Privacy Policy

1. Introduction

TM Digital Biz Services (“TM Digital Biz Services”, “TM Digital Biz”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal data when you visit or use our website, www.tmdigitalbizservices.com, communicate with us, request our services, purchase our digital products, subscribe to our communications, or otherwise interact with us.

We are a Nigerian company registered as a Private Company Limited by Shares and operate in accordance with applicable laws and regulations of the Federal Republic of Nigeria.

Our processing of personal data is primarily governed by the Nigeria Data Protection Act 2023 (NDPA) and applicable regulations, directives, guidelines and other requirements issued by the Nigeria Data Protection Commission (NDPC).

Where other data-protection laws apply to you or to particular processing activities, we will take reasonable steps to comply with those laws to the extent applicable.

The NDPC identifies transparency, lawful processing, purpose limitation, data minimisation, accuracy, storage limitation and appropriate security as fundamental principles governing the processing of personal data.

Please read this Privacy Policy carefully so that you understand how we handle your personal data.

2. Who We Are

Legal Name: TM Digital Biz Services
Company Type: Private Company Limited by Shares
CAC Registration Number: 9677847
Website: www.tmdigitalbizservices.com
Email: info@tmdigitalbizservices.com
Telephone/WhatsApp: 07015060410
Business Address: Nigeria.

For purposes of applicable data-protection law, TM Digital Biz Services may act as a data controller when we determine the purposes and means for processing your personal data.

In some circumstances, particularly when providing digital marketing, social media management, advertising or related services to clients, we may process personal data on behalf of a client and may therefore act as a data processor or service provider.

The applicable role will depend on the nature of the processing activity.

3. Who This Privacy Policy Applies To

This Privacy Policy applies to individuals who:

• Visit our website;
• Contact us;
• Request a quotation;
• Request our services;
• Apply for social media management or marketing services;
• Request advertising or digital marketing services;
• Book or request a consultation;
• Subscribe to our mailing list;
• Download our free resources or lead magnets;
• Purchase digital products or resources;
• Communicate with us through WhatsApp or other communication channels;
• Submit testimonials or other content;
• Interact with our advertisements;
• Are existing or prospective clients;
• Participate in our marketing activities; or
• Otherwise interact with TM Digital Biz Services.

Our website may be accessed by people worldwide. Accordingly, personal data may be processed across different jurisdictions where permitted by applicable law.

4. Information We Collect

We collect personal data only where reasonably necessary for legitimate and specified purposes.

The type of information we collect depends on how you interact with us.

4.1 Information you provide directly

You may provide information to us when you complete a form, contact us, request a service, subscribe to our mailing list, purchase a product or otherwise communicate with us.

This may include:

• Full name;
• Email address;
• Telephone number;
• WhatsApp number;
• Business name;
• Business type;
• Website address;
• Social media handles or profile links;
• Marketing budget;
• Services you are interested in;
• Business goals;
• Information about your marketing needs;
• Consultation or enquiry details;
• Information contained in correspondence with us;
• Purchase and transaction information;
• Testimonials, photographs, videos or other content you voluntarily provide; and
• Other information you voluntarily choose to provide.

We do not intentionally request sensitive personal data through our ordinary website enquiry and service forms unless there is a specific lawful reason to do so.

You should not provide sensitive personal data to us through an ordinary enquiry form unless specifically requested or reasonably necessary for a stated purpose.

5. Information Collected Through Google Forms

We may use Google Forms for certain enquiries, applications, service requests, client onboarding processes, surveys, lead-generation activities or other business purposes.

Depending on the particular form, information may include:

• Name;
• Email address;
• Phone/WhatsApp number;
• Business name;
• Business type;
• Website;
• Social media handles;
• Marketing budget;
• Service required;
• Business goals; and
• Other information reasonably necessary for the relevant form.

Different forms may collect different categories of information.

We will seek to limit the information collected through our forms to information reasonably necessary for the stated purpose.

Google may process information in accordance with its own terms and privacy practices. Where applicable, Google acts as a third-party technology/service provider rather than as part of TM Digital Biz Services.

