TWL Privacy Policy
Last updated: 8 September 2026
1. Who we are
TWL is operated by Ndidi Ngwuluka Limited, a company registered in Nigeria. We are the controller of personal data when we decide how and why it is used.
Contact details
Ndidi Ngwuluka Limited
KT Building, Bukuru-Du, 930281, Nigeria
Email: hello@ndidingwuluka.com
2. Scope and age limit
This policy covers our website, online shop, TWL Advisor, digital products, coaching, communities, mailing lists, customer support, and communications through Telegram or WhatsApp. TWL operates online and serves customers internationally.
Our services are for adults aged 18 or over. We do not knowingly offer them to, or intentionally collect personal data from, anyone under 18. Contact us if you believe a person under 18 has provided data to us.
3. Personal data we collect
Depending on how you use TWL, we may collect:
- Identity and contact data: name, email, telephone number, billing address, country, account details, and communication preferences.
- Order and payment data: purchases, subscriptions, prices, currency, payment status, transaction references, invoices, and refunds. PayPal, Flutterwave, or Paystack processes full payment credentials. We receive only limited transaction information and do not intend to store complete card numbers, security codes, or online banking credentials.
- TWL Advisor data: first name, messages, the full available conversation transcript, consent and completion status, category, recommendation, personalised result, and result delivery data.
- Coaching data: enquiries, agreements, invoices, intake responses, notes, summaries, action plans, progress information, and correspondence.
- Communications and community data: emails, support requests, authorised testimonials, and Telegram or WhatsApp messages and profile information.
- Website data: IP address, browser and device type, pages viewed, referring page, access time, server logs, cookie identifiers, cart activity, and security information.
We may receive data from payment providers, WordPress and WooCommerce, email and mailing-list providers, Telegram, WhatsApp, or a person who lawfully buys or refers a service for you.
Please provide only information relevant to the service. Do not include another person's data, passwords, financial credentials, identification numbers, detailed medical records, or other highly sensitive information unless necessary and lawful.
4. Why we use personal data
| Purpose | Data used | Lawful basis |
|---|---|---|
| Manage accounts, carts, orders, subscriptions, payments, refunds, and fraud prevention | Identity, contact, order, transaction, and technical data | Contract, steps before a contract, legal obligation, and legitimate interests |
| Deliver products, coaching, support, communities, and service messages | Identity, contact, purchase, coaching, and communication data | Contract, steps before a contract, and legitimate interests |
| Operate TWL Advisor and provide categories, recommendations, and personalised results | First name, transcript, category, recommendation, result, and delivery data | Steps taken at your request and other lawful bases that apply to the information provided |
| Maintain customer and service records | Identity, order, structured Advisor, and communication data | Contract and legitimate interests |
| Send newsletters and offers | Name, email, subscription status, and approved structured data | Consent |
| Secure, maintain, and improve our services | Technical, usage, security, and limited interaction data | Legitimate interests, plus consent for non-essential cookies or tracking |
| Meet financial, regulatory, and dispute obligations | Orders, agreements, invoices, payments, and relevant communications | Legal obligation and legitimate interests |
Where we rely on legitimate interests, we consider necessity and the effect on your rights. You may withdraw consent at any time without affecting earlier lawful processing. If data is needed for a contract and you do not provide it, we may be unable to complete a purchase or deliver the requested service.
5. TWL Advisor and Anthropic
Anthropic processes TWL Advisor conversations and helps generate results. During a conversation, the messages you submit are processed to provide relevant responses. For result generation, we send Anthropic your full available transcript, first name, relevant product or category information, and result-generation instructions. This allows TWL Advisor to identify a category, recommend suitable content or products, and prepare a personalised result.
Conversations may reveal religious or philosophical beliefs, health information, or other sensitive personal data. We process the information you choose to provide so TWL Advisor can conduct the conversation and generate your result. If you do not want particular information processed, do not include it in the conversation.
Advisor content may be incomplete or inaccurate. It supports reflection and general information and is not medical, legal, financial, psychological, or emergency advice. You may ask us to explain a result or correct underlying data.
We do not use raw Advisor transcripts for direct marketing. Raw transcripts are retained for up to 30 days and then deleted or anonymised. They are never sent to Zoho.
6. Marketing and Zoho
With your consent, Zoho may receive your name, email address, category, recommendation, and result delivery data to administer subscriptions, segment approved communications, and deliver or record results. Zoho does not receive your raw TWL Advisor transcript.
Marketing is optional. You can unsubscribe through an email link or contact us. Necessary messages about an order, account, security issue, or purchased service are not marketing.
