How SALCOMMS collects, uses, stores, and shares personal data.

1. Who we are and how to reach us

This website (shinasalako.com) is operated by SALCOMMS KWIK XTRA LIMITED, a private limited company registered in Nigeria. For the purposes of applicable data protection law, SALCOMMS KWIK XTRA LIMITED is the data controller.

Questions about this policy, or requests to exercise any of the rights described below, should be sent to privacy@shinasalako.com or by post to the registered office address available on request from the same email.

2. What personal data we collect

We collect the following categories of personal data, and only when you provide it to us through the website or related communications:

Data you give us directly through forms

• Identity data: name, role/job title, organisation name.
• Contact data: email address (work email preferred for most forms).
• Operational context: fleet size, seat (cargo-owner or transporter), free-text context about your operation that you choose to share on enquiry forms.
• Transactional data: when you purchase a book or book a training seat, the data required to process the transaction. Card details are never handled by SALCOMMS — they are processed directly by our payment providers (see section 5).

Data collected automatically

• Usage data: pages viewed, time spent, referring source, device type, broad geographic location (country and city, not street address), browser type. Collected via Google Analytics 4 and LinkedIn Insight Tag (see section 6).
• Technical data: IP address, anonymised for analytics; cookie identifiers.

Data we do not collect

We do not knowingly collect special-category personal data (health information, racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data, sexual orientation). If you accidentally include this information in a free-text form field, please tell us at privacy@shinasalako.com and we will remove it.

3. How we use that data

We use personal data for the following purposes only:

• To deliver the asset you have requested — the First Look PDF, the maturity-assessment results report, training programme materials, the book you purchased.
• To respond to enquiries you have sent to us via a form or by email.
• To process transactions for the book and the training programmes.
• To send you the quarterly practitioner note from the author, if you have opted in.
• To send transactional emails relating to a training programme you have booked (calendar invites, balance invoices, pre-work, reminders).
• To analyse aggregate website usage and improve the operating experience of the site.
• To comply with applicable legal obligations.

We do not sell, rent, or trade personal data with any third party, ever, under any circumstance.

4. The legal basis for processing

Under the Nigeria Data Protection Regulation (NDPR) 2019 and Data Protection Act 2023, and under the EU General Data Protection Regulation (GDPR) for any visitors in the EEA, we rely on the following legal bases:

• Consent: when you submit a form (e.g. the First Look opt-in), you are giving consent for us to use your data for the purpose stated on that form. You may withdraw consent at any time.
• Contract: when you purchase a book or book a training seat, processing your data is necessary to fulfil that contract.
• Legitimate interest: for aggregate analytics, replying to enquiries you have initiated, and protecting the site against fraud. We have balanced these interests against your privacy rights and consider them appropriate.
• Legal obligation: where we are required by law to retain certain records (for example, tax records for transactions).

5. Who we share data with

We share personal data with the following categories of trusted sub-processors, each bound by data protection terms. The current list is:

• Email platform — REPLACE_WITH_PLATFORM (e.g. MailerLite, SendGrid): for delivering the First Look PDF, the quarterly note, and transactional emails for training cohorts.
• Form backend — REPLACE_WITH_BACKEND (e.g. Formspree, Basin): for receiving and routing form submissions from the website.
• Payment processors: Paystack (for naira transactions) and Stripe (for dollar transactions). When you make a payment, you are interacting directly with these providers. SALCOMMS never sees your card details.
• Hosting — REPLACE_WITH_HOST (e.g. Cloudflare, Vercel, Netlify): for serving the website itself.
• Analytics — Google (Google Analytics 4) and LinkedIn (Insight Tag): for aggregate usage analytics. See section 6 for cookie detail.

We may also disclose personal data where required by law, court order, or to protect our legal rights. We do not disclose for any other purpose.

6. Cookies and analytics

The site uses cookies and similar technologies for the following purposes only:

• Strictly necessary: cookies that make the site work (for example, remembering whether you have dismissed the cookie banner). Cannot be disabled.
• Analytics: Google Analytics 4 cookies that help us understand which pages are read, what is shared, and where readers come from. Set only with consent where consent is legally required.
• Marketing measurement: the LinkedIn Insight Tag, used to measure the conversion of LinkedIn campaigns. Set only with consent where consent is legally required.

You can withdraw cookie consent at any time by clearing the site's cookies in your browser. Your browser also gives you the option to block all cookies — the site will continue to work for reading and form submission if you do.

7. How long we keep data

We keep personal data for the following periods, then delete or anonymise it:

• Email list: as long as you remain subscribed, plus 30 days after you unsubscribe (so we can honour the unsubscribe and not accidentally re-add you).
• Enquiry data (contact form, scoping calls, in-house enquiries): 24 months from last interaction, then deleted.
• Transaction records (book sales, training cohort bookings): seven years, as required by Nigerian tax record-keeping rules.
• Analytics data: retained at aggregate level for 26 months in Google Analytics, then auto-deleted.

8. How we protect data

We use industry-standard technical and organisational measures to protect personal data — HTTPS encryption across the entire site, encrypted-at-rest databases at our sub-processors, multi-factor authentication on all administrative access, regular security review of the operating stack. Despite these measures, no system on the internet is fully secure, and we cannot guarantee absolute security. If we become aware of a personal data breach that creates a risk to you, we will notify you and the Nigeria Data Protection Commission (and, where applicable, the relevant EU supervisory authority) without undue delay.

9. International data transfers

SALCOMMS is established in Nigeria. Some of our sub-processors are established in other jurisdictions — notably the United States and the European Union. Where we transfer personal data to these providers, we rely on the appropriate transfer mechanisms (Standard Contractual Clauses for EEA-originated data, sub-processor agreements for NDPR-governed data) and on the recipient's own data-protection certifications.

10. Your rights

Under the NDPR / Nigeria Data Protection Act 2023 and the GDPR, you have the following rights regarding your personal data:

• Access: request a copy of the personal data we hold about you.
• Rectification: ask us to correct data that is inaccurate or incomplete.
• Erasure: ask us to delete data we hold about you, subject to legal retention obligations.
• Restriction: ask us to restrict processing in certain circumstances.
• Portability: receive a copy of your data in a machine-readable format.
• Objection: object to processing based on legitimate interest.
• Withdraw consent: withdraw any consent you have previously given.
• Complain: lodge a complaint with the Nigeria Data Protection Commission (or your local supervisory authority).

To exercise any of these rights, write to privacy@shinasalako.com. We will respond within 30 days. There is no charge for exercising your rights — except in exceptional circumstances permitted by law.

11. Children

The site is built for senior practitioners in the fleet and logistics industry. It is not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected such data, please write to privacy@shinasalako.com and we will delete it.

12. Changes to this policy

We will update this policy from time to time as the site, the sub-processor list, or applicable law changes. The effective date at the top of the page indicates the most recent revision. For material changes, we will notify subscribers to the newsletter and post a prominent notice on the homepage for at least 30 days.

If anything in this policy is unclear, or you would like to discuss any aspect of how we handle your data, please write to privacy@shinasalako.com. We will respond in plain English.