Privacy Policy
Last updated: 14 Oct 2026
Effective Date: 5 October 2026
This Privacy Policy explains how PivotWings (“PivotWings”, “we”, “our”, or “us”) collects, uses, shares, and protects personal data when you use the PivotWings platform, including our websites, applications, and related services (collectively, the Services). It applies to Seekers, Guardians, employers, affiliates, interns, event attendees, and visitors. Our Cookie Policy forms part of this Privacy Policy and is set out below.
We process personal data in line with the Nigeria Data Protection Act 2023 and, where they apply to you, the EU and UK General Data Protection Regulation (GDPR) and other applicable data protection laws. PivotWings is the data controller for the personal data described in this policy.
Data We Collect
Data you give us
- Account and profile data: name, email address, phone number, password, country and city, profile photo, bio, education, work history, skills, career goals, CV or resume, and links to your professional profiles.
- Guardian data: professional background, areas of expertise, session prices, availability, and payout and identity details needed to pay you.
- Employer data: company name, contact details, job listings, and candidate or employee data you upload to employer tools.
- Learning data: courses and e-books you access, progress, quiz and assignment answers, Skill Test answers and results, career roadmap, growth management checklist entries, and self-assigned tasks.
- Booking and session data: booking details, session times, messages between Seekers and Guardians, and ratings and reviews.
- Payment data: plan purchased, amount, date, gift recipients, and transaction reference. Card and bank details are collected and processed by our payment providers; we do not store your full card details.
- Community content: posts, comments, reactions, and messages you share.
- Application data: information you submit for PivotWings Launchpad, the affiliate programme, events, or podcast and live session guest spots.
- Communications: messages you send to support and your email preferences.
Data collected automatically
- Device and usage data: IP address, browser and device type, pages viewed, features used, clicks, time spent, and referring links, including affiliate links.
- Video call data: call connection data such as join and leave times, call duration, and technical quality data. Audio and video are transmitted to provide the call and are not recorded by PivotWings unless a recording notice is shown to all participants.
- Cookies and similar technologies: as described in the Cookie Policy section below.
Data from others
Employers or partners who refer you to opportunities, affiliates who refer you to PivotWings, and people who gift you a subscription (your name and email).
Google, if you choose to sign in with Google or connect Google Calendar, as described in the Google User Data and Google Calendar section below.
How We Use Your Data
| How We Use Your Data | Legal Basis |
|---|---|
| Create and manage your account and deliver the Services, including courses, e-books, bookings, video sessions, Career Development, and Skill Tests. | Contract |
| Process payments, subscriptions, gifts, refunds, Guardian payouts, and affiliate commissions. | Contract; Legal obligation |
| Generate your career roadmap, recommendations, and AI-assisted learning content and feedback. | Contract; Legitimate interest |
| Match Seekers with Guardians, jobs, internships, and employers, including sharing Skill Test results and profile data with employers where you allow it. | Consent; Contract |
| Review applications for Launchpad, events, and the affiliate programme. | Contract; Legitimate interest |
| Send service emails such as booking confirmations, receipts, and account notices. | Contract |
| Send career insights, newsletters, job alerts, and offers. | Consent or legitimate interest; you can unsubscribe at any time |
| Measure and improve the Services, run analytics, and measure our advertising. | Consent (for non-essential cookies); Legitimate interest |
| Keep the Services safe, prevent fraud and cheating, and enforce our Terms of Use. | Legitimate interest; Legal obligation |
| Meet tax, accounting, and other legal duties. | Legal obligation |
AI Features
Some features use artificial intelligence to build career roadmaps, recommend content, generate learning materials, and give feedback on your answers. To do this, we send the relevant inputs, such as your profile, goals, and questions, to third-party AI model providers acting on our behalf. These providers may only process the data to deliver the feature to you and may not use it to train their own models.
AI features do not make decisions that have legal or similarly significant effects on you. Hiring decisions are made by employers, not by PivotWings' AI features. Please do not enter sensitive personal data, such as health or financial information, into AI features.
