Legal
Privacy Policy
This Privacy Policy explains how Joche Solutions Ltd ("we", "us", "our") collects, uses, stores, shares and protects personal data of users ("you") of the Joche Gauntlet platform (the "Platform"), available at gauntlet.jocheacademy.com. We comply with the Nigeria Data Protection Act 2023 (NDPA) and applicable regulations issued by the Nigeria Data Protection Commission (NDPC).
1. Who we are
Joche Solutions Ltd is a private company limited by shares incorporated in the Federal Republic of Nigeria under the Companies and Allied Matters Act 2020, registration number RC 9650706. For any privacy questions, contact us at gauntlet@jocheacademy.com.
2. Information we collect
2.1 Information you provide
Account details (full name, email, password), profile data, payment references via Paystack, and submissions you make to challenges.
2.2 Information collected automatically
Device and browser information, IP address, pages visited, timestamps, and cookie identifiers.
2.3 Information from third parties
Payment confirmations from Paystack and, where you sign in using a social provider, basic profile information from that provider.
3. How we use your information
| Purpose | Lawful basis |
|---|---|
| Create and operate your account | Performance of a contract |
| Process winner prize payouts | Performance of a contract |
| Score submissions and publish leaderboards | Performance of a contract |
| Detect fraud and protect the integrity of the Gauntlet | Legitimate interests |
| Send transactional emails | Performance of a contract |
| Send marketing emails | Consent (you can opt out at any time) |
| Comply with legal obligations | Legal obligation |
4. Sharing your information
We share personal data only with:
- Payment processor - Paystack.
- Cloud infrastructure providers used to host the Platform.
- Analytics providers used to understand and improve the Platform.
- Law enforcement or regulators where legally required.
5. International transfers
Where data is transferred outside Nigeria, we rely on adequacy decisions, standard contractual clauses, or your explicit consent, in line with the NDPA.
6. How long we keep your data
| Data category | Retention period |
|---|---|
| Account data | Until you delete your account + 30 days |
| Payment records of prizes actually paid (payout amount, reference, beneficiary bank details) | 7 years (Companies Income Tax Act / CAMA tax & accounting), retained even after account deletion |
| Identity verification (KYC) of paid winners | 5 years after the payout (anti-money-laundering / CBN due diligence). KYC of users who were never paid is erased on account deletion. |
| Records under an active legal hold (dispute, fraud or law-enforcement matter) | Retained until the matter is resolved, then erased |
| Submissions & leaderboard history | Indefinitely as part of public Gauntlet archive |
| Support correspondence | 3 years |
When you delete your account it is deactivated straight away and permanently erased after a 30-day grace period, during which signing back in reactivates it. At erasure we remove your personal data, except records the law requires us to keep for the periods above: the financial records of any prize we actually paid you, and the identity documents of paid winners for anti-money-laundering purposes. These are kept only for as long as the law requires and are not used for any other purpose.
7. Your rights
Under the NDPA you have the right to access, rectify, erase, restrict, port and object to processing of your personal data, and to withdraw consent at any time. To exercise any right, email gauntlet@jocheacademy.com. You may also lodge a complaint with the Nigeria Data Protection Commission at ndpc.gov.ng.
8. Security
We use industry-standard safeguards including TLS encryption in transit, encryption at rest, role-based access controls, and regular security reviews. No system is 100% secure - please use a strong, unique password.
9. Cookies
We use essential cookies to keep you signed in and analytics cookies to improve the Platform. You can manage your choice through the cookie banner shown on first visit, and via your browser settings.
10. Children
The Platform is not directed at children under 18. We do not knowingly collect data from minors. If you believe a minor has used the Platform, contact gauntlet@jocheacademy.com.
11. Changes to this policy
We may update this Privacy Policy from time to time. The "Last updated" date above reflects the latest revision. Material changes will be communicated by email or via a banner on the Platform.
12. Contact
Joche Solutions Ltd (RC 9650706)
Email: gauntlet@jocheacademy.com