6. Information Collected Automatically

When you visit our website, certain technical information may be collected automatically by our website infrastructure, hosting provider, security systems or other technologies.

This may include:

• IP address;
• Browser type;
• Device type;
• Operating system;
• General geographic information derived from technical information;
• Pages visited;
• Date and time of access;
• Referring website;
• Website interactions;
• Technical logs;
• Error information; and
• Other information necessary for website security and operation.

We may use this information to maintain website security, diagnose technical problems, improve website functionality and understand general website usage.

7. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Cookies are small files or pieces of information stored on your device that allow websites to recognise your browser, remember preferences, maintain functionality and, depending on the type of cookie, understand how users interact with a website.

Our website may use or may in the future use the following categories of cookies:

Necessary cookies

These cookies may be necessary for basic website functionality, security, navigation and other essential services.

Functional cookies

These cookies may allow the website to remember preferences and improve functionality.

Analytics cookies

We may introduce analytics technologies, including Google Analytics, to understand how visitors use our website, measure website performance and improve our services.

Google Analytics is not currently represented as an active tracking technology merely because it is named in this Privacy Policy. If and when we implement it, we will configure and use it in accordance with applicable privacy and consent requirements.

Advertising and tracking technologies

We may introduce Meta Pixel or similar technologies in the future to:

• Measure conversions from Facebook and Instagram advertising;
• Understand the effectiveness of advertising campaigns;
• Create or support remarketing/retargeting audiences;
• Measure website interactions following advertising activity; and
• Improve our advertising.

Where applicable law requires consent before such non-essential tracking technologies are activated, we will provide an appropriate consent mechanism.

Our use of cookies and similar technologies is further described in our Cookie Policy.

8. Google Analytics

We may use Google Analytics in the future to analyse website traffic and user interactions.

If implemented, Google Analytics may collect information such as:

• Device information;
• Browser information;
• IP-related information;
• Website interactions;
• Pages visited;
• Traffic sources;
• Approximate geographic information; and
• Other analytics information.

We may use this information to understand website performance, improve our website and evaluate our marketing activities.

Where required, we will obtain appropriate consent before activating non-essential analytics cookies or technologies.

Google may process information according to its own privacy terms and policies.

9. Meta Pixel and Advertising Technologies

We may implement Meta Pixel or similar advertising technologies in the future.

If implemented, these technologies may help us:

• Measure conversions resulting from Facebook and Instagram advertisements;
• Determine whether advertising campaigns are effective;
• Understand website activity following an advertisement;
• Build or support remarketing audiences;
• Improve advertising campaigns; and
• Deliver or measure relevant advertising where permitted.

Where required by applicable law, we will obtain consent before activating non-essential advertising or tracking technologies.

The processing of information by Meta will also be subject to Meta's applicable privacy terms and policies.

10. How We Use Your Personal Data

We may process your personal data for the following purposes:

Responding to enquiries

We may use your information to respond to questions, requests and enquiries.

Providing services

We may process your information to:

• Understand your business needs;
• Prepare proposals and quotations;
• Provide social media management services;
• Provide digital marketing services;
• Provide advertising services;
• Provide consultations;
• Communicate with you about your project;
• Manage client relationships; and
• Fulfil our contractual obligations.

Processing purchases

We may use transaction information to:

• Confirm purchases;
• Provide purchased services or products;
• Process invoices;
• Provide customer support;
• Maintain transaction records; and
• Resolve payment or purchase-related issues.

Delivering digital products and resources

Where you purchase a digital product or resource through a third-party platform such as Selar, your information may be processed by the relevant platform for transaction, delivery, account management and related purposes.

Email marketing

Where permitted by applicable law and, where required, based on your consent, we may use your information to:

• Send newsletters;
• Deliver free resources;
• Send educational content;
• Announce webinars or events;
• Promote courses and training;
• Promote digital products;
• Promote services;
• Share offers;
• Send business updates; and
• Measure engagement with our communications.

Website improvement

We may process technical and usage information to understand how visitors interact with our website and improve its functionality.

Security and fraud prevention

We may process information to:

• Protect our website;
• Detect suspicious activity;
• Prevent fraud;
• Protect our business and users;
• Investigate security incidents; and
• Maintain the integrity of our systems.

