Effective date: 16 October 2026
Last reviewed: 16 October 2026
1. Who we are
Citizens Liberation Advocacy Initiative ("CLAI", "we", "us" or "our") is a Nigerian corporate body registered with the Corporate Affairs Commission under registration number 59280. CLAI carries out civic advocacy, voter education, public enlightenment, community engagement and related programmes.
For the processing described in this Policy, the data controller is:
Citizens Liberation Advocacy Initiative
50, Sunmonu Street, Oke-Ira, Ogba, Ikeja, Lagos Nigeria
Email: admin@citizensliberation.com
Our Privacy Officer is:
Samuel Oreduni Esq.
14b Adeniyi Jones, Ikeja, Lagos, Nigeria
Email: admin@citizensliberation.com
Please use the subject line Privacy Request.
This Policy is intended to meet the transparency requirements of the Nigeria Data Protection Act 2023 ("NDP Act") and the Nigeria Data Protection Act General Application and Implementation Directive 2025 ("GAID").
2. Scope
This Policy explains how CLAI handles personal data when a person:
- visits citizensliberation.com;
- sends a general, voters' rights support or partnership enquiry;
- contacts CLAI by email, telephone, SMS or WhatsApp;
- applies for, holds or ends membership;
- creates or uses a member account;
- volunteers, attends an event or takes part in a CLAI programme;
- subscribes separately to news, campaign updates or event invitations;
- appears in a photograph, recording, testimonial or programme report used by CLAI; or
- exercises a privacy right or makes a complaint.
Additional short notices may be displayed at the point of collection. If a specific notice conflicts with this Policy, the more specific notice applies to that activity to the extent permitted by law.
3. Personal data we may collect
We collect only the information reasonably needed for a stated purpose.
3.1 Website and technical information
CLAI currently understands the Site's web hosting and related email service to be supplied through IONOS. For products covered by IONOS's published Web Hosting data-processing notice, IONOS says its systems process an anonymised IP address, referrer, requested file, browser and operating-system information, device type and access time for security, stability and quality, retain that visitor data for eight weeks, and do not transfer it outside the European Union. Applicability to CLAI's account, the email service, contracting entity and account-specific settings remains under verification. WordPress and approved security tools may also record login, error and security-event information and use necessary session, login and security cookies for users who sign in.
3.2 Enquiries and correspondence
An activated website enquiry form may request a full name, email address, optional phone number and the message a person chooses to send. We also process the contact details, account identifiers, correspondence and delivery metadata contained in communications sent by email, telephone, SMS or WhatsApp.
Please provide only information necessary for the enquiry. Do not send a voter card, NIN, passport, driver's licence, other identity document, financial credential, medical record or another person's confidential information through a general form, email or WhatsApp.
3.3 Membership applications and member accounts
When online membership applications are enabled, the approved application may request:
- name;
- email address and phone number;
- state or FCT, Local Government Area or Area Council, and town or community, but not a house number or full street address;
- preferred contact method and, where relevant, chapter preference;
- reason for applying, civic interests, preferred forms of participation and availability;
- optional occupation, skills, languages and relevant volunteering experience;
- declarations that the applicant is a Nigerian national, is at least 18 years old, has provided accurate information, accepts the Membership Rules and has read this Policy; and
- a separate, optional choice about promotional communications.
For approved members, we may also process a username, password hash, membership status, account preferences, chapter or programme assignment, participation history, communications and records of decisions made under the Membership Rules.
CLAI's approved online membership process is designed not to request or accept:
- an exact date of birth;
- a voter-card, NIN, passport, driver's-licence or other identity-document number or image;
- a passport-style portrait or other registration photograph;
- a full residential or street address; or
- a political-party affiliation, voting intention or political opinion.
Do not place these items in a free-text box or send them by email or WhatsApp. An applicant confirms age and Nigerian nationality by declaration. If a material eligibility concern cannot be resolved through a less intrusive clarification, CLAI may pause or decline the application rather than collect an identity-document copy.
3.4 Participation, accessibility and events
For a programme, volunteer activity or event, we may collect registration and attendance details, role, availability, communications, emergency information where genuinely necessary, and accessibility arrangements requested by the participant. Accessibility information is optional, is restricted to personnel who need it to arrange support and is not used to decide membership eligibility.
3.5 Photographs, video and audio
The website contains leadership portraits and programme or event images. Where CLAI creates or publishes identifiable media, we will provide appropriate notice and use consent or another lawful basis suitable to the circumstances. We will use a parent or guardian process before intentionally publishing an identifiable image of a child. Some archive images supplied for the current gallery pre-date this Policy; CLAI is reviewing their source, caption and permission records and will remove or restrict any image for which an appropriate basis cannot be documented. Archive images will not be repurposed for paid advertising while that review is pending. A person who believes that an image or caption is inaccurate, unauthorised or creates a safety concern may contact the Privacy Officer to request review or removal.
3.6 Sensitive or unexpectedly supplied information
CLAI does not ask membership applicants for political opinions or affiliations and does not profile people on that basis. A free-text message may nevertheless contain sensitive information voluntarily supplied by its author. We will restrict access, use only what is necessary to address the matter, and delete or redact unnecessary material. Where applicable law requires explicit consent or another special condition for processing, we will obtain or document it before continuing.
