Privacy Policy

1. Who we are

The Creative Startup (“we”, “us”, “our”) is a paid advertising agency operating from [Port Haucourt, NIGERIA]. We provide campaign management, video ad production, coaching and online courses.

This policy explains what personal information we collect when you use our website, contact us, buy from us or join our community — and what we do with it.

For the purposes of the Nigeria Data Protection Act 2023, we are the data controller for the information described below. Our contact details are at the end of this policy.

2. Information we collect

Information you give us

• When you contact us — usually by WhatsApp or email. This includes your name, phone number, email address, and whatever you tell us about your business.
• When you subscribe to our newsletter — your email address.
• When you join our community — your name, email address, and anything you choose to post or share there.
• When you buy from us — your name, contact details, and billing information. Card details are handled by our payment provider and are never stored by us.
• When we work together — access to your advertising accounts, business information, brand materials, and anything else you share with us so we can do the work.

Information collected automatically

• Usage data — pages visited, time spent, links clicked, and how you arrived at the site.
• Device and connection data — browser type, device type, operating system, approximate location and IP address.
• Advertising and analytics data — collected through cookies and tracking pixels. See section 5.

3. How we use your information

We do not sell your personal information, and we do not share it with third parties for their own marketing.

4. Our legal basis

We process personal information where:

• you have consented — for example, subscribing to the newsletter or accepting non-essential cookies;
• it is necessary to perform a contract with you — for example, delivering a package you have paid for;
• we have a legitimate interest — for example, responding to enquiries, securing the website, or understanding how it is used; or
• we are under a legal obligation — for example, keeping financial records.

5. Cookies and tracking

Our website uses cookies and similar technologies. Some are necessary for the site to work. Others help us understand how the site is used, or measure our advertising.

We currently use the following third-party tracking tools:

These tools set their own cookies and may share information with their providers, who operate outside Nigeria. Each provider publishes its own privacy policy governing what it does with that data.

You can block or delete cookies through your browser settings. Doing so may affect how parts of the site work.

6. Who we share information with

We share personal information with service providers who help us run the business. They may only use it to provide their service to us.

We may also disclose information where we are required to by law, or where it is necessary to establish, exercise or defend legal claims.

7. International transfers

Some of the providers listed above store or process data outside Nigeria. Where personal information is transferred abroad, we take reasonable steps to ensure it remains protected to a standard consistent with the Nigeria Data Protection Act 2023.

8. How long we keep it

We keep personal information only as long as we need it for the purpose it was collected, or as long as the law requires.

• Enquiries that go nowhere — [RETENTION PERIOD, e.g. 12 months]
• Client records — for the duration of the engagement and [RETENTION PERIOD] afterwards
• Financial records — as required by Nigerian tax and accounting law
• Newsletter subscribers — until you unsubscribe
• Community accounts — until you ask us to delete the account

9. Your rights

Under the Nigeria Data Protection Act 2023 you have the right to:

• ask what personal information we hold about you, and get a copy of it;
• have inaccurate information corrected;
• ask us to delete information where there is no good reason for us to keep it;
• object to processing based on our legitimate interests;
• withdraw consent at any time, where consent is the basis we rely on;
• ask us to restrict how we use your information while a concern is resolved; and
• complain to the Nigeria Data Protection Commission.

To exercise any of these, contact us using the details below. We will respond within the timeframe required by law.

10. Security

We take reasonable technical and organisational measures to protect personal information against loss, misuse and unauthorised access. No system is completely secure, and we cannot guarantee absolute security of information transmitted over the internet.

11. Children

Our services are intended for business owners and are not directed at children. We do not knowingly collect personal information from anyone under 18. If you believe we have, contact us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last changed. Where changes are significant, we will make that clear on the website.

13. Contact us

If you have a question about this policy or about how we handle your information: