Contents
- Introduction
- Information We Collect
- How We Use Your Information
- Legal Basis for Processing
- Information Sharing & Disclosure
- Donations & Payment Information
- Elections & Voting Data
- Alumni Directory & Profile Visibility
- Community Forum & User-Generated Content
- Cookies & Tracking Technologies
- Data Security
- Data Retention
- Your Rights
- Children's Privacy
- Third-Party Links
- Changes to This Policy
- Contact Us
1. Introduction
The Unity/Govt. College, Oye Alumni ("UGCOA," "we," "our," or "us") operates the alumni portal at www.ugcoa.com.ng (the "Portal"). This Privacy Policy describes how we collect, use, store, and protect personal information from our members, visitors, donors, and other users of the Portal.
By accessing or using the Portal โ including registering as a member, making a donation, participating in elections, using the community forum, or subscribing to our newsletter โ you acknowledge that you have read and understood this Privacy Policy.
UGCOA is the official alumni body for all graduates of Ekiti State Government College, Oye-Ekiti (formerly Ondo State Unity Secondary School, Oye-Ekiti). Our association is registered and operates under the laws of the Federal Republic of Nigeria.
2. Information We Collect
We collect different types of information depending on how you interact with the Portal:
a) Information You Provide Directly
| Activity | Data Collected |
|---|---|
| Member Registration | First name, surname, nickname (school name), email address, phone number, graduation set/year, country of residence |
| Member Profile | Profile photo, current occupation, employer, city/state of residence, biography, social media handles |
| Donations | Donor name, email, donation amount, payment reference, and transaction records |
| Event RSVP | Name, contact details, attendance preferences |
| Elections | Voter identity (verified member ID), vote selections (stored anonymously) |
| Community Forum | Posts, comments, replies, and any content you share publicly |
| Job Listings | Job title, description, company details, and contact information you choose to publish |
| Volunteer Registration | Name, skills, availability, and areas of interest |
| Newsletter Subscription | Email address |
| Contact/Feedback Forms | Name, email, message content |
b) Information Collected Automatically
When you visit the Portal, we may automatically collect:
- IP address and approximate geolocation
- Browser type, version, and operating system
- Pages visited, time spent, and navigation paths
- Referring URL (the page that linked you to us)
- Device type (desktop, mobile, tablet)
This information is collected through server logs and, where applicable, cookies and similar technologies (see Section 10).
c) Information from Third Parties
If you make a donation through a third-party payment gateway, we may receive transaction confirmation details (such as a payment reference, amount, and status) from the payment processor. We do not receive or store your full bank card details.
3. How We Use Your Information
We use the information we collect for the following purposes:
- Membership management: to register, verify, and maintain your alumni membership, and to populate the Alumni Directory
- Communication: to send you event invitations, newsletters, association announcements, and responses to your enquiries
- Events & reunions: to manage RSVPs, coordinate logistics, and communicate event details
- Elections & governance: to verify voter eligibility, conduct digital elections, and publish aggregated (non-identifying) results
- Fundraising & donations: to process contributions, issue acknowledgement receipts, and track campaign progress
- Career support: to facilitate job listings, mentorship matching, and professional networking among alumni
- Community engagement: to operate the forum, volunteer hub, and other collaborative features
- Portal improvement: to analyse usage patterns, fix technical issues, and improve the user experience
- Legal compliance: to meet record-keeping obligations and respond to lawful requests from authorities
4. Legal Basis for Processing
In accordance with the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act 2023 (NDPA), we process your personal data on the following lawful bases:
- Consent: When you register on the Portal, subscribe to our newsletter, or submit information through forms, you consent to our processing of that information for the stated purposes.
- Legitimate interest: We may process data where it is in the legitimate interest of the association โ for example, to maintain accurate membership records, improve Portal security, or communicate association activities to members.
- Contractual necessity: Where processing is necessary to fulfil our obligations to you as a registered member of UGCOA.
- Legal obligation: Where we are required by law to process or retain certain information.
6. Donations & Payment Information
All financial transactions on the Portal โ including donations to fundraising campaigns (such as the Classroom Renovation Project, Science Lab Equipment fund, and Scholarship Fund) โ are processed through reputable third-party payment gateways.
- We do not collect, store, or have access to your full credit/debit card numbers, bank account details, or payment PINs.
- We retain only transaction reference numbers, donation amounts, dates, and donor identification for record-keeping and accountability purposes.
- Payment processors are independent data controllers and are subject to their own privacy policies. We encourage you to review their policies before transacting.
