Privacy Notice

1. Introduction

TogetherWell Services (“TogetherWell,” “we,” “our” or “us”) respects your privacy and is committed to handling personal information responsibly, securely and transparently.

We provide family-life education, relationship and marriage education and coaching, parenting education and coaching, family wellness resources, training programmes and related professional support.

When you visit our website, submit an enquiry, register for a programme or communicate with us, we may collect personal information necessary to respond to your request or provide the relevant service.

This Privacy Notice explains how we collect, use, protect, retain and disclose personal information, as well as the rights available to individuals whose information we process.

Our approach is guided by applicable Nigerian data protection requirements, including the Nigeria Data Protection Act 2023.

2. Who This Notice Applies To

This Privacy Notice applies to individuals who interact with TogetherWell through our website and associated online enquiry channels, including:

  • Individuals seeking relationship or marriage education and coaching.
  • Parents and caregivers seeking parenting education or guidance.
  • Individuals and families exploring family wellness resources and support.
  • Participants enquiring about training, workshops and programmes.
  • Representatives of organisations interested in partnerships or professional services.
  • Visitors who contact us with general questions.

Additional privacy and confidentiality information may be provided before participation in structured coaching, educational programmes or other services where more detailed personal information may be involved.

3. Our Approach to Privacy

TogetherWell recognises that enquiries about relationships, parenting and family life can involve personal and potentially sensitive matters.

We aim to collect only information reasonably necessary for a clearly identified purpose, restrict access to authorised persons and avoid requesting detailed sensitive information through general website enquiry forms.

We also recognise the importance of dignity, informed consent, confidentiality, safeguarding and responsible professional boundaries.

Privacy and confidentiality are important commitments, but they are not absolute. Information may need to be handled or disclosed where required or permitted by applicable law, including relevant safeguarding obligations.

4. Personal Information We May Collect

TogetherWell Services collects personal information that is relevant and reasonably necessary for our activities, enquiries and services.

Depending on how you interact with us, this may include:

Identity and Contact Information

  • Full name
  • Email address
  • Telephone or WhatsApp number
  • Organisation or professional affiliation, where relevant

Enquiry and Communication Information

  • The type and subject of your enquiry
  • Information you voluntarily provide in contact forms
  • Correspondence relating to your enquiry
  • Information needed to respond appropriately to your request

Programme and Service Information

Where you register for or participate in a TogetherWell programme or service, we may collect additional information necessary for registration, communication, programme administration or the agreed service.

Any collection of more detailed personal information should be explained through the relevant registration process, privacy information or service agreement.

We encourage visitors not to submit unnecessary sensitive personal information through general website contact forms.

5. Information Collected Through Our Website

When you interact with the TogetherWell website, certain technical information may be processed to support website operation, security and performance.

Depending on the technologies enabled, this may include:

  • Internet Protocol (IP) addresses
  • Browser and device information
  • Website access and error logs
  • Cookies or similar technologies
  • Information about website usage and performance

Some of this processing may be performed by our website hosting provider or other authorised service providers.

The specific technologies used, their purposes and any applicable consent arrangements will be described in this notice once verified.

6. Sensitive Personal Information

TogetherWell recognises that family-life and relationship enquiries may involve sensitive personal circumstances.

Our general website contact form is intended for initial enquiries, not for collecting detailed personal histories, clinical information, allegations of abuse or extensive confidential information about other people.

Where more sensitive information is necessary for a particular service, we aim to explain why it is needed, establish an appropriate basis for processing it and use suitable safeguards.

We do not treat submission of a general enquiry as permission to collect or use sensitive personal information for unrelated purposes.

Where safeguarding concerns arise, information may need to be handled in accordance with applicable legal obligations and appropriate protection procedures.

7. How We Use Personal Information

TogetherWell Services uses personal information for specific, legitimate and clearly identified purposes connected with our activities.

Depending on your interaction with us, these purposes may include:

  • Receiving, reviewing and responding to enquiries.
  • Providing information about our services, programmes and resources.
  • Communicating with individuals who request parenting, relationship or family wellness support.
  • Managing registrations, participation and administration for educational programmes, workshops and events.
  • Arranging agreed coaching, educational or relationship strategy services.
  • Maintaining appropriate administrative records and correspondence.
  • Managing website operations, technical performance and security.
  • Responding to complaints, safeguarding concerns and applicable legal obligations.

