This Privacy Policy explains how Kazwhale Concepts Limited (operating as JEKAFLY®) collects, uses, discloses, and protects your personal data when you use the JEKAFLY website, mobile application, or any related service (the "Platform"). It is written to comply with the Nigeria Data Protection Act 2023 (NDPA) and the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC). By using the Platform, you acknowledge that you have read and understood this Privacy Policy.
1Introduction and Scope
1.1This Privacy Policy applies to all personal data processed by JEKAFLY in connection with the Platform, including data collected when you browse the Platform, create an account, make a Booking for any JEKAFLY service (Flights, Visa, Stay, Consult, or Holidays), contact customer support, or otherwise interact with us.
1.2This Privacy Policy should be read together with our Terms & Conditions of Use. Where a specific JEKAFLY Visa engagement is additionally governed by a signed engagement form or supplementary terms, the data-protection provisions of that document apply alongside this Privacy Policy in respect of that engagement.
1.3This Privacy Policy applies regardless of whether you are a Nigerian resident, a diaspora Nigerian, or a foreign national, in accordance with the extraterritorial scope of the NDPA, which applies to the processing of personal data of any data subject in Nigeria, and to any Nigerian data controller processing personal data outside Nigeria.
2Who We Are — Data Controller
2.1The data controller responsible for your personal data is:
- Kazwhale Concepts Limited, trading as JEKAFLY®
- Registered address: 13, Ayinke Street, Akoka, Lagos, Nigeria
- Email: Kazwhaleconcepts@gmail.com
- Phone: +234 818 653 7678
2.2For all data protection enquiries, requests to exercise your rights, or complaints, you may contact us using the details above, marked for the attention of the Data Protection Officer / Compliance Lead.
3Information We Collect
Depending on which JEKAFLY Service you use, we may collect the following categories of personal data:
3.1 Identity and Contact Data
- Full name, title, date of birth, gender, nationality, marital status;
- Residential address, email address, phone/WhatsApp number;
- Emergency contact details, where provided.
3.2 Travel Document and Immigration Data
- Passport number, issuing country, issue and expiry dates, passport biodata page image;
- Visa application details, immigration history, prior refusals, and supporting documentation submitted for JEKAFLY Visa or JEKAFLY Consult engagements;
- Certificate of Sponsorship references and employer/sponsor details, where relevant to a work-visa engagement.
3.3 Financial Data
- Billing name and address, and limited transaction data (such as payment status and amount) needed to process a Booking;
- Full card numbers and sensitive payment credentials are collected and processed directly by our licensed third-party payment processors and are not stored on JEKAFLY's own servers.
3.4 Technical and Usage Data
- IP address, browser type and version, device identifiers, operating system, referral source;
- Pages visited, search queries, and interaction data collected via cookies and similar tracking technologies (see Clause 7).
3.5 Sensitive / Special Category Data
- Health information, where voluntarily provided in connection with a medical-visit visa application, travel insurance claim, or special assistance request;
- Criminal history declarations, where required for a visa or immigration application;
- We collect and process such sensitive data only with your explicit consent, or where necessary for the establishment, exercise, or defence of a legal claim, or another lawful ground recognised under the NDPA.
3.6 Marketing and Preference Data
- Your communication preferences, and your responses to marketing campaigns, surveys, or promotions.
4How We Collect Your Information
4.1Directly from you — when you create an account, complete a Booking form, upload documents for a visa or travel consultation, contact customer support, or subscribe to marketing communications.
4.2Automatically — through cookies, pixels, and similar technologies when you browse the Platform (see Clause 7), including technical and usage data described in Clause 3.4.
4.3From third parties — including payment processors (confirming payment status), airlines, hotels, and tour operators (confirming Booking status), identity-verification providers, and, where you choose to register or log in using a third-party account (such as Google), basic profile information from that provider.
