COOKIE POLICY
CONFIDENTIALITY
This document is a property of Interconnect Clearinghouse Nigeria Limited and shall under no circumstances be copied, sold or reproduced for private or commercial use without the express permission of the Company.
1. Introduction
Interconnect Clearinghouse Nigeria Limited ("ICNL", "we", "us" or "our") operates the website at www.interconnectnigeria.com (the "Website"). This Cookie Policy explains what cookies are, how we use them, and how you can manage your preferences.
This policy is issued in compliance with Section 24(1)(d) of the Nigeria Data Protection Act 2023 (NDP Act) and Article 19 of the NDP Act General Application and Implementation Directive (GAID) 2025. By continuing to use our Website after being presented with our cookie notice, you acknowledge that you have read and understood this policy.
2. What Are Cookies?
Cookies are small text files stored on your device (computer, tablet, or mobile phone) when you visit a website. They are widely used to make websites work efficiently, improve user experience, and provide information to website operators. Cookies may be:
- Session cookies — temporary cookies that expire when you close your browser.
- Persistent cookies — cookies that remain on your device for a set period or until manually deleted.
- First-party cookies — set directly by ICNL.
- Third-party cookies — set by external providers we use (e.g. Google Analytics).
3. Categories of Cookies We Use
3.1 Essential Cookies (Always Active)
These cookies are strictly necessary for the Website to function. They enable core features such as page navigation, secure login, and CSRF protection. They do not collect personal data for marketing purposes and cannot be disabled without significantly affecting website functionality.
3.2 Non-Essential Cookies (Require Your Consent)
These cookies are not strictly necessary for the Website to operate. They collect data for analytics and performance measurement purposes. We will only activate these cookies after obtaining your explicit, freely-given consent.
4. Complete List of Cookies Used on This Website
The table below sets out every cookie currently used on our Website, categorised by type, purpose, data collected, and retention period.
| Cookie Name | Category | Set By | Purpose | Data Collected | Retention Period |
|---|---|---|---|---|---|
cookieConsent |
Essential | ICNL (First-party) | Stores the user's cookie consent preferences to avoid repeated prompts. | Consent choices (yes/no per category). No personal identifiers collected. | Persistent — expires after 12 months |
PHPSESSID / Session Token |
Essential | ICNL (First-party) | Maintains user session state and enables access to secure areas of the Website. | Session identifier only. No personal or sensitive data. IP addresses are not stored. | Session — deleted when the browser is closed |
csrf_token |
Essential | ICNL (First-party) | Cross-Site Request Forgery (CSRF) protection. Prevents unauthorised commands from a user's browser. | Randomly generated token only. No personal data collected. | Session — deleted when the browser is closed |
_ga |
Non-Essential | Google Analytics (Third-party) | Distinguishes unique users to generate statistical usage reports for the Website. | Anonymised Client ID, approximate geographic location (country/city level), browsing behaviour (pages visited, time on site, referral source). IP addresses are anonymised by Google before storage. | Persistent — expires after 24 months |
_ga_[ID] |
Non-Essential | Google Analytics (Third-party) | Maintains session state for Google Analytics 4 measurement. | Session data and page interaction events. IP addresses anonymised. | Persistent — expires after 24 months |
_gid |
Non-Essential | Google Analytics (Third-party) | Distinguishes users for analytics purposes within a short window. | Anonymised session identifier and browsing behaviour within the visit. | Session — expires after 24 hours |
_gat |
Non-Essential | Google Analytics (Third-party) | Throttles the Google Analytics request rate on high-traffic pages. | No personally identifiable information collected. | Session — expires after 1 minute |
* Google Analytics data is processed in accordance with Google's Privacy Policy at policies.google.com/privacy. ICNL has enabled IP anonymisation on all Google Analytics tracking.
5. Information Gathered by Cookies
Depending on your consent choices, cookies on this Website may collect the following types of information:
- IP Address (anonymised): Google Analytics anonymises IP addresses before storage. ICNL's own essential cookies do not collect or store IP addresses.
- Browsing behaviour: Pages visited, links clicked, time spent on pages, and navigation path through the Website.
- Device and browser information: Browser type, operating system, screen resolution, and device category (desktop, mobile, tablet).
- Geographic location (approximate): Country and city-level location derived from anonymised IP data. Precise location is not collected.
- Referral source: How you arrived at the Website (e.g. search engine, direct link, referring website).
- Session identifiers: Randomly generated tokens to maintain your session. These are not linked to any personal identity.
- Consent record: Your cookie preferences stored locally on your device and, where applicable, logged on our servers for audit purposes.
We do not use cookies to collect sensitive personal data such as financial information, health data, or National Identification Numbers.
6. Legal Basis for Processing
- Essential cookies: Processed on the basis of legitimate interests and the necessity to deliver the service requested (Section 25(1)(b) and (e), NDP Act 2023).
- Non-essential cookies (Analytics): Processed only on the basis of your freely given, specific, and informed consent (Section 25(1)(a), NDP Act 2023). You may withdraw consent at any time without detriment.
7. How to Manage Your Cookie Preferences
7.1 Via Our Cookie Banner
When you first visit our Website, you will be presented with a cookie consent banner. You may click "Accept All" to consent to all categories, "Reject All" to decline all non-essential cookies, or "Cookie Settings" to review and save individual preferences. You may revisit your preferences at any time using the "Manage Cookies" button at the bottom-right of any page.
7.2 Via Your Browser Settings
You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. Refer to your browser's help documentation for instructions: Google Chrome | Mozilla Firefox | Microsoft Edge | Apple Safari
Please note that blocking or deleting essential cookies may affect your ability to use certain features of our Website.
7.3 Google Analytics Opt-Out
You may opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on.
8. Consent Records and Audit
In accordance with Article 19 of the NDP Act GAID 2025, ICNL maintains proper records of cookie consent. Each consent interaction is recorded with the following details:
- Timestamp of consent action (date and time)
- Categories of cookies accepted or declined
- Version of this Cookie Policy in effect at the time of consent
- The page on which consent was collected
These records are reviewed and audited on a quarterly basis as part of ICNL's data protection compliance programme. Consent records are retained for a period of 3 years in line with our Records Retention Schedule.
9. Your Rights and How to Lodge a Grievance
Under the Nigeria Data Protection Act 2023, you have the right to:
- Withdraw consent for non-essential cookies at any time without detriment.
- Request information about the cookies we use and the data collected.
- Request erasure of data collected about you through cookies (where technically feasible).
- Lodge a complaint with our Data Protection Officer (DPO).
- Escalate unresolved complaints to the Nigeria Data Protection Commission (NDPC).
10. Contact Details of Our Organisation
Data Protection Officer (DPO) — Interconnect Clearinghouse Nigeria Limited
11. Changes to This Cookie Policy
We review this Cookie Policy at least annually or whenever there is a material change to our use of cookies, applicable law, or regulatory guidance. The "Last Reviewed" date in the version bar above will be updated accordingly. Where changes are significant, we will notify users via a prominent notice on the Website and, where appropriate, request fresh consent.
For more details about how we process personal data generally, please see our Privacy Policy.