Privacy Policy
How Intern Router collects, uses, and protects your personal data under the Nigeria Data Protection Act 2023.
This Privacy Policy explains how Intern Router Services ("we", "us", or "our") collects, uses, discloses, and safeguards your personal data when you use Intern Router (the "Platform"). It is issued in accordance with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR) 2019, and applicable directives of the Nigeria Data Protection Commission (NDPC).
1.Who We Are (Data Controller)
- Data Controller: Intern Router Services, a Nigerian entity operating internrouter.com.ng.
- Data Protection Officer (DPO): dpo@internrouter.com.ng
- Postal address for data requests: Lagos, Nigeria (available on request).
- NDPC registration: Pending / Registered (to be updated upon completion).
2.Scope
- This Policy applies to all visitors, Students, Firms, and Administrators interacting with the Platform.
- It does not cover third-party sites or services linked from the Platform — those are governed by their own privacy policies.
3.Information We Collect
3.1 Account Information
- Email address, password (hashed), full name, phone number, role (student / firm / admin).
- For Google OAuth sign-up: name, email, and profile picture URL from Google.
3.2 Profile & Application Information
- Students: age, city, state, institution name and type, year of study, matriculation number, Microsoft Office skills, soft skills, areas of interest, internship duration and start month preferences, firm choices.
- Firms: firm name, NIESV registration number, address, location, specialisations, description, logo, intern slot count, deadline, contact details.
3.3 Documents & Payments
- CVs (PDF, optional, stored on Cloudinary).
- Application letters (PDF, optional, stored on Cloudinary).
- Payment proofs (image or PDF, stored on Cloudinary).
- Payer's full name as entered during Application.
- We DO NOT store card details, bank credentials, or any banking information. Payments are made via direct bank transfer outside our system.
3.4 Technical & Usage Data
- IP address, browser type and version, device type, operating system.
- Pages visited, time on page, referring URL, session duration.
- Cookie identifiers (see section 10).
- Logs of API requests and errors for security and debugging purposes.
4.Lawful Bases for Processing
Under NDPA 2023 s.25, we rely on the following lawful bases:
| Purpose | Lawful Basis |
|---|---|
| Account creation & authentication | Performance of contract |
| Application routing to chosen Firms | Performance of contract |
| Sending transactional emails (verification, application status) | Performance of contract |
| Sending marketing emails (opt-in only) | Consent (withdrawable at any time) |
| Verifying payment proofs | Performance of contract |
| Detecting fraud and securing the Platform | Legitimate interest |
| Aggregated analytics for product improvement | Legitimate interest |
| Compliance with NDPC / tax / regulatory obligations | Legal obligation |
5.How We Use Your Information
- To create and manage your account.
- To route your Application to your selected Firms (Students) or to deliver Applications to you (Firms).
- To verify payment proofs and process the Application Routing.
- To send transactional emails (verification, payment confirmation, application status updates, acceptance/rejection notifications).
- To respond to support requests.
- To detect, prevent, and investigate fraud, abuse, or security incidents.
- To improve the Platform through aggregated, de-identified analytics.
- To comply with legal obligations.
7.Sub-processors & Service Providers
| Provider | Purpose | Data Type | Location |
|---|---|---|---|
| Supabase | Authentication & database | Account & profile data | SG / EU |
| Cloudinary | File storage (CVs, letters, proofs) | Documents & images | United States |
| Vercel | Application hosting & edge delivery | Technical / usage data | United States |
| Resend | Transactional email delivery | Email, name | United States |
| OAuth sign-in (optional) | Email, name, profile picture | United States |
8.International Data Transfers
- Some of our sub-processors operate servers outside Nigeria. Under section 41 of the NDPA 2023, we transfer personal data internationally only where: (a) the recipient country provides adequate protection; or (b) standard contractual clauses or equivalent appropriate safeguards are in place; or (c) you have given explicit consent after being informed of the risks.
- We assess each sub-processor's data protection posture before onboarding and require contractual data-protection commitments.
- You may request a copy of the safeguards by emailing dpo@internrouter.com.ng.
9.Data Retention
- Account data: retained while your account is active and for 24 months after closure, then deleted or fully anonymised.
- Application data and uploaded documents: retained for 18 months after the Application's final outcome, then deleted.
- Payment proofs: retained for 5 years for financial-record purposes as required by Nigerian financial regulation.
- Technical logs: retained for 90 days, except where required longer for incident investigation.
- Anonymised, aggregated statistics may be retained indefinitely for product analytics.
11.Your Rights Under NDPA 2023
Right of Access
Request a copy of the personal data we hold about you.
Right of Rectification
Request correction of inaccurate or incomplete data.
Right of Erasure
Request deletion where there is no overriding legal basis to retain.
Right to Restrict Processing
Request a temporary halt to certain processing activities.
Right of Data Portability
Receive your data in a structured, machine-readable format.
Right to Object
Object to processing based on legitimate interest or for direct marketing.
Right to Withdraw Consent
Withdraw any previously given consent at any time, without affecting prior processing.
Right to Lodge a Complaint
File a complaint with the Nigeria Data Protection Commission at ndpc.gov.ng.
12.Children's Privacy
- The Platform is not directed at persons under 16. We do not knowingly collect personal data from anyone under 16 without verifiable parental or guardian consent.
- If we learn that we have collected such data without proper consent, we delete it promptly.
- If you believe we hold data about a minor without consent, contact dpo@internrouter.com.ng.
13.Security Measures
- Transport: All traffic is encrypted in transit using TLS 1.3.
- At rest: Passwords are hashed using industry-standard algorithms (Supabase Auth defaults). Sensitive uploads are stored under signed, access-controlled URLs.
- Access controls: Internal access to personal data is restricted to authorised personnel on a need-to-know basis and logged.
- Monitoring: We log security-relevant events and review them regularly.
- No system can be guaranteed 100% secure. While we take reasonable precautions, you also bear responsibility for safeguarding your account credentials.
14.Data Breach Notification
- In the event of a personal-data breach likely to result in risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission within seventy-two (72) hours of becoming aware, as required by NDPA s.40.
- Affected individuals will be notified without undue delay where the breach poses a high risk.
15.Changes to This Policy
- We may update this Policy from time to time. Material changes will be notified by email to registered users at least 14 days before they take effect.
- The "Last updated" date at the top reflects the latest revision. Prior versions are archived and available on request.
16.Contact Us
- Data Protection Officer: dpo@internrouter.com.ng
- General privacy enquiries: privacy@internrouter.com.ng
- Postal address: Lagos, Nigeria (full address on request)
- Regulator: Nigeria Data Protection Commission — ndpc.gov.ng
Questions about your privacy?
Reach our Data Protection Officer or compliance team for clarifications about how we handle your data.