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Privacy Policy

Last updated: September 10, 2025

1. Introduction

At TR Thrive ("we", "our", or "us"), we are dedicated to safeguarding the privacy of our users. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you access or use our legal job portal platform at https://trthrive.com, including all associated services, features, and functionalities such as job listings, event management, professional networking, and career development tools. Our commitment to privacy is rooted in our mission to provide a trusted and secure platform for legal professionals, law firms, and organisations within the Nigerian legal ecosystem.

This Privacy Policy complies with the Data Protection Act 2023 and the Nigerian Data Protection Regulation (NDPR) 2019 and other applicable data protection laws in Nigeria. It is designed to inform you about your rights, our data practices, and the measures we take to ensure your personal information is handled responsibly. By using our Platform, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree, please refrain from using the Platform. For any questions or concerns, you may contact our Data Protection Officer at legal@trthrive.com.

2. Information We Collect

2.1 Personal Information

To provide a tailored and effective experience on TR Thrive, we collect personal information necessary for the operation of our Services. This includes basic information such as your full name, email address, phone number, and physical address, which are essential for account creation and communication. For job seekers, we collect professional information, including work experience, employment history, professional qualifications, certifications, and LinkedIn profiles, to facilitate job applications and networking. Educational information, such as institutions attended, degrees earned, and National Youth Service Corps (NYSC) details, helps verify qualifications. Account information, including login credentials and preferences, ensures secure access and a personalised experience. Additionally, we collect documents such as CVs, resumes, profile pictures, and other uploaded materials, as well as job application data like cover letters and job preferences, to support your career goals.

2.2 Usage Information

We collect usage information to understand how users interact with the Platform and to enhance its functionality. This includes device information such as your IP address, browser type, operating system, and device identifiers, which helps us optimise the Platform for different devices. Activity data, such as pages visited, time spent on pages, and interactions with features, allows us to analyse user behaviour and improve user experience. Job interaction data, including job views, applications submitted, saved jobs, and application status, helps us tailor job recommendations. Similarly, event interaction data, such as registrations, likes, saves, and participation records, supports event management. Performance metrics, like view counts and click rates, provide insights into platform engagement and effectiveness.

2.3 Communication Data

Communication data is collected to facilitate interactions and provide support. This includes messages and correspondence between users, such as job seekers communicating with employers or event organisers. Feedback and survey responses help us improve our Services, while customer support communications allow us to address your inquiries effectively. If you subscribe to our newsletters, we collect your subscription preferences to deliver relevant updates. All communication data is handled with care to ensure privacy and compliance with NDPR requirements.

3. Legal Basis for Processing

We process your personal data in accordance with the Nigeria Data Protection Act, 2023 (NDPA) and Nigeria Data Protection Regulation, 2019 (NDPR) based on the following legal grounds:

  • Consent: Where you explicitly agree, such as for marketing communications or processing sensitive data.
  • Contract Performance: To fulfill obligations under our Terms of Service, such as processing job applications or event registrations.
  • Legal Obligation: To comply with Nigerian laws, such as tax or regulatory reporting requirements.
  • Legitimate Interests: For purposes like improving Platform functionality, personalizing content, or preventing fraud, provided your rights are not overridden.
  • Vital Interests: To protect your or another individual’s vital interests, such as in emergencies.
  • Public Interest: For tasks in the public interest, such as cooperating with regulatory authorities.

You may withdraw consent at any time by contacting our Data Protection Officer at legal@trthrive.com, though this may limit certain Platform functionalities.

4. How We Use Your Information

4.1 Core Platform Services

We use your information to deliver the core functionalities of TR Thrive. This includes facilitating job applications and recruitment processes by connecting job seekers with employers and ensuring applications are processed efficiently. For event management, we use your data to handle registrations, confirm participation, and provide updates. Scholarship applications are processed to support career development opportunities. We enable communication between users, such as direct messaging between job seekers and employers, to foster professional connections. Additionally, your information is used to provide customer support, addressing inquiries and resolving issues promptly to ensure a seamless experience.

4.2 Platform Improvement

To enhance the Platform’s performance and user experience, we analyse user behaviour and preferences to identify trends and areas for improvement. This data informs updates to features and functionality, ensuring the Platform remains relevant and user-friendly. Personalisation is a key focus; we use your information to tailor job recommendations, event suggestions, and content to your interests and professional goals. Performance metrics, such as engagement statistics, help us measure the Platform’s effectiveness and make data-driven decisions to optimise its services.