Legal and regulatory compliance

We may process information where necessary to comply with legal, regulatory, tax, accounting or other lawful obligations.

11. Lawful Bases for Processing

We will process personal data only where we have an appropriate lawful basis under applicable law.

Depending on the circumstances, these bases may include:

Consent

We may process personal data based on your consent.

Examples may include:

• Subscribing to certain marketing communications;
• Non-essential cookies;
• Analytics technologies where consent is required;
• Advertising/retargeting technologies where consent is required; or
• Other optional processing activities.

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing that took place before withdrawal.

Contract

We may process personal data where necessary to enter into or perform a contract with you.

For example, if you engage TM Digital Biz Services for social media management, advertising or another service, we may need your contact and business information to perform the agreement.

Legal obligation

We may process personal data where necessary to comply with a legal or regulatory obligation.

Legitimate interests

Where permitted by applicable law, we may process personal data where necessary for our legitimate interests, provided those interests do not override applicable rights and freedoms.

This may include:

• Website security;
• Fraud prevention;
• Business administration;
• Maintaining business records;
• Improving our services;
• Managing existing client relationships;
• Protecting our legal rights; and
• Measuring business performance.

Other lawful bases

Where applicable, we may rely on another lawful basis recognised by the NDPA or another applicable data-protection law.

12. Direct Marketing

We may send marketing communications to individuals who have requested information, subscribed to our mailing list, purchased our products/services, or otherwise have a lawful basis for receiving relevant communications.

Marketing communications may include:

• Email newsletters;
• Educational content;
• Digital products;
• Courses and training;
• Events and webinars;
• Service announcements;
• Promotions; and
• Other TM Digital Biz Services offerings.

Where applicable law requires consent, we will obtain consent before sending direct marketing.

You may unsubscribe from marketing communications at any time by:

• Using the unsubscribe link included in an email;
• Adjusting your communication preferences; or
• Contacting us at info@tmdigitalbizservices.com.

Opting out of marketing does not prevent us from sending necessary non-marketing communications relating to transactions, contracts, security, legal matters or services you have requested.

13. Mailchimp

We may use Mailchimp as our email marketing and communication platform.

If you subscribe to our mailing list or otherwise receive marketing communications through Mailchimp, information such as your name, email address and interaction with our communications may be processed through Mailchimp.

Depending on our configuration and the features we use, this may include information about whether emails were opened or links were clicked.

We may use this information to understand engagement and improve our communications.

Mailchimp may process personal data in accordance with its own privacy policy and terms.

Where consent is required, we will obtain the appropriate consent before adding you to relevant marketing communications.

14. WhatsApp

Our website may include a “Chat with us on WhatsApp” button.

If you choose to contact us through WhatsApp, your telephone number, profile information, messages and other information you voluntarily provide may be processed through WhatsApp and may be accessible to TM Digital Biz Services.

WhatsApp is operated by a third party and has its own terms and privacy practices.

You are not required to use WhatsApp to contact us. You may instead contact us by email or other available communication channels.

15. Calendly and Consultation Bookings

We may introduce Calendly or another scheduling service for consultation and appointment bookings.

Calendly is not currently represented as an active service merely because it is identified in this Privacy Policy.

If implemented, a scheduling service may process information such as:

• Name;
• Email address;
• Telephone number;
• Appointment date and time;
• Meeting type;
• Information you provide when booking; and
• Other information necessary to arrange the appointment.

The applicable scheduling provider may process this information according to its own privacy policy.

Where required, we will provide appropriate privacy information at the point of booking.

16. Payment Processing

TM Digital Biz Services may use third-party payment providers, including Paystack and Flutterwave, for payment of agency services.

When you make a payment, the payment provider may process information necessary to complete the transaction.

This may include:

• Name;
• Email address;
• Transaction details;
• Amount paid;
• Payment status;
• Transaction reference;
• Payment method information; and
• Other information required to process or verify the transaction.

Payment card details and other payment credentials may be handled directly by the relevant payment provider rather than being stored directly by TM Digital Biz Services.

