further information may be obtained via the following links:

The information provided throughout this Privacy Notice about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of Cookies and other tracking technologies.

Change of purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6.     Disclosures of your Personal Information

We may share your Personal Information with the parties set out below for the purposes set out in the table [Purposes for which we will use your Personal Information] above.

  • Internal Third Parties including our employees.
  • External Third Parties including (x) service providers acting as processors based in Nigeria or any other country who provide IT and system administration services; (y) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Nigeria or any other country who provide consultancy, banking, legal, insurance and accounting services; and (z)such other third parties as may be necessary to us and the use, safety, security, and performance of the web

We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

7.     International transfers

Bold Fusion is based in Nigeria and stores and processes your Personal Information on computers in Nigeria. However, please note that in order to provide a smooth and seamless digital service provision, we depend on hosting services and servers located outside Nigeria; thus, your interactions with our website may mean that your Personal Information will be stored, processed, and maintained in the ordinary course of business by our hosting providers. As a matter of course, we endeavour to ensure that foreign jurisdictions where your Personal Information is processed also have data protection legislation that is no less than the existing data protection regulations in force in Nigeria.

When you are accessing our website or services from outside Nigeria, please note that any information collected may be processed in accordance with Nigerian laws, which may be different from the laws applicable in your country of residence.

8.      Data security

We are very particular about preserving your privacy and protecting your data at Bold Fusion. Therefore, to avoid the loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction of your information, we have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

Despite this, we cannot completely guarantee the security of any information you transmit via the website, as the internet is not an entirely secure place. We have put in place procedures to deal with any suspected Personal Information breach and will notify you.

9.      Data retention

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal or regulatory.

10.  Your legal right as a Data Subject

Because we determine the purposes for and the manner in which your Personal Information may be processed, we are regarded as a data controller. Likewise, because you can be identified directly or indirectly through certain categories of data that is specific to your identity, the law regards you as a data subject.

As a data subject, the law vests you with certain rights—they include the right to:

  • Request access to the Personal Information we hold about you, and request correction of such information where you believe it to be inaccurate.
  • Obtain a copy of the Personal Information we hold about you.
  • Restrict the processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: If you want us to establish the data’s accuracy; Should our use of the data be unlawful but you do not want us to erase it; Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Object to the processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Where feasible, receive all Personal Information you have provided to us—in a structured, commonly used, and machine-readable format—and to transmit the information to another data controller.
  • Withdraw your consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request the erasure of your Personal Information (also known as the right to be forgotten.) This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, in the event your information has been processed unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Lodge a complaint with a relevant authority, where you have reason to believe that we have violated the term(s) of this Privacy Notice. (You may lodge a complaint or seek redress from us within 30 days from the time you first detected the alleged violation.)

If you wish to exercise any of the rights set out above at any time, please send us an email at

No fee usually required

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may notify you and keep you updated.

11.    Contact us

If you have any questions about this Privacy Notice or any suggestions on how we can improve its terms with respect to the Personal Information we collect, please email us at

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Copyleft | Bold Fusion | (Year of the Vaccine) 2021