4.3 Communication

We use your information to keep you informed and engaged. This includes sending job alerts and recommendations based on your preferences and activity, as well as event updates and reminders to ensure you don’t miss opportunities. Administrative notifications, such as account updates or policy changes, are sent to keep you informed of important Platform developments. With your consent, we may send marketing communications, such as newsletters or promotional offers, which you can opt out of at any time. All communications are designed to be relevant and compliant with NDPR consent requirements.

5. Information Sharing

5.1 With Other Users

To fulfill the Platform’s purpose, certain information is shared with other users. For job seekers, application details, such as CVs and cover letters, are shared with employers to facilitate recruitment. Profile information, including professional qualifications and experience, may be visible to recruiters to help them identify suitable candidates. Event participation details, such as registration confirmations, are shared with event organisers to manage attendance and logistics. Public profile information, such as your name and professional summary, may be visible to other users to support networking, but you can control visibility settings to protect your privacy.

5.2 With Service Providers

We engage trusted third-party service providers to support the Platform’s operations. Payment processors handle transactions securely, ensuring compliance with PCI DSS standards. Email service providers deliver communications, such as job alerts and event updates. Analytics providers help us understand usage patterns to improve the Platform, while cloud storage providers securely host your data. All service providers are bound by contracts that require them to comply with NDPR and protect your information, ensuring it is used only for the intended purposes.

5.3 Legal Obligations

In certain circumstances, we may share your information to comply with legal obligations, such as responding to court orders, subpoenas, or requests from regulatory authorities like the Nigerian Data Protection Authority (NDPA). We may also disclose information to protect our rights, enforce our Terms of Service, or investigate potential violations, fraud, or security issues. Such disclosures are made in strict compliance with applicable laws and only to the extent necessary to meet legal requirements.

5.4 Cross-Border Data Transfers

If we transfer your data outside Nigeria (e.g., to cloud servers in the EU or US), we comply with NDPA Section 42 by:

  • Obtaining approval from the Nigeria Data Protection Commission (NDPC).
  • Using safeguards like Standard Contractual Clauses, Binding Corporate Rules, or adequacy decisions to ensure equivalent protection.
  • Notifying users of such transfers where required by law.

6. Data Protection and Security

Protecting your personal data is a priority for TR Thrive. We implement robust technical and organisational measures to safeguard your information, in line with NDPR requirements. Data transmission is secured using SSL/TLS encryption to prevent unauthorised access. Regular security assessments and updates ensure our systems remain resilient against threats. Access controls and authentication measures, such as strong password requirements and two-factor authentication, restrict access to authorised personnel only. We maintain data backup and recovery procedures to protect against data loss, and our employees undergo regular training on data protection best practices to uphold our commitment to your privacy.

Despite our efforts, no online platform can guarantee absolute security. In the unlikely event of a data breach, we will notify affected users and the NDPA promptly, in accordance with legal requirements, and take immediate steps to mitigate any harm. Users are encouraged to contribute to security by using strong passwords, and reporting any suspicious activity to legal@trthrive.com.

7. Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, we will:

  • Notify the Nigeria Data Protection Commission (NDPC) within 72 hours, as required by NDPA Section 40.
  • Inform affected users promptly via email or Platform notification, providing details of the breach and recommended protective actions.
  • Take immediate steps to contain the breach, mitigate harm, and prevent recurrence.

We maintain a breach response plan to ensure swift and compliant action. Contact our Data Protection Officer at legal@trthrive.com to report suspected breaches.

8. Your Data Protection Rights

Under the Data Protection Act 2023 and the Nigerian Data Protection Regulation (NDPR) 2019, you have specific rights regarding your personal data. You have the right to access your data to understand what information we hold and how it is used. If any information is inaccurate, you can request corrections to ensure its accuracy. You may request the deletion of your data, subject to legal or operational retention requirements. The right to restrict processing allows you to limit how your data is used in certain circumstances. You can also request data portability to receive your data in a structured, commonly used format for transfer to another service. Additionally, you may object to certain types of processing, such as marketing communications, and withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact our Data Protection Officer at legal@trthrive.com. We will respond to requests within the timeframes specified by the NDPR, typically within one month, and provide assistance to ensure your rights are upheld. If you are dissatisfied with our response, you may lodge a complaint with the Nigerian Data Protection Authority (NDPA).

9. Cookies and Tracking

TR Thrive uses cookies and similar tracking technologies to enhance your experience and collect usage data. Essential cookies are necessary for core Platform functionality, such as maintaining your login session and ensuring secure navigation. Analytics cookies help us understand usage patterns, such as which pages are most visited, to improve the Platform’s performance. Preference cookies remember your settings, such as language or display preferences, for a personalised experience. Performance cookies optimise the Platform’s speed and responsiveness, ensuring a smooth user experience.

