1. Synopsis
- This policy clarifies when and why personal information about our website visitors is collected, its usage, security and your rights as data subject.
- The collection, usage and storage of your data can be done as described in this Data Privacy Policy and as defined when we collect data from you.
- Amendment to this Data Privacy Policy may be made from time to time without prior notice. This amendment to Data Privacy Policy may be due to regulations. However, for any major changes, you will be informed. So you are advised to check our website for the latest Privacy Policy.
- We always comply with Nigeria Data Protection Regulation (NDPR) when dealing with your data. For this reason, we will be the “controller” of all personal data we hold about you.
2. Collecting Personal Information
The following types of personal information may be collected, stored, and used:
- Information about your computer including your IP address, geographical location, browser type and version, and operating system;
- Information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
- Information, such as your email address, that you enter when you register with our website;
- Information that you enter when you create a profile on our website—for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
- Information, such as your name and email address, that you enter to set up subscriptions to our emails and/or newsletters;
- Information that you enter while using the services on our website;
- Information that is generated while using our website, including when, how often, and under what circumstances you use it;
- Information relating to services you use, or transactions you make through our website, which includes your name, address, telephone number, email address, etc.
- Information that you post to our website with the intention of publishing it on the internet, which includes your username, profile pictures, and the content of your posts;
- Information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
- Any other personal information that you send to us.
- Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. Using your personal information
Personal information forwarded to us via our website will be utilized for the purposes specified in this policy or on the appropriate pages of the website. We may use your personal information for the following:
- administering our website and business;
- personalizing our website for you;
- enabling your use of the services available on our website;
- sending account statements, contract notes, cscs statements etc;
- sending you non-marketing commercial communications;
- sending you email notifications that you have specifically requested;
- sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
- sending you marketing communications on our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
- providing third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
- dealing with inquiries and complaints made by or about you on our website
- keeping our website secure and to prevent fraud
- verifying compliance with the terms and conditions governing use of our website (including monitoring private messages sent through our website private messaging service);
If you submit personal information for publication on our website, we will publish and/or otherwise use that information in accordance with the license you grant to us.
Your privacy settings can be used to limit the publication of your information on our website and can be adjusted using privacy controls on the website.
We will not, without your express consent, supply your personal information to any third party for their or any other third party’s direct marketing.
4. Disclosing Personal Information
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably needed for the purposes set out in this policy.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.
Disclosure of your personal information will be done:
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
- to any person who we reasonably believe has applied to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
- Except as provided in this policy, we will not provide your personal information to third parties.
5. International Data Transfers
- Information that we collect may be stored, processed, and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy.
- Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in Nigeria, the United States of America, Russia, Japan, China, and India.
- Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
- You expressly agree to the transfer of personal information described in this Section
6. Retaining Personal Information
- Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
- Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- Without prejudice, we will usually delete personal data based on our data retention policy.
- Notwithstanding the other provisions, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise, or defend our legal rights (including providing information to others for fraud prevention and reducing credit risk).
7. Security of your personal information
- Reasonable technical and organizational precautions will be taken to prevent loss, misuse, or alteration of your personal information.
- All personal information provided will be stored on our secure (password – and firewall-protected) servers.
- All electronic financial transactions entered into through our website will be protected by encryption technology.
- Acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
- You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
8. Amendments
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.
9. Third - party websites
Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. Your rights
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the following:
- Paying a service fee where applicable; and
- The supply of appropriate evidence of your identity:
- International Passport
- Passport Photograph
- Driver’s License
- Voters card
- National Identification Number (National ID Card)
3. To access your data
4. To be provided with information about how your data is processed
5. To have your data corrected
6. To have your data erased in certain circumstances
7. To object to or restrict how your data is processed
8. To have your data transferred to you or to another business in certain circumstances.
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt- out of the using of your personal information for marketing purposes.
For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Officer
12. Our Contact:
Futureview Plaza
22 Oju Olobun Street
Victoria Island
Lagos.
Tel: +234: 01 – 280 5410, 01 – 2805411,