We do not regard a general enquiry as automatic permission to send unrelated promotional communications.

Where we wish to send newsletters, promotional updates or other optional marketing communications, we will establish an appropriate lawful basis and provide any required choice or consent mechanism.

Personal information should not be used for purposes incompatible with those for which it was originally collected unless another lawful basis permits the processing.

8. Lawful Bases for Processing Personal Information

TogetherWell processes personal information only where an appropriate lawful basis exists under applicable data protection law.

Depending on the circumstances, these bases may include:

Consent

Where you have given valid consent for a specific processing activity, such as receiving optional communications or participating in an activity that requires consent.

Where processing relies on consent, you may withdraw that consent, subject to applicable legal requirements.

Steps Before Entering a Contract or Performance of a Contract

Where processing is necessary to respond to a request about a proposed service, arrange an agreed service or fulfil obligations arising from a service agreement.

Compliance With Legal Obligations

Where processing is necessary to meet an applicable legal or regulatory requirement.

Legitimate Interests

Where processing is necessary for a legitimate organisational purpose, such as maintaining website security or managing ordinary administrative communications, provided the relevant legal requirements are satisfied and individuals’ rights and interests are appropriately considered.

Vital Interests

Where applicable law permits processing necessary to protect someone’s life or other vital interests.

The lawful basis used will depend on the purpose and circumstances of the particular processing activity.

Where sensitive personal data is involved, additional legal conditions and safeguards may apply.

9. When Personal Information May Be Shared

TogetherWell does not disclose personal information indiscriminately.

Information may be shared where reasonably necessary, appropriately authorised or required or permitted by law.

Depending on the circumstances, recipients may include:

Authorised TogetherWell Personnel

Individuals responsible for receiving enquiries, administering programmes or delivering agreed services, subject to appropriate access restrictions and confidentiality responsibilities.

Website and Technology Service Providers

Providers involved in website hosting, form processing, email delivery, technical maintenance or other necessary digital operations.

Such providers should process information only under appropriate arrangements and safeguards.

Professional or Specialist Services

Where a matter requires referral or coordinated support, relevant information may be shared with an appropriate professional or organisation where a valid lawful basis exists and the disclosure is necessary and proportionate.

Legal, Regulatory or Safeguarding Authorities

Information may be disclosed where required or permitted by applicable law, including circumstances involving legal obligations, child protection or serious safety concerns.

We aim to limit disclosures to information reasonably necessary for the relevant purpose.

TogetherWell does not treat personal information submitted through its general enquiry form as available for unrestricted marketing, unrelated disclosure or commercial sale.

10. How We Protect Personal Information

TogetherWell Services recognises its responsibility to protect personal information against unauthorised access, accidental loss, misuse, alteration and inappropriate disclosure.

We aim to implement appropriate organisational and technical safeguards proportionate to the nature of the information we process and the risks involved.

These measures may include:

  • Restricting access to personal information to authorised personnel with a legitimate need.
  • Using appropriate account authentication and access controls.
  • Maintaining reasonable website, email and form security arrangements.
  • Applying confidentiality requirements to personnel handling enquiries and service information.
  • Reviewing the security arrangements of relevant technology service providers.
  • Responding appropriately to suspected personal data breaches.

No method of electronic transmission or storage can guarantee absolute security.

We therefore encourage visitors to avoid submitting unnecessary sensitive information through general website enquiry forms.

Where a personal data breach occurs, TogetherWell will assess the incident and take appropriate steps in accordance with applicable legal requirements, including notification where legally required.

11. How Long We Keep Personal Information

TogetherWell aims to retain personal information only for as long as reasonably necessary to fulfil the purpose for which it was collected, meet applicable legal obligations, resolve relevant disputes or maintain records where there is a valid reason to do so.

Different categories of information may require different retention arrangements.

These may include:

General Website Enquiries

TogetherWell ordinarily retains general website enquiries and related correspondence for up to 12 months after the last meaningful interaction, unless a longer period is necessary for a legitimate purpose or required by applicable law.

We review retained enquiries periodically and delete information that is no longer required, subject to relevant legal, safeguarding or administrative obligations.

This review covers information stored in our website’s form submission system and administrative email accounts. Copies held in website backups are managed according to applicable backup retention arrangements.