You can manage cookie settings through your browser preferences, including disabling non-essential cookies. However, disabling certain cookies may limit some Platform functionalities, such as personalised job recommendations. We provide a cookie consent mechanism on the Platform, allowing you to make informed choices about cookie usage in compliance with NDPR requirements. For more details, please review our Cookie Policy at https://trthrive.com/cookie-policy.

10. Advertising and Google AdSense

TR Thrive displays advertisements through Google AdSense to support our free services. These advertisements help us maintain the Platform and provide valuable content to our users at no cost. Google AdSense uses cookies and similar technologies to deliver relevant advertisements based on your interests and browsing behavior.

Important Information About Google Advertising Cookies

Google advertising cookies: Google uses cookies to help serve the ads it displays on the websites of its partners, such as websites displaying Google ads or participating in Google certified ad networks. When users visit a Google partner's website, a cookie may be dropped on that end user's browser.

10.1 Third-Party Advertising Disclosure

Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to your website or other websites. Google's use of advertising cookies enables it and its partners to serve ads to your users based on their visit to our sites and/or other sites on the Internet.

10.2 AdSense Data Collection

Google AdSense may collect and process data including:

  • Your IP address and general location information
  • Browser type and device information
  • Pages visited and time spent on our Platform
  • Ad interactions and click-through rates
  • Demographic information (age, gender, interests)
  • Browsing history and search queries

10.3 AdSense Data Usage

Google uses this information to:

  • Display relevant advertisements
  • Prevent fraud and abuse
  • Analyze ad performance
  • Improve advertising services
  • Provide personalized advertising experiences

10.4 Third-Party Advertisers and Ad Networks

If you have not opted out of third-party ad serving, the cookies of other third-party vendors or ad networks may also be used to serve ads on our site. We notify our site visitors of the third-party vendors and ad networks serving ads on our site and provide links to the appropriate vendor and ad network websites.

These third-party vendors and ad networks have their own privacy policies, and we encourage you to review them. We do not control these third-party cookies or their data collection practices.

10.5 Your Advertising Choices

Users may opt out of personalized advertising by visiting Ads Settings. Alternatively, you can direct users to opt out of a third-party vendor's use of cookies for personalized advertising by visiting www.aboutads.info.

You can also manage your cookie preferences through our cookie consent tool on the Cookie Policy page, which allows you to control marketing cookies that include AdSense cookies.

10.6 Impact of Opting Out

Disabling AdSense cookies may result in less relevant advertisements, but it will not affect the core functionality of our Platform. You can still access all features and services without these cookies. However, opting out of personalized advertising may result in seeing generic ads that are less relevant to your interests.

11. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. For active accounts, data is retained to provide ongoing Services, such as job applications and event participation. We also retain data to comply with legal obligations, such as tax or regulatory reporting requirements under Nigerian law. Data may be kept to resolve disputes, enforce our Terms of Service, or meet operational needs, such as maintaining performance metrics.

When data is no longer needed, we securely delete or anonymise it to prevent unauthorised access. For example, inactive accounts may be deleted after a specified period, and application data may be anonymised for statistical analysis. Users can request data deletion by contacting legal@trthrive.com, subject to any legal retention obligations. Our retention practices are designed to balance user privacy with operational and legal requirements.

12. Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with the NDPA and NDPR, as required for organizations processing significant volumes of personal data. The DPO monitors our data protection practices, handles inquiries, and ensures adherence to legal standards. Contact the DPO at legal@trthrive.com for any privacy concerns or to exercise your data protection rights.

13. Changes to Privacy Policy

TR Thrive may update this Privacy Policy periodically to reflect changes in our Services, legal requirements, or operational practices. Material changes, such as those affecting your rights or data usage, will be communicated via email or Platform notification at least 30 days before they take effect. Non-material changes, such as minor clarifications, may take effect immediately. Continued use of the Platform after the effective date of changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed of how we protect your data.

14. Contact Information

For any privacy-related inquiries, to exercise your data protection rights, or to provide feedback, please contact our Data Protection Officer. We are committed to addressing your concerns promptly and ensuring compliance with NDPR requirements.

If you are dissatisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission at info@ndpc.gov.ng or visit https://ndpc.gov.ng.

This Privacy Policy is compliant with the Nigeria Data Protection Act, 2023, the Nigerian Data Protection Regulation, 2019, and other applicable Nigerian laws. For additional guidance on privacy policies and cookie consent notices, you may wish to review resources such as the Network Advertising Initiative and cookiechoices.org.