Google User Data and Google Calendar
PivotWings offers two optional Google features: signing in with your Google account, and connecting Google Calendar so your PivotWings sessions appear in your calendar. This section explains exactly what Google user data we access through these features, how we use it, and the choices you have.
Sign in with Google
If you sign in or sign up with Google, Google shares your name, email address, and profile photo with us, along with a Google account identifier. We use this only to create and secure your PivotWings account, sign you in, and show your name and photo on your profile. We do not receive your Google password.
Google Calendar
Connecting Google Calendar is optional and only happens when you choose “Connect to your calendar” and approve access on Google’s consent screen. We request one Google Calendar permission, “View and edit events on all your calendars” (the “calendar.events” scope). We use this permission only to add your PivotWings sessions to your calendar.
- What we do: when you book, host, reschedule, or cancel a PivotWings session, we create, update, or remove the matching event in your Google Calendar. The event contains the session title, date and time, and the link to join the session on PivotWings.
- What we do not do: we do not read, collect, analyse, or store your other calendar events, and we do not change or delete any event that PivotWings did not create.
- What we store: the email address of the Google account you connected, the authorisation tokens Google issues so we can keep your sessions in sync, and the identifiers of the events PivotWings created, so we can update or remove them later. Tokens are kept on our secure servers and are never shown to other users.
How we protect and limit Google user data
- We use Google user data only to provide the features described above, which you can see and control in PivotWings.
- We do not sell Google user data, and we do not use it for advertising, for building user profiles for third parties, or to determine creditworthiness or lending eligibility.
- We do not use Google user data to develop, improve, or train generalised artificial intelligence or machine learning models, and we do not send it to AI model providers.
- We do not share or transfer Google user data to anyone, except service providers that host our systems on our behalf, where needed to comply with the law, or as part of a merger or acquisition with notice to you.
- No PivotWings staff member reads Google user data unless you ask us to for support, it is needed for security purposes such as investigating abuse, or the law requires it.
PivotWings’ use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.
Disconnecting and deletion
You can disconnect Google Calendar at any time, either from PivotWings or from your Google Account at https://myaccount.google.com/permissions. When you disconnect, we stop syncing and delete the authorisation tokens we hold for your calendar. Session events already added to your calendar stay there until you delete them in Google Calendar. If you delete your PivotWings account, we delete the Google user data we hold about you as described in the Data Retention section. You can also ask us to delete it at any time by contacting support.
International Transfers
Some of our service providers are located outside Nigeria and outside your country. When we transfer personal data abroad, we use safeguards required by applicable law, such as standard contractual clauses or transfers to countries with adequate data protection.
Data Retention
We keep your personal data for as long as your account is active and as long as needed to provide the Services. When you delete your account, we delete or anonymise your personal data within ninety (90) days, except where we must keep it longer to meet legal, tax, or accounting duties, resolve disputes, or prevent fraud. Payment and payout records are kept for the period required by tax law.
Data Security
We use technical and organisational measures to protect your personal data, including encrypted connections, access controls, and secure payment processing by our providers. No system is fully secure, so please use a strong password and keep it private.
Your Rights
Depending on where you live, you have the right to:
- access the personal data we hold about you;
- correct inaccurate or incomplete data;
- delete your data;
- object to or restrict how we use your data;
- receive your data in a portable format;
- withdraw consent at any time, without affecting earlier processing;
- opt out of marketing emails using the unsubscribe link in any email.
To use these rights, email support@pivotwings.com. We will respond within thirty (30) days. If you are not satisfied with our response, you may complain to the Nigeria Data Protection Commission or to the data protection authority in your country.
Children
The Services are for people aged eighteen (18) and over. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we will delete it.
Changes to This Policy
PivotWings may update this Privacy Policy, including the Cookie Policy, from time to time to reflect changes in technology, legal requirements, or operational practices. Updated versions will be posted with a revised effective date. Where changes are significant, we will notify you by email or through the Services.
Contact
For privacy or cookie questions or requests, contact support@pivotwings.com.