1. Introduction
BehindDWheel Truckers' Ventures Cooperative ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website (behinddwheel.com) and cooperative services.
This policy complies with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Commission (NDPC) Act 2023, and the EU General Data Protection Regulation (GDPR) where applicable.
2. Data Controller
BehindDWheel Truckers' Ventures Cooperative
Lagos, Nigeria
Email: contact@behinddwheel.com
Data Protection Officer: dpo@behinddwheel.com
Phone: +234 803 654 7585
3. What Data We Collect
3.1 Personal Identification Information
- Full name, email address, phone number
- Date of birth, gender, marital status
- Residential address, state of origin, LGA
- Passport photograph
3.2 Verification Documents (KYC)
- FRSC Driver's License number and image
- National Identification Number (NIN)
- International Passport (if applicable)
- Proof of address (utility bill, etc.)
3.3 Financial Information
- Savings account balances and transaction history
- Loan application details, repayment history
- Bank account details for disbursements (encrypted at rest)
3.4 Technical Data
- IP address, browser type, device information
- Cookies and usage data (see Section 9)
4. How We Use Your Data
- Membership Processing: To verify your identity and approve cooperative membership
- Service Delivery: To manage savings accounts, process loans, and calculate dividends
- Communication: To send important updates about your account, cooperative meetings, and job opportunities
- Legal Compliance: To comply with NDPR, NDPC, SCUML, NDIC, and other Nigerian regulations
- Security: To protect against fraud, unauthorized access, and misuse
We do NOT sell, rent, or trade your personal data to third parties.
5. Legal Basis for Processing (GDPR/NDPR)
- Consent: You explicitly consent when registering and providing KYC documents
- Contractual Necessity: Processing is required to provide cooperative membership services
- Legal Obligation: Compliance with Nigerian cooperative society regulations (SCUML, NDIC)
- Legitimate Interest: Fraud prevention, security, and service improvement
6. Data Storage & Security
We implement strict technical and organizational measures to protect your data:
- Encryption: All sensitive data (passwords, BVN, bank details, license numbers) is encrypted at rest using industry-standard encryption (AES-256)
- Access Control: Only authorized cooperative officers (Admin, Loan Officer) can access member data, and only on a need-to-know basis
- Secure Transmission: All data is transmitted over HTTPS (TLS 1.3)
- Server Security: Hosted on secure servers with firewalls, intrusion detection, and regular security audits
- Data Minimization: We only collect data that is necessary for cooperative operations
Important: Sensitive personal data (license numbers, NIN, BVN, bank account details) are never exposed in frontend code or client-side JavaScript. They are processed and stored exclusively on our secure backend servers.
7. Data Retention
- Active Members: Data retained for the duration of membership
- Exited Members: Data retained for 7 years (as required by Nigerian cooperative and financial regulations)
- Unsuccessful Applications: KYC documents deleted after 90 days
- Cookie Data: Retained as per consent (maximum 365 days)
8. Your Rights (NDPR/GDPR)
As a data subject, you have the following rights:
- Right to Access: Request a copy of your personal data
- Right to Rectification: Correct inaccurate or incomplete data
- Right to Erasure: Request deletion of your data ("right to be forgotten")
- Right to Restrict Processing: Limit how we use your data
- Right to Data Portability: Receive your data in a structured format
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent at any time
- Right to Complain: Lodge a complaint with the NDPC (Nigeria Data Protection Commission)
To exercise any of these rights, contact our Data Protection Officer at dpo@behinddwheel.com or call +234 803 654 7585.
9. Cookies Policy
We use cookies to improve your experience:
- Essential Cookies: Required for site functionality (session management, CSRF protection, login). Cannot be disabled.
- Analytics Cookies: Optional — help us understand how you use the site (Google Analytics). Only activated with your explicit consent.
- No Advertising Cookies: We do not use advertising or tracking cookies.
You can manage your cookie preferences at any time through our cookie consent banner or by clearing your browser cookies.
10. Third-Party Services
We use the following third-party services that may process limited data:
- Google Analytics: Anonymous usage statistics (only with consent)
- Truehost Cloud Nigeria: Web hosting (servers located in Nigeria)
- Payment Processors: For registration fees and contributions (PCI-DSS compliant)
11. Data Breach Notification
In the event of a data breach, we will:
- Notify affected members within 72 hours of discovery
- Notify the NDPC (Nigeria Data Protection Commission) as required by law
- Provide details of the breach, likely impact, and remedial actions taken
12. Children's Privacy
Our services are not directed at individuals under 18 years of age. We do not knowingly collect data from minors. If you believe a minor has provided us with personal data, please contact us immediately.
13. International Data Transfers
Your data is stored on servers located in Nigeria. We do not transfer your data outside Nigeria unless absolutely necessary for service delivery, and only to countries with adequate data protection laws as determined by NDPC.
14. Changes to This Policy
We may update this Privacy Policy from time to time. Members will be notified of significant changes via email or through our website. Continued use of our services after changes constitutes acceptance of the updated policy.
15. Contact Us
For any questions about this Privacy Policy or to exercise your data rights:
- Email: dpo@behinddwheel.com
- Phone: +234 803 654 7585
- Address: BehindDWheel Truckers' Ventures Cooperative, Lagos, Nigeria
- NDPC Complaint: Visit ndpc.gov.ng to lodge a complaint with the Nigeria Data Protection Commission