7. Who receives personal data
We do not sell personal data. We share only what is reasonably needed with:
- Anthropic, for TWL Advisor conversations and results;
- Zoho, for mailing lists and approved structured records;
- PayPal, Flutterwave, and Paystack, for payments, refunds, security, and fraud prevention;
- WordPress and WooCommerce providers, for the website, shop, accounts, and orders;
- Google email services, for customer and administrative email;
- Telegram, for general TWL communities;
- WhatsApp, including for Director's Cut private chats and related communications;
- MDDHosting and other hosting or technical providers, to host, secure, and maintain the service;
- advisers, insurers, accountants, auditors, and contractors under appropriate duties; and
- regulators, courts, law enforcement, or others when required by law or needed to protect safety, rights, prevent fraud, or handle legal claims.
Some providers act as our processors, while others independently decide how they use data collected through their services. Their own privacy terms may also apply. Data may also be shared under suitable safeguards if our business or relevant assets are reorganised or transferred.
8. International processing
TWL is an online international service. Providers, systems, or support teams may process personal data outside Nigeria. For cross-border processing, we use a lawful route under the Nigeria Data Protection Act 2023, such as an applicable adequacy basis, contractual or approved safeguards, explicit consent where permitted and required, or another lawful exception. Contact us for information about relevant safeguards.
9. Retention
| Record | Retention |
|---|---|
| Raw TWL Advisor transcript | Up to 30 days, then deleted or anonymised |
| Structured Advisor category, recommendation, consent, completion, and result delivery data | During the active relationship, then up to 24 months after inactivity |
| Zoho name, email, subscription, and approved structured data | Until unsubscribe or no longer needed, with a minimal suppression record where necessary to honour an opt-out |
| Coaching agreements, invoices, and payment records | Up to 7 years, or longer if law requires |
| Coaching intake records, notes, summaries, and action plans | 3 years after the coaching relationship or record is completed, unless longer retention is reasonably required by law or for a claim |
| WhatsApp coaching or Director's Cut chats held by us | Up to 7 years, subject to platform operation, device changes, user deletion, or loss outside our control |
| Orders, refunds, transaction references, and accounting records | Up to 7 years, or the applicable legal period |
| Enquiries and ordinary support messages | Until resolved, then only as needed for follow-up, administration, or a claim |
| Security and technical records | As reasonably needed to secure, diagnose, and operate the service |
If no specific period applies, we delete or anonymise data when its purpose is complete and, where the applicable storage-limitation rule requires, no later than six calendar months afterwards unless restricted retention is justified by law or a legal claim.
Secure backups may be removed on a later backup cycle. Third-party platforms may retain data under their own policies. Data that has been irreversibly anonymised may be kept for statistics, service improvement, and record keeping.
10. Security
We use reasonable organisational and technical safeguards, including access controls, authentication, secure hosting, software updates, confidentiality measures, backups, and encryption where appropriate. No online service is completely secure. If a personal data breach occurs, we will investigate and notify affected people and the Nigeria Data Protection Commission where required by law.
11. Your rights
Subject to the Nigeria Data Protection Act 2023 and lawful exceptions, you may ask us to:
- confirm whether we process your data and provide access to it;
- correct incomplete or inaccurate data;
- delete data that is no longer needed or unlawfully processed;
- restrict or object to processing in applicable circumstances;
- stop direct marketing;
- record withdrawal of consent;
- provide eligible data in a portable, machine-readable form; and
- provide safeguards concerning solely automated decisions with legal or similarly significant effects.
You also have the right to be informed and to complain to the Nigeria Data Protection Commission. These rights are not absolute. We may verify your identity and may keep data required by law or for a legal claim.
Send requests to hello@ndidingwuluka.com. We will respond without undue delay and within the period required by law.
12. Complaints
Please contact us first if you would like us to address a concern. You may also complain to the Nigeria Data Protection Commission (NDPC) using its current channels at https://ndpc.gov.ng/contact/. Contacting us first does not limit your right to approach the NDPC or seek another lawful remedy.
13. Cookies and third-party services
Our website uses cookies and related technologies for website, cart, security, preference, and payment functions. Non-essential technologies require your choice where consent is required. See the TWL Cookie Policy for categories and controls.
Links to independent third-party services are governed by those providers' own terms and privacy notices.
14. Changes and contact
We may update this policy when our services, providers, law, or data practices change. We will post the updated policy and change the date above. Where required, we will provide additional notice or request consent.
For questions, rights requests, or privacy concerns, contact:
Ndidi Ngwuluka Limited
KT Building, Bukuru-Du, 930281, Nigeria
Email: hello@ndidingwuluka.com