Different retention requirements may apply to coaching records, programme records, safeguarding matters and other specialised information.

Programme and Event Information

Registration and participation records may be retained for legitimate programme administration, reporting and applicable legal obligations.

Coaching and Service Records

Where structured services involve additional records, the applicable retention arrangements should be explained through the relevant service documentation and privacy information.

Technical and Website Information

Website logs and related technical records may be retained according to legitimate operational and security needs and the arrangements of relevant service providers.

When information is no longer required, we aim to delete, anonymise or securely dispose of it, subject to applicable legal requirements.

Specific retention periods or criteria will be established and reviewed as part of TogetherWell’s data management procedures.

12. International Transfers of Personal Information

TogetherWell operates from Nigeria, but some website hosting, email, software or technology service providers may process or store information in other countries.

Where personal information is transferred outside Nigeria, TogetherWell will assess the applicable legal requirements and seek to ensure that appropriate safeguards or another legally permitted transfer mechanism is in place.

Depending on the circumstances, this may involve evaluating the receiving country’s data protection arrangements, contractual protections, applicable legal authorisations or other recognised safeguards.

We do not assume that using an internationally available technology service automatically makes every international data transfer compliant with Nigerian data protection requirements.

Relevant service-provider locations and transfer arrangements will be reviewed as part of our privacy and data protection procedures.

13. Your Data Protection Rights

Under the Nigeria Data Protection Act 2023 and other applicable laws, individuals may have rights concerning how their personal information is processed.

Depending on the circumstances and applicable legal conditions, these rights may include:

Right to Be Informed

You may request information about how and why your personal data is collected and processed.

Right of Access

You may request access to personal information TogetherWell holds about you, subject to applicable legal limitations.

Right to Rectification

You may request correction of inaccurate personal information or completion of incomplete information.

Right to Erasure

You may request deletion of personal information where the relevant legal conditions are satisfied.

Right to Restrict or Object to Processing

You may request restriction of certain processing activities or object to processing where the law provides that right.

Right to Withdraw Consent

Where processing relies on your consent, you may withdraw that consent. Withdrawal does not automatically invalidate processing lawfully carried out before withdrawal.

Right to Data Portability

Where applicable legal conditions are met, you may request to receive certain personal information in a suitable format or have it transmitted to another controller.

Rights Relating to Automated Decision-Making

You may have rights concerning decisions based solely on automated processing that produce legal or similarly significant effects.

Right to Lodge a Complaint

You may raise concerns with TogetherWell or lodge a complaint with the Nigeria Data Protection Commission, subject to applicable procedures.

Exercising Your Rights

To make a privacy-related request, contact TogetherWell using the details provided in Section 15.

We may need to verify your identity before responding to certain requests to protect personal information from unauthorised disclosure.

Requests will be assessed and handled in accordance with applicable legal requirements.

14. Cookies and Similar Technologies

Cookies are small data files that websites may store on a visitor’s device to support website functionality, remember preferences or provide information about website usage.

The TogetherWell website may use cookies or similar technologies for purposes such as:

  • Essential website operation and security.
  • Maintaining website functionality.
  • Remembering user preferences where relevant.
  • Understanding website performance and usage, where applicable.

Some cookies may be set by third-party services integrated into the website.

Where applicable law requires consent for particular technologies, TogetherWell will seek to implement an appropriate consent mechanism before using them.

Visitors may also be able to manage certain cookies through their browser settings.

The specific cookies and technologies used by our website, including any analytics, embedded content or marketing tools, will be reviewed and disclosed as appropriate.

15. Contact Us About Privacy

If you have questions about this Privacy Notice, wish to exercise a data protection right or have concerns about how your personal information is handled, you may contact:

TogetherWell Services

Email: hello@togetherwellfamily.com

Subject: Privacy Enquiry

Please provide enough information for us to understand your request, but avoid including unnecessary sensitive personal details in your initial email.

We will review your enquiry and respond in accordance with applicable legal requirements.

If you remain dissatisfied with how a data protection concern has been handled, you may contact the Nigeria Data Protection Commission through its official channels.

Updates to This Privacy Notice

TogetherWell may update this Privacy Notice to reflect changes in our services, website technologies, data processing activities or applicable legal requirements.

When changes are made, the updated notice will be published on our website with a revised effective date.

Effective Date: 12 October 2026

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