DRAFT — NOT FOR PUBLICATION Prepared by MD-DRIVE as a structure for Jenkins Michaels Limited's legal advisers. Sections marked To be confirmed are not written yet. This page is excluded from search engines and must not be linked as a live policy.
Legal

Privacy Policy

How TalentHub collects, uses, stores and protects your personal data — and what you can ask us to do with it.

Last updated — · Version draft

TalentHub is operated by Jenkins Michaels Limited (RC 1518112). This policy explains what we do with information about you. It applies to everyone who uses TalentHub — artisans, professionals, employers, individuals and entrepreneurs.

1 · Who we are

Jenkins Michaels Limited is the data controller for the personal data described in this policy. That means we decide what is collected and why, and we are answerable for it.

To be confirmed — Client Registered office address, and the name and contact details of the Data Protection Officer or the person responsible for data protection enquiries. NDPA requires a reachable contact point.

2 · What we collect

When you create an account

  • Your name
  • Your email address
  • Your phone number
  • Your state and, if you give it, your city or town
  • The role you are joining as
  • Your password — this is held by our sign-in provider in a scrambled form. Nobody at TalentHub can see it, including our administrators.

We also generate a permanent registration number for you, in the form TH-2026-00147.

If you sign in with Google

We receive your name, email address and profile picture from Google. We then ask you for a phone number and location, because Google does not provide them.

What you add afterwards

This depends on your role, and all of it is optional until you choose to publish. It may include your trade or profession, skills, experience, work history, qualifications, rates, availability, a profile photograph, photographs of your work, company details, job postings, applications, quotes, and reviews you write or receive.

If you pay for a membership

We record which plan you selected, the amount, a payment reference, and — if you upload one — a copy of your transfer receipt. We never see or store your card or bank login details. Payments are made by transfer directly to our bank; TalentHub is not involved in the transaction itself.

Automatically

How many times your profile has been viewed. Standard technical information your browser sends to any website, such as your approximate location and device type, handled by our hosting provider.

3 · Why we use it

In plain terms: to run the platform. To create and secure your account, to show your profile to people looking to hire, to let you apply for work and receive enquiries, to verify who you are, to take payment for memberships, to respond to reports of misuse, and to comply with the law.

To be confirmed — Counsel The lawful basis relied upon for each purpose under the Nigeria Data Protection Act 2023 — consent, contract, legal obligation, legitimate interest — and how consent is recorded and withdrawn where it is the basis.

4 · Identity verification

This is the part of TalentHub that handles the most sensitive information, so it is worth setting out fully.

What we ask for

A photograph of a government-issued identity document, and a live photograph of you holding that document in a position we choose at random. You also tell us the document type and the name printed on it.

What we do with it

A member of our staff looks at the two photographs and decides whether the person in the live photograph is the person on the document.

There is no facial recognition and no biometric processing. We do not create or store a facial template, a biometric record, or any measurement of your face. No computer compares your face to anything. A person looks at two pictures and makes a judgement.

We never ask for, and never store, your identity document number. Not your NIN, not your passport number, not your licence number. We record only the type of document and the name printed on it.

We do not check your details against NIMC or any government database, and we do not send your information to any identity-verification company.

What happens to the photographs

They are deleted the moment the decision is recorded — whether you are approved or rejected. This is automatic and does not depend on anyone remembering to do it.

Deleted files remain recoverable on our storage provider's systems for a short protection period afterwards, and are then permanently destroyed. In practice the photographs exist for a few hours.

To be confirmed — MD-DRIVE The exact soft-delete retention window configured on the storage bucket, stated here in days.

What we keep afterwards

Only the outcome and a short record of how it was reached: whether you were approved or rejected, the type of document, the name you typed from it, which position we asked you to hold it in, when you applied, when it was decided, and which of our staff decided it.

If you are rejected

We tell you why, and you may correct the problem and submit again. There is no limit on attempts. Every decision is made by a person — no automated system decides whether you are verified.

5 · What other people can see

Nothing about you is public until you choose to publish, and — with the exception of a basic account — nothing is published until your identity has been verified.