5Legal Basis for Processing
In accordance with the NDPA, we process your personal data only where we have a lawful basis to do so, which will typically be one of the following:
- Consent — where you have given clear, informed, opt-in consent, for example for marketing communications, non-essential cookies, or processing of sensitive data.
- Performance of a contract — where processing is necessary to create your account, process a Booking, or deliver a Service you have requested.
- Legal obligation — where we must process data to comply with Nigerian law, tax and financial reporting obligations, or requirements imposed by a Relevant Authority in connection with a visa application.
- Legitimate interests — where processing is necessary for our legitimate business interests (such as fraud prevention, Platform security, or service improvement), provided this is not overridden by your rights and interests.
- Vital interests — in rare cases, where processing is necessary to protect your life or physical safety, such as in a medical or security emergency while travelling.
6How We Use Your Information
6.1We use your personal data to:
- create and manage your JEKAFLY account;
- process and confirm Bookings for flights, accommodation, visa consultations, holiday packages, and travel advisory services;
- prepare and support visa and immigration applications on your behalf, including sharing necessary information with the Relevant Authority, visa application centre, or a named UK host/sponsor;
- communicate with you about your Booking, respond to enquiries, and provide customer support;
- process payments and prevent fraudulent transactions;
- send you service updates, booking confirmations, and, where you have opted in, marketing communications about offers and new services;
- improve the Platform, analyse usage trends, and develop new features;
- comply with our legal, regulatory, and tax obligations, and enforce our Terms & Conditions.
7Cookies and Tracking Technologies
7.1The Platform uses cookies and similar tracking technologies to operate core functionality, remember your preferences, analyse traffic, and, where you consent, personalise marketing content.
7.2In accordance with Article 19 of the NDPC's General Application and Implementation Directive (GAID) 2025, we obtain your prior opt-in consent before placing any non-essential cookie or tracking tool on your device. Strictly necessary cookies required for core security, stability, and accessibility functions do not require consent.
7.3You can manage or withdraw your cookie preferences at any time through the cookie-preference banner on the Platform or through your browser settings. Disabling certain cookies may limit some Platform functionality.
8Sharing and Disclosure of Your Information
We do not sell your personal data. We may share your personal data with:
- Suppliers — airlines, hotels, tour operators, and ground-handling partners, strictly to the extent necessary to fulfil your Booking;
- Relevant Authorities — embassies, high commissions, consulates, visa application centres, and immigration departments, strictly for the purpose of processing a visa or immigration application you have instructed us to support;
- Payment processors — licensed payment gateway providers who process your payment on our behalf;
- Professional advisers — lawyers, auditors, and consultants, where necessary for our legitimate business purposes, under confidentiality obligations;
- Regulators and law enforcement — where required by Nigerian law, court order, or a lawful request from the NDPC or another competent authority;
- Business transfers — a successor entity in the event of a merger, acquisition, or sale of all or part of Kazwhale Concepts Limited's business, subject to that entity assuming equivalent data-protection obligations.
9International Data Transfers
9.1Certain Services, in particular JEKAFLY Visa and JEKAFLY Holidays, necessarily involve transferring your personal data outside Nigeria — for example, to UK Visas and Immigration (UKVI), a foreign visa application centre, an overseas hotel, or an international tour operator.
9.2In accordance with the NDPA, we only transfer personal data outside Nigeria where: (a) the destination country or organisation ensures an adequate level of data protection; (b) appropriate safeguards are in place (such as contractual data-protection clauses with the recipient); (c) you have given explicit, informed consent to the specific transfer; or (d) the transfer is necessary to protect your vital interests or to perform a contract at your request (such as submitting your visa application to a foreign embassy).
10Data Retention
10.1We retain your personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including to provide the Services, comply with our legal and tax obligations, resolve disputes, and enforce our agreements.
