This policy explains how Opeyemi Akinlolu, trading as McBilly Exploits (registration number 2162886), collects, uses, stores, shares, and protects personal data when you use PM Career Lab.
1. Who we are
McBilly Exploits is the data controller for PM Career Lab. Our address is 130 Akerele Street, Surulere, Lagos, Nigeria. Privacy enquiries can be sent to privacy@opeyakinlolu.com.ng.
2. Scope
This policy applies to the invite-only PM Career Lab website, learner simulations, assessments, facilitator and administrator tools, support communications, and associated security and audit records. It does not apply to third-party services you choose to access separately.
3. Information we collect
- Account and profile information, including name, email, role, cohort, target role, experience level, and learning goals.
- Invite, entitlement, activation, and consent records.
- Simulation activity, work products, decisions, messages, ceremony transcripts, progress, scores, feedback, and portfolio material.
- AI interactions, including prompts, responses, safety events, model/provider metadata, token usage, latency, and cost records.
- Technical, security, and audit data, such as IP-derived security information, device/browser information, timestamps, and access logs.
- Support, privacy-rights, and other correspondence.
- Payment and billing records where paid services are offered. Payment-card details are handled by the payment provider and are not intended to be stored by us.
Do not enter real confidential, sensitive, special-category, client, employer, patient, customer, or government data into a simulation. Scenarios use fictional data. If you include personal data in free text, you are responsible for having authority to do so.
4. How we collect information
We collect data from you when an account is invited or activated, while you use the service, when a facilitator or administrator manages a cohort, and automatically through essential service logs. We may receive limited information from identity, hosting, database, payment, support, analytics, or AI providers used to operate the service.
5. Why we use personal data
- To provide accounts, simulations, assessment, coaching, feedback, certificates, and portfolio features.
- To administer cohorts, invitations, entitlements, support, and service communications.
- To maintain security, prevent abuse, investigate incidents, enforce our terms, and keep audit records.
- To understand and improve product performance, accessibility, reliability, and learning outcomes.
- To comply with law, exercise or defend legal claims, and meet accounting or regulatory duties.
Depending on the activity and applicable law, our legal basis is performance of a contract, legitimate interests, consent, or compliance with a legal obligation. Where processing is based on consent, you may withdraw it without affecting processing already carried out.
6. AI-assisted features
PM Career Lab may use AI providers, including Anthropic or OpenAI where enabled, to generate fictional stakeholder dialogue, coaching, hints, summaries, and assessment support. AI can be inaccurate. Outputs are educational aids and must not be treated as professional advice or as the sole basis for employment, disciplinary, legal, financial, medical, or other high-impact decisions.
We minimise the data sent to an AI provider and apply configuration, access, logging, budget, and kill-switch controls. Do not submit real confidential or sensitive information. Provider availability may change and AI features may be disabled without disabling the core service.
7. Sharing and processors
We may share data with contracted providers supporting hosting, databases, authentication, email, payments, analytics, customer support, security, and AI functionality. They may process data only for agreed purposes and subject to appropriate safeguards. We may also disclose information when required by law, to protect rights or safety, during a business reorganisation, or with your direction. We do not sell personal data.
8. International transfers
Providers may process data outside Nigeria or your country. Where required, we use contractual, organisational, and technical safeguards appropriate to the transfer and the destination.
9. Retention
Unless law, a dispute, or a documented legal hold requires longer retention, our standard schedule is:
- Invite tokens: until expiry or acceptance, then up to 12 months.
- Account and profile data: while active, then up to 24 months after closure or last activity.
- Simulation, progress, work-product, and assessment data: while active, then up to 24 months.
- AI interaction records: 12 months.
- Security and audit logs: 12 months.
- Support and rights correspondence: 24 months.
- Billing records: for the period required by applicable tax and accounting law.
- Backups: normally no more than 90 days after deletion from active systems, unless subject to legal hold.
- Consent and suppression records: for as long as reasonably needed to demonstrate or respect your choices.
We delete, anonymise, or aggregate data when it is no longer needed.
10. Security
We use role-based access, least-privilege controls, authentication safeguards, encryption in transit, provider controls, audit logging, backups, monitoring, and incident procedures proportionate to the service. No system is completely secure, so users must protect passwords and promptly report suspected compromise to security@opeyakinlolu.com.ng.
11. Your rights
Subject to applicable law, you may request access, correction, deletion, restriction, objection, portability, or withdrawal of consent, and may complain to the Nigeria Data Protection Commission or another competent authority. Send requests to privacy@opeyakinlolu.com.ng. We may verify identity before responding and may retain data where law or overriding legitimate grounds require it.
12. Children
The service is intended for adults and authorised professional learners. It is not directed to children, and we do not knowingly collect children's personal data. Contact us if you believe a child has provided data.
13. Cookies and similar technology
We use strictly necessary cookies and local storage for authentication, security, preferences, and core operation. Non-essential analytics or marketing technologies will not be used without any consent required by applicable law.
14. Changes to this policy
We may update this policy. The displayed version and effective date identify the text in force. If a change is material, we will provide appropriate notice and require a new acceptance before continued use where appropriate.
15. Contact and complaints
Privacy: privacy@opeyakinlolu.com.ng. Security: security@opeyakinlolu.com.ng. General enquiries: opey@opeyakinlolu.com.ng. Website: www.lab.opeyakinlolu.com.ng.
16. Controller details
Opeyemi Akinlolu trading as McBilly Exploits, registration number 2162886, 130 Akerele Street, Surulere, Lagos, Nigeria.