4. How and why we use personal data
| Purpose | Typical data | Lawful basis |
|---|---|---|
| Deliver and secure the website; diagnose errors; prevent misuse | Technical and security data | CLAI's legitimate interest in operating a safe and reliable website; legal obligation where applicable |
| Receive and answer general or voters' rights support enquiries | Name, contact details and message | Steps requested by the person; CLAI's legitimate interest in responding to genuine enquiries |
| Consider partnership enquiries | Representative's name, work contact details, organisation and message | Steps requested before a possible arrangement; legitimate interest in responsible collaboration |
| Assess a membership application | Approved application information and declarations | Steps requested by the applicant before entering the membership relationship; legitimate interest in fair and safe membership administration |
| Administer membership and member accounts | Profile, status, account, participation and decision records | Performance of the membership arrangement; legitimate interest in administration, safeguarding and enforcing the Membership Rules |
| Arrange accessibility support | Support request and only necessary related information | The person's explicit consent, or another condition permitted for sensitive data where applicable |
| Send news, campaign updates and event invitations | Name, contact channel, subscription choices and engagement needed to honour the preference | Consent. This choice is optional and is not a condition of membership |
| Organise events, volunteering and programmes | Registration, attendance, contact and participation details | Steps requested by the participant; performance of the participation arrangement; legitimate interest in programme administration |
| Publish an identifiable testimonial, portrait or promotional image | Image, voice, name, role and approved caption | Consent, unless another lawful basis is clearly identified and notified before use |
| Keep records, respond to legal process, exercise or defend claims and meet regulatory duties | Relevant application, consent, decision, complaint, transaction and audit information | Legal obligation; legitimate interest in accountability and legal claims |
| Respond to privacy requests and investigate complaints or incidents | Identity and contact details, request, correspondence, verification and outcome | Legal obligation under data-protection law; legitimate interest in resolving issues and demonstrating compliance |
Where we rely on legitimate interests, we consider necessity, reasonable expectations and the possible effect on the individual. We will not rely on a legitimate interest that is overridden by the person's rights, freedoms and interests.
5. Consent and promotional communications
When consent is requested, any optional consent choice will be presented separately from required declarations and unticked by default; silence or inactivity will not count as consent.
A person may withdraw consent at any time by using an unsubscribe method in the message or by contacting admin@citizensliberation.com. Withdrawal does not affect processing already lawfully carried out. Withdrawal of optional consent will not affect membership. If a separate service requested by the person cannot be delivered without processing information genuinely necessary for that service and no other lawful basis applies, we will explain the consequence and stop only that service.
6. Cookies, member login and embedded media
The approved website design does not use advertising pixels or non-essential analytics cookies. WooCommerce source-attribution storage is disabled on the public Site while no approved shop or consent control is in use. If CLAI later introduces analytics, advertising, attribution or another non-essential technology, it will update this Policy and obtain any required opt-in consent before activating that technology.
| Technology | Purpose | Typical duration |
|---|---|---|
wordpress_test_cookie |
Checks whether the browser accepts cookies on the WordPress login page. | Session |
wordpress_sec_* and wordpress_logged_in_* |
Secures and maintains an authenticated account session. | Session, or normally up to 14 days where “remember me” is selected |
| WordPress or approved security/form tokens | Protects requested functions against misuse and forgery. | Session or the shortest configured security period |
Blocking necessary cookies may prevent login or another requested function from working.
Gallery videos are displayed through YouTube's privacy-enhanced domain only after a visitor selects Load video. Until then, the video iframe is not loaded by the CLAI page. Selecting the button requests the YouTube content and causes the visitor's browser to connect directly to Google/YouTube, which may receive the visitor's IP address, browser and device data and may process data outside Nigeria under its own terms. A visitor who does not want that connection should not load the video and may instead continue using the rest of the site.
7. Who may receive personal data
We do not sell or rent personal data. Personal data may be disclosed only where the purpose and recipient are authorised, including to:
- authorised CLAI officers, membership staff and authorised programme or chapter personnel;
- the hosting and related email service currently understood to be supplied through IONOS, and any later replacement provider approved for hosting, email, security or backup services under CLAI's instructions;
- approved form and membership-system providers used to deliver a function requested by the person;
- communications providers used by the person or chosen for an agreed communication, including Meta/WhatsApp where the person chooses WhatsApp;
- Google/YouTube when the person chooses to load an embedded video or follow a YouTube link;
- professional advisers, auditors or insurers where confidentiality and necessity are established;
- regulators, courts, law-enforcement bodies or other authorities where disclosure is required or permitted by law; and
- another person where the data subject has expressly requested or consented to the disclosure.
Before enabling a new provider to process personal data for CLAI, we will assess the service, limit the data supplied, and put appropriate contractual and security requirements in place. CLAI must verify and record the account-specific IONOS contracting entity, data-processing terms, backup cycle and applicable subprocessor information before activating public forms or membership applications. Those collection features remain inactive while that review is outstanding. A third party that independently decides how to use data is responsible for its own privacy notice.