Public once you publish: your name, trade or profession, skills, rates, availability, work photographs, ratings and reviews, your state and city, your verification status and your registration number.

Never public: your identity documents, your email address, your password, your payment records, and reports made about or by you.

To be confirmed — Client Whether member phone numbers are shown publicly, shown only to signed-in members, or released only when a member chooses. This is currently not published and the decision is outstanding.

6 · Growth Partners

Some people are appointed by Jenkins Michaels Limited to introduce new members to TalentHub. If you joined using a partner's code or link, we record that they introduced you.

That record is kept for as long as your account exists and is used to work out what the partner is owed. A partner can see how many people they introduced who went on to verify their identity, shown by registration number and date only. They cannot see your name, your email address, your phone number or anything else about you.

Anyone claiming to represent TalentHub can be checked at Check a Partner. TalentHub never charges anyone to join, to be verified or to apply for work, and no partner is permitted to ask you for money.

7 · Where your data is held

TalentHub runs on Google Cloud. Your personal data is stored outside Nigeria, because Google operates no data centre in Nigeria.

WhatWhere
Your account record, profile, jobs, applications, reviews and verification resultBelgium
All uploaded files — profile photograph, work photographs, CVs, and identity photographs during reviewUnited States
Your sign-in details and passwordUnited States

Google acts as our processor and handles this data only on our instructions.

To be confirmed — Counsel The transfer mechanism relied upon for these cross-border transfers under the Nigeria Data Protection Act 2023, and how it is described to members. The available instrument is the Google Cloud Data Processing Addendum.

8 · How long we keep it

InformationKept for
Identity document and live photographUntil the decision is made, then deleted
Verification outcome and audit recordAs long as your account exists
Your account and profileUntil you delete your account
Reviews written about youKept after your account is deleted — a review is a record of a completed transaction and belongs to the person who wrote it as much as to you
Payment and commission recordsKept — these are financial records

When you delete your account, we remove your profile, your uploaded files and your verification record. Backups may retain copies for a limited period afterwards before they are overwritten.

To be confirmed — Counsel and Client Whether retaining reviews and financial records after account deletion is properly justified, on what basis, and for how long financial records must be kept. Also the backup retention period, once configured.

9 · Your rights

Under the Nigeria Data Protection Act 2023 you have rights over your personal data, including the right to ask what we hold, to have mistakes corrected, to ask us to delete it, to object to certain uses, and to complain to the Nigeria Data Protection Commission.

You can correct most of your information yourself from your dashboard, and you can delete your account there at any time.

To be confirmed — Counsel The full and accurate statement of data subject rights under the Act, how a request is made, how identity is confirmed before a request is honoured, the response deadline, and the NDPC complaint route.

10 · Security

Your connection to TalentHub is encrypted, and your data is encrypted where it is stored. Access to identity documents is restricted to you and to authorised administrators, enforced by our infrastructure rather than by the website — so it cannot be bypassed. Every verification decision records which administrator made it.

No system is perfectly secure, and we do not claim otherwise. Choose a password you do not use elsewhere.

To be confirmed — Client and Counsel What TalentHub commits to doing if a breach occurs, and the notification obligations under the Act.

11 · Cookies and device storage

TalentHub does not use advertising cookies and does not track you across other websites.

We store a small amount of information on your device so the site works: your sign-in session, so you are not asked to sign in on every page; and, if you arrived using a Growth Partner's link, that partner's code, kept for up to 30 days so they are credited if you register later.

12 · Age

To be confirmed — Client and Counsel The minimum age for a TalentHub account, and what happens if we learn an account belongs to someone below it. TalentHub is a platform for work and currently has no age check at registration. This needs a stated position before launch.

13 · Changes to this policy

If we change this policy we will update the date at the top of this page. Where a change materially affects you, we will tell you.

To be confirmed — Client How members are notified of material changes, and whether continued use constitutes acceptance.

14 · Contact us

If you have a question about this policy, or want to exercise any of your rights, contact Jenkins Michaels Limited.

To be confirmed — Client The email address and postal address for data protection enquiries, and the named Data Protection Officer.