7. Elections & Voting Data
The Portal includes a digital Election Portal that allows registered members to participate in association elections. We take the following measures to protect election integrity and voter privacy:
- Voter verification: Your membership status is verified before you are permitted to vote. This requires your member ID and associated credentials.
- Vote anonymity: Once verified, your individual vote selections are recorded anonymously. Your identity is not linked to your specific ballot choices in any stored record.
- Participation logs: We may retain a record that you participated in an election (i.e., that you voted), but not how you voted.
- Results: Only aggregated, non-identifying vote tallies are published.
8. Alumni Directory & Profile Visibility
The Alumni Directory is a core feature of the Portal, enabling graduates to find and reconnect with classmates. By registering, you agree that certain profile information may be visible to other logged-in members.
Default Visibility
The following fields are visible by default to logged-in members in the directory:
- Full name (first name and surname)
- Graduation set/year
- Country of residence
- Profession/occupation (if provided)
Optional / Controlled Visibility
The following are only displayed if you choose to make them visible in your profile settings:
- Profile photo
- Email address
- Phone number
- City/state of residence
- Employer/company
- Social media handles
- Biography
9. Community Forum & User-Generated Content
The Portal provides a community forum where members can share stories, discuss ideas, and engage with fellow alumni. Please be aware of the following:
- Any content you post on the forum (including your display name and profile photo) is visible to all registered members.
- Forum posts may be moderated by UGCOA administrators to ensure compliance with community guidelines.
- You are responsible for the content you post. Do not share sensitive personal information (such as bank details, National Identification Numbers, or passwords) in forum posts.
- UGCOA reserves the right to remove content that violates community guidelines, including content that is defamatory, abusive, or constitutes spam.
- Deleted posts may be retained in our backups for a limited period before being permanently removed.
11. Data Security
We take the security of your personal information seriously and employ the following measures:
- Encryption: Data transmitted between your browser and the Portal is protected using SSL/TLS encryption (HTTPS).
- Password protection: Member passwords are stored using industry-standard cryptographic hashing. We never store passwords in plain text.
- Access controls: Access to personal data is restricted to authorised UGCOA administrators and officers on a need-to-know basis.
- Regular backups: Portal data is backed up regularly to prevent loss due to technical failure.
- Server security: Our hosting environment is maintained with up-to-date security patches and firewall protections.
12. Data Retention
We retain personal information for as long as necessary to fulfil the purposes outlined in this policy:
- Member accounts: Your membership data is retained for as long as your account is active. If you request account deletion, we will remove your personal data within 30 days, except where we are legally required to retain it.
- Donation records: Transaction records are retained for a minimum of 6 years for financial accountability and audit purposes.
- Election records: Anonymised vote tallies are retained indefinitely as part of association governance records. Participation logs are retained for 2 years.
- Forum content: Posts remain on the forum until deleted by you or removed by a moderator. Backups containing deleted content are purged within 90 days.
- Newsletter subscriptions: Your email is retained until you unsubscribe.
- Server logs: Automatically collected data (IP addresses, browser info) is retained for up to 12 months.
13. Your Rights
Under the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR), you have the following rights regarding your personal data:
- Right of access: You may request a copy of the personal data we hold about you.
- Right to rectification: You may request correction of inaccurate or incomplete data. You can also update most of your profile information directly through your account settings.
- Right to erasure: You may request deletion of your personal data, subject to any legal obligations that require us to retain certain records.
- Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
- Right to data portability: You may request a copy of your data in a structured, commonly used format.
- Right to object: You may object to the processing of your data for specific purposes, including direct marketing.
- Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us using the details in Section 17 below. We will respond to your request within 30 days.
If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).
14. Children's Privacy
The UGCOA Portal is designed for alumni โ graduates of Ekiti State Government College, Oye-Ekiti โ and is not intended for use by children under the age of 16. We do not knowingly collect personal information from children under 16.
If we become aware that we have inadvertently collected personal data from a child under 16, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at the address in Section 17.
15. Third-Party Links
The Portal may contain links to external websites, including social media platforms, payment gateways, and partner organisations. These third-party sites have their own privacy policies, and we are not responsible for their content or data practices.
We encourage you to review the privacy policy of any external site before providing personal information.
16. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or association governance. When we make material changes:
- The updated policy will be posted on this page with a revised "Effective Date."
- For significant changes, we will notify registered members via email or a prominent notice on the Portal.
We encourage you to review this page periodically to stay informed about how we protect your information.
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Unity/Govt. College, Oye Alumni (UGCOA)
๐ Ekiti State Government College, Oye-Ekiti, Ekiti State, Nigeria
๐ www.ugcoa.com.ng
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