Paystack and Flutterwave have their own privacy policies, terms and security practices.

We may retain transaction information necessary for accounting, customer service, legal, tax and business-record purposes.

17. Selar and Digital Products

We may use Selar to sell or deliver courses, digital products, downloadable resources or other digital offerings.

Where you purchase a product through Selar, information required to complete the purchase and provide the product may be processed by Selar.

This may include:

• Name;
• Email address;
• Purchase information;
• Transaction information;
• Product purchased;
• Account information; and
• Information necessary to provide customer support.

Selar may process your information in accordance with its own terms and privacy policy.

Where the transaction occurs through a third-party platform, that platform's privacy notice may also apply.

18. Third-Party Service Providers

We may engage third-party service providers to support our business and website.

Depending on the services we use, these providers may include:

• Website hosting providers;
• Website security providers;
• Google and Google services;
• Meta;
• Mailchimp;
• WhatsApp;
• Calendly;
• Paystack;
• Flutterwave;
• Selar;
• Analytics providers;
• Cloud-storage providers;
• Email providers;
• Form providers;
• Professional advisers;
• IT and technical service providers; and
• Other service providers reasonably necessary for operating our business.

We will seek to use third parties that provide appropriate privacy and security protections and, where required, establish appropriate contractual arrangements with processors.

We do not sell your personal data to third parties.

19. Sharing Your Personal Data

We may disclose personal data to third parties where reasonably necessary and lawful.

This may include:

Service providers

Third-party providers that perform services on our behalf.

Professional advisers

Lawyers, accountants, auditors, insurers, consultants or other professional advisers where necessary.

Government and regulatory authorities

Where disclosure is required by law, regulation, court order or lawful governmental request.

Legal proceedings

Where necessary to establish, exercise or defend legal rights or claims.

Business transactions

If TM Digital Biz Services is involved in a merger, acquisition, restructuring, financing, sale of assets or similar transaction, relevant personal data may be transferred as part of the transaction, subject to applicable law.

We will not disclose personal data merely because it is convenient to do so. Disclosure will be based on an appropriate lawful basis and limited to what is reasonably necessary for the relevant purpose.

20. International Transfers of Personal Data

Because TM Digital Biz Services serves clients and website users internationally and uses technology providers that may operate in different countries, your personal data may be processed or stored outside Nigeria.

For example, some technology providers used by our website, marketing, communications, payment or digital-product infrastructure may operate or maintain infrastructure outside Nigeria.

Where personal data is transferred internationally, we will take appropriate measures required by applicable data-protection law.

Depending on the circumstances, this may include:

• An adequacy decision or recognised adequate level of protection;
• Appropriate contractual safeguards;
• Approved transfer mechanisms;
• Binding contractual arrangements;
• Other safeguards recognised by applicable law; or
• Another lawful basis for the transfer.

The NDPC's current framework addresses cross-border transfers and requires appropriate safeguards and consideration of the mechanism used for international transfers.

Where a third-party provider independently determines its own processing purposes and means, its own privacy policy may also govern its processing.

21. Data Retention

We will retain personal data only for as long as reasonably necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law.

Different categories of information may have different retention periods.

For example:

• Enquiry information may be retained for a period necessary to respond to the enquiry and manage the relevant business relationship;
• Client records may be retained for the duration of the relationship and for an appropriate period afterwards for contractual, accounting, legal or dispute-resolution purposes;
• Transaction records may be retained as required for accounting, tax and legal purposes;
• Marketing information may be retained while you remain subscribed or until you withdraw consent, subject to lawful exceptions;
• Security and technical logs may be retained for periods reasonably necessary for security and operational purposes.

When personal data is no longer reasonably required, we will take reasonable steps to delete, securely destroy or anonymise it.

22. Your Rights as a Data Subject

Subject to applicable law and any lawful limitations, you may have rights including:

Right to be informed

You have the right to receive clear information about how your personal data is collected and processed.

Right of access

You may request access to personal data we hold about you and information concerning how it is processed.

Right to rectification

You may request correction of inaccurate, incomplete or outdated personal data.

Right to object

You may object to certain processing of your personal data where permitted by law.