10.2As a general guide: account and Booking data is retained for the duration of your relationship with JEKAFLY and for up to six (6) years afterwards for tax, audit, and legal-claim purposes; visa application documents are retained for the period necessary to support the specific application and any related follow-up, after which they are securely deleted or anonymised unless a longer retention period is required by law.
11Data Security
11.1We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, including encrypted data transmission (HTTPS/TLS), access controls limiting staff access to personal data on a need-to-know basis, and secure storage of physical documents.
11.2In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the NDPC within the timeframe required by the NDPA (currently 72 hours of becoming aware of the breach) and will notify affected Users without undue delay where required.
12Children's Privacy
12.1The Platform is not intended for use by individuals under the age of 18 acting independently. Where a minor's personal data is processed (for example, as a travelling companion or dependant on a family Booking or visa application), it is processed on the basis of consent given by, and under the supervision of, their parent or legal guardian, who accepts responsibility for the accuracy of that information.
13Your Rights Under the Nigeria Data Protection Act 2023
As a data subject, you have the following rights in respect of your personal data, subject to applicable exceptions under the NDPA:
- Right of access — to request confirmation of whether we process your data, and to obtain a copy of it;
- Right to rectification — to request correction of inaccurate or incomplete personal data;
- Right to erasure — to request deletion of your personal data where it is no longer necessary for the purpose collected, or where you withdraw consent and no other legal basis applies;
- Right to restrict processing — to request that we limit how we use your data in certain circumstances;
- Right to object — to object to processing based on legitimate interests, and an unconditional right to object to direct marketing at any time;
- Right to data portability — to receive your personal data in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible;
- Right to withdraw consent — at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
- Right to protection from solely automated decision-making — to obtain human review of, express your view on, and contest any decision based solely on automated processing that significantly affects you;
- Right to lodge a complaint — with the Nigeria Data Protection Commission (NDPC), if you believe your data protection rights have been violated.
To exercise any of these rights, please contact us at Kazwhaleconcepts@gmail.com. We will respond within the timeframe required by the NDPA. We may need to verify your identity before actioning certain requests.
14Marketing Communications and Opt-Out
14.1Where you have opted in to receive marketing communications from JEKAFLY (such as promotional offers, newsletters, or updates on new destinations and packages), you may withdraw your consent and opt out at any time by using the "unsubscribe" link in any marketing email, adjusting your notification preferences in your account settings, or contacting us directly.
14.2Transactional communications relating to your Bookings (such as confirmations, itinerary updates, and payment receipts) are not marketing communications and will continue to be sent as necessary to deliver the Services you have requested.
15Third-Party Links
15.1The Platform may contain links to third-party websites, including airline, hotel, or government visa portals. This Privacy Policy does not apply to those third-party sites, and we encourage you to review their respective privacy policies before submitting any personal data to them.
16Data Breach Notification
16.1We maintain internal procedures to detect, investigate, and respond to any suspected personal data breach. Where a breach is likely to result in a risk to your rights and freedoms, we will notify the NDPC and affected data subjects in accordance with the timelines and requirements of the NDPA.
17Changes to This Privacy Policy
17.1We may update this Privacy Policy from time to time to reflect changes in our practices, Services, or legal requirements. The updated policy will be posted on the Platform with a revised "Effective Date", and material changes will, where reasonably practicable, be notified to registered Users by email or in-app notice.
18How to Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact:
- Kazwhale Concepts Limited (Data Protection Officer / Compliance Lead)
- 13, Ayinke Street, Akoka, Lagos, Nigeria
- Email: Kazwhaleconcepts@gmail.com
- Phone: +234 818 653 7678
19Right to Lodge a Complaint with the NDPC
If you are not satisfied with our response to a data protection concern, or believe we have processed your personal data unlawfully, you have the right to lodge a complaint directly with Nigeria's data protection regulator:
- Nigeria Data Protection Commission (NDPC)
- No. 12 Clement Isong Street, Asokoro, Abuja, Nigeria
- Website: www.ndpc.gov.ng
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