8. Transfers outside Nigeria
For products covered by its published Web Hosting notice, IONOS states that the visitor data described in section 3.1 is not transferred outside the European Union; whether that notice applies to CLAI's account and related services remains under verification. Other online or communications providers may operate or store information outside Nigeria. Before CLAI enables a provider to process personal data on its behalf outside Nigeria, the Privacy Officer must document a transfer basis permitted under the NDP Act, such as an adequate protection mechanism, an approved transfer instrument or another lawful condition, and the appropriate safeguards. Information about a relevant transfer and safeguard may be requested from the Privacy Officer.
A visitor's decision to load YouTube or use an external communications service can also result in a direct connection between that visitor and the external provider. The notice shown before the connection explains the choice and should be read together with the provider's own notice.
9. Security and personal-data breaches
The current public Site uses encrypted web connections; public registration and public forms are disabled while processing controls are reviewed. Before CLAI activates membership applications or another material collection feature, it must verify named least-privilege accounts, multi-factor authentication where available, backup and deletion settings, system updates, incident logging, staff confidentiality duties and processor controls.
No online system is guaranteed to be completely secure. If a personal-data breach occurs, CLAI will contain and assess it, keep the required record, notify the Nigeria Data Protection Commission within 72 hours where the breach is likely to create a risk to people's rights and freedoms, and communicate without delay to affected people where the breach is likely to create a high risk, as required by law.
10. Retention and deletion
We keep personal data only while it is needed for the stated purpose, a legal duty, due diligence or the establishment, exercise or defence of legal claims. Our Data Retention Policy gives the detailed schedule.
Key periods include:
- for products covered by IONOS's public Web Hosting notice, visitor logs: eight weeks; applicability to CLAI's account remains to be verified and recorded;
- a CLAI-created security or incident extract: up to 90 days unless an unresolved incident, legal duty or legal claim requires a documented hold;
- an open enquiry: while it is being handled, then no more than six months after closure and in any event normally no more than 12 months after the last substantive contact;
- an incomplete stored membership application: 30 days after the last activity;
- an unsuccessful or withdrawn membership application: six months after the final decision or withdrawal;
- an active member's operational profile: for the membership period and up to six months after it ends;
- a CLAI-controlled manual or rolling backup: no more than 30 days unless isolated for a documented incident or legal hold; the provider recovery-copy cycle remains to be verified and recorded before forms or registration are enabled; and
- limited consent, complaint, disciplinary, incident or legal-claim evidence: up to six years where necessary for accountability, due diligence or legal claims.
When the applicable period ends, we securely delete, destroy or irreversibly anonymise the information, unless a documented legal hold applies.
11. Your rights
Subject to applicable law, a person may ask CLAI to:
- confirm whether we process their personal data and provide information about that processing;
- provide access to, and a copy of, their personal data;
- correct inaccurate, incomplete, out-of-date or misleading data;
- delete personal data that is no longer necessary or has no lawful basis;
- restrict processing while a request, objection or legal claim is resolved;
- stop processing based on an objection, including an unconditional objection to direct marketing;
- record withdrawal of consent;
- provide portable data where the right applies; and
- provide human review of a decision based solely on automated processing that has a legal or similarly significant effect.
CLAI does not make membership decisions solely by automated means and does not profile applicants by political opinion or party affiliation.
To exercise a right, email admin@citizensliberation.com with the subject Privacy Request, or write to the Privacy Officer at 14b Adeniyi Jones, Ikeja, Lagos, Nigeria. Describe the request and the CLAI interaction concerned.
We will acknowledge and respond as soon as reasonably possible and normally within 30 days after receiving the request and any information reasonably necessary to verify it. We will use a proportionate, least-intrusive verification method. Do not send a full identity-document image unless CLAI has first provided a specific secure process and explained why the document is necessary. We may redact information about another person and may refuse or limit a request only where the law permits; if so, we will explain the reason and available complaint route.
12. Children
The website's general civic information may be viewed by a broad audience, but CLAI online membership is restricted to people aged 18 or older. A child must not submit a membership application or create a member account. CLAI does not knowingly use the website to collect children's personal data for membership or direct marketing. If we learn that this has occurred, we will restrict and delete the information unless retention is required to protect the child, meet a legal duty or address a safeguarding matter.
A programme specifically involving people under 18 must use a separate safeguarding and parental-or-guardian consent process before collecting their personal data or publishing an identifiable image.
13. Complaints
Please first contact the Privacy Officer so that CLAI can investigate and try to resolve the matter promptly:
Samuel Oreduni Esq., Privacy Officer
14b Adeniyi Jones, Ikeja, Lagos, Nigeria
admin@citizensliberation.com
This does not limit the right to complain to the Nigeria Data Protection Commission or to seek another remedy available under law.
14. Changes to this Policy
We will review this Policy at least annually and when our processing, service providers or legal obligations materially change. The current version and effective date will be published on this page. Where a change would materially affect an existing consent or membership arrangement, we will provide an appropriate additional notice and obtain new consent where required.