This includes certain direct marketing activities.

Right to restriction of processing

In applicable circumstances, you may request that processing of your personal data be restricted.

Right to erasure

In applicable circumstances, you may request deletion of your personal data.

This is sometimes referred to as the “right to be forgotten”.

Right to data portability

Where applicable, you may request certain personal data in a structured, commonly used and machine-readable format and, where technically feasible and legally required, request transmission to another organisation.

Right to withdraw consent

Where we process your personal data based on consent, you may withdraw that consent.

Rights relating to automated decision-making

Where applicable, you may have rights relating to decisions based solely on automated processing that produce legal or similarly significant effects.

Right to lodge a complaint

You may lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority where applicable.

The NDPC identifies these rights, including access, rectification, objection, restriction, portability, erasure, withdrawal of consent and rights relating to automated decision-making.

23. How to Exercise Your Data Rights

To exercise an applicable data-protection right, contact us:

Email: info@tmdigitalbizservices.com
Telephone/WhatsApp: 07015060410

Please include:

• Your full name;
• Email address or other identifier associated with your interaction with us;
• The nature of your request; and
• Any information reasonably necessary for us to identify the relevant personal data.

We may need to verify your identity before providing access to personal data or completing certain requests.

This is intended to protect your information from being disclosed to an unauthorised person.

We will handle valid requests within the timeframe required by applicable law.

Some rights are subject to legal exceptions and limitations.

24. Withdrawing Marketing Consent

If you have consented to receive marketing communications from us, you may withdraw that consent at any time.

You may do so by:

• Clicking “unsubscribe” in our marketing emails;
• Contacting us at info@tmdigitalbizservices.com; or
• Contacting us through another official communication channel.

Withdrawal of marketing consent will not affect processing that was lawful before your withdrawal.

It will also not necessarily stop non-marketing communications that are necessary to provide a service, administer an account, complete a transaction, enforce a contract or comply with legal obligations.

25. Data Processing for Our Clients

TM Digital Biz Services provides social media management, digital marketing, advertising, strategy and related services to businesses and organisations.

In performing these services, our clients may provide us with personal data belonging to their customers, prospects, employees, followers, leads or other individuals.

Where the client determines why and how such personal data is processed, TM Digital Biz Services may process that data on the client's behalf.

In those circumstances:

• The client may be the relevant data controller;
• TM Digital Biz Services may act as a data processor;
• Processing may be governed by our service agreement and, where appropriate, a Data Processing Agreement;
• We will process personal data in accordance with applicable instructions and contractual obligations; and
• We will apply reasonable technical and organisational safeguards.

This Privacy Policy primarily governs personal data that TM Digital Biz Services processes for its own purposes. Client-specific processing may also be governed by the relevant client agreement and data-processing documentation.

26. Client Confidentiality

When you engage TM Digital Biz Services, you may provide confidential business or marketing information.

Such information may include:

• Business strategies;
• Marketing plans;
• Customer information;
• Social media information;
• Advertising information;
• Business documents;
• Campaign information;
• Business goals; and
• Other confidential information.

We will use such information for legitimate purposes connected with providing our services, managing the business relationship, complying with applicable law or as otherwise permitted by our agreement with you.

Where appropriate, confidentiality and data-processing obligations may also be contained in a separate contract or agreement.

27. Testimonials, Photographs and Client Content

We may request permission to use testimonials, reviews, photographs, videos, screenshots, logos, case studies or other content provided by clients, students or other individuals.

Where identifiable personal data is involved, we will seek appropriate permission or rely on another lawful basis where applicable.

If you provide a testimonial or other content voluntarily for publication, you should understand that content published publicly may be viewed by people worldwide.

You may contact us regarding future use of content where withdrawal is legally applicable.

28. Children's Privacy

Our website is not specifically directed toward children.

We do not knowingly seek to collect personal data from children in circumstances where doing so is not permitted by applicable law.

If we become aware that personal data belonging to a child has been collected improperly, we will take reasonable steps to investigate and address the situation.

Where a particular programme or service is intended for minors, we will implement appropriate safeguards and obtain any consent or authorisation required by applicable law.

