REVIEW DRAFT — not approved for publication. Version 2026-10-13. The operator’s legal identity, hosting arrangements, jurisdiction and operational practices require verification by qualified counsel.
Scope and information
This draft applies to the public corporate website, not the authenticated business application. Enquiries may contain your name, email, organisation, category, subject and message. Hosting may process technical request information needed for operation and abuse prevention. Do not include confidential business records or credentials.
Purpose and lawful basis
Information would be used to respond to enquiries and operate and protect this website. Counsel must confirm the appropriate legal basis for each processing purpose under the Nigeria Data Protection Act 2023 and applicable intended-market laws before collection begins; a form acknowledgement does not replace that assessment.
Cookies and analytics
No website advertising or analytics is configured. Cloudflare Turnstile protects the enquiry form and processes technical signals including IP addresses, browser headers and website origin. Provider storage and cookie behaviour require review against the deployed configuration.
Storage, providers and transfers
Render hosts the website in Virginia, USA. Resend delivers enquiries to company inboxes hosted on Zoho Mail Free. Upstash Redis in Northern Virginia stores global rate-limit counters, not enquiry content or visitor-specific keys. Cloudflare provides Turnstile verification. The application does not persist enquiry messages locally. The operator confirmed hosted email receipt. Provider contracts, data-centre details, retention and international-transfer safeguards still require legal review.
Retention and security
The owner approved manual retention of resolved website enquiries for 90 days after resolution, with documented exceptions for ongoing matters or legal obligations. Automatic deletion is not configured. A synthetic rehearsal passed; daily mailbox processing and deletion have not been verified. Provider logs and recovery copies have separate retention arrangements requiring review. HTTPS, validation, Turnstile and shared rate limits reduce risk but do not guarantee immunity from attacks.
Your rights and enquiries
Applicable rights may include access, correction, erasure, objection and restriction, subject to legal conditions. Contact info@qavynel.com for privacy enquiries. Qualified counsel must confirm rights-handling procedures and regulator complaint information.
Updates and legal references
Changes should carry a new version and accurate processing disclosures. The Nigeria Data Protection Commission’s rights information is a reference, not an endorsement or certification of QAVYNEL.