29. Third-Party Websites

Our website may contain links to third-party websites, platforms and services.

These may include:

• Selar;
• Paystack;
• Flutterwave;
• Google;
• WhatsApp;
• Calendly;
• Social media platforms;
• TM Digital Academy;
• Other websites or services.

When you follow a link to a third-party website, your use of that website is governed by its own terms and privacy policy.

We do not control the privacy practices of third-party websites.

You should review the privacy policy of any third-party platform before submitting personal information.

30. TM Digital Academy

TM Digital Biz Services may provide links from this website to TM Digital Academy or other websites operated by us.

Training registration and related activities may take place on the TM Digital Academy website rather than directly on the TM Digital Biz Services website.

Where a separate privacy notice applies to TM Digital Academy, that notice will govern the relevant processing activities carried out through the Academy website.

Visitors should review the applicable privacy notice before submitting information through the Academy website.

31. Data Security

We take reasonable technical and organisational measures to protect personal data against:

• Unauthorised access;
• Unauthorised disclosure;
• Accidental loss;
• Destruction;
• Alteration;
• Misuse;
• Unlawful processing; and
• Other reasonably foreseeable security risks.

Depending on the nature of the information and processing activity, security measures may include:

• Access controls;
• Password protection;
• Restricted access to personal data;
• Secure hosting;
• Authentication controls;
• Software and security updates;
• Backups;
• Monitoring;
• Secure service-provider arrangements; and
• Staff or contractor confidentiality obligations.

No electronic transmission or storage system can be guaranteed to be completely secure.

Accordingly, while we take reasonable measures to protect personal data, we cannot guarantee absolute security.

32. Personal Data Breaches

If we become aware of a personal-data breach, we will assess the incident and take appropriate steps to contain, investigate and remediate it.

Where applicable law requires notification to the NDPC or affected data subjects, we will make the required notifications within the applicable legal timeframe.

The current Nigerian data-protection framework provides specific requirements concerning breach assessment, notification and response.

33. Your Responsibility

You should ensure that information you provide to us is accurate and, where necessary, kept up to date.

Where you provide personal data belonging to another individual, you should ensure that you have the lawful authority or appropriate basis to provide that information to us.

For example, if you submit a customer's contact details to TM Digital Biz Services as part of a marketing campaign, you are responsible for ensuring that the collection and disclosure of that information to us is lawful.

34. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Changes may occur because of:

• Changes to our business;
• New services;
• New technologies;
• Changes to our website;
• Changes to third-party providers;
• Changes in the way we process personal data;
• Changes to applicable laws or regulations; or
• Improvements to our privacy practices.

When we make changes, we will update the “Last Updated” date at the top of this Privacy Policy.

Where a change materially affects your rights or the way we process your personal data, we will provide additional notice where required by applicable law.

35. Governing Law

This Privacy Policy is primarily governed by the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act 2023 and applicable data-protection regulations, directives and guidance.

Where mandatory data-protection laws of another jurisdiction apply to the processing of your personal data, those laws may also apply to the extent required.

36. Questions, Requests and Privacy Complaints

If you have a question, concern, complaint or request relating to your personal data or this Privacy Policy, please contact us first.

TM Digital Biz Services

Legal Name: TM Digital Biz Services
Company Type: Private Company Limited by Shares
CAC Registration No.: 9677847
Website: www.tmdigitalbizservices.com
Email: info@tmdigitalbizservices.com
Phone/WhatsApp: 07015060410
Address: Nigeria.

We will review privacy complaints and requests and take reasonable steps to resolve legitimate concerns.

If you are dissatisfied with our response or believe your data-protection rights have been infringed, you may have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), Nigeria's data-protection supervisory authority. The NDPC expressly provides data subjects with a right to report concerns to the Commission.

37. Acknowledgement

By using our website, you acknowledge that you have had the opportunity to read this Privacy Policy.

Where applicable law requires us to obtain your consent for a particular processing activity, we will obtain that consent through an appropriate mechanism.

Your use of our website does not, by itself, constitute consent where applicable law requires a separate consent mechanism.

© 2026 TM Digital Biz Services. All rights reserved.