TABLE OF CONTENTS
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- PERSONAL DATA PROTECTION PRINCIPLES
- YOUR LEGAL RIGHTS
- CONSENT AND ACCESS RIGHTS
- VIOLATIONS OF PRIVACY
- CONTACT US
1. IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly or intentionally collect data relating to any person below thirteen (13) years.
(b) WHO IS THE CONTROLLER?
DETAIL is the controller of the personal data you submit to us and responsible for your personal data under applicable data protection laws.
You have the right to make a complaint at any time to your jurisdiction’s supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach your jurisdiction’s supervising authority so please contact us in the first instance at email@example.com
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
(d) DOES THIS WEBSITE CONTAIN THIRD-PARTY LINKS?
2. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
Personal data or personal information means any information about a natural person from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address, fax and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of services you have received from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes any username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
(a) WHAT HAPPENS IF YOU FAIL TO PROVIDE PERSONAL DATA?
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data when filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make an inquiry or engage our services;
- subscribe to our newsletters or publications;
- request marketing materials be sent to you;
- register to receive updates about our events and to attend our events and provide your contact information;
- in the course of our recruitment process; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below
- Technical Data from analytics and search information providers, such as Google;
- Contact and Transaction Data from providers of technical, payment and delivery services such as based inside or outside the Nigeria.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have given consent (where necessary) for our use in a specific purpose or the organization you work for has obtained your consent (where necessary) to share your information with us.
- Where we need to perform a contract we are about to enter into or have entered into with you. [See below meaning of Performance of Contract].
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. [See below meaning of Legitimate Interest].
- Where we need to comply with a legal obligation. [See below meaning of Legal Obligation].
Consent means freely given, specific, informed and unambiguous indication that you wish to allow us to process your data.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data where the law allows us. However, we will get your consent before sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org
(a) WHAT ARE THE PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA?
We have set out below, in a table format, a description of some of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data||Lawful basis for processing including basis of legitimate interest|
To register you as a new client
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our content and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our services and grow our business)
(b) HOW DO WE USE YOUR PERSONAL DATA FOR MARKETING?
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and information may be relevant to send you (we call this marketing).
You will receive marketing communications from us if you have subscribed to our mailing list and expressly consented to receive information such as our newsletters, events, news and updates.
(c) CAN YOU WITHDRAW YOUR CONSENT FROM RECEIVING MARKETING MATERIALS?
If you receive marketing materials relating to our services by email, you may withdraw your consent for us to send these to you at any time, by clicking the “unsubscribe” option included in the marketing email. Alternatively, you can let us know your preferences by sending an email to email@example.com.
(d) DO WE SHARE YOUR PERSONAL DATA FOR THIRD-PARTY MARKETING?
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
(e) HOW CAN YOU OPT OUT OF RECEIVING MARKETING MESSAGES?
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links and instructions on any marketing emails sent to you or by contacting us at any time at firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of engaging our services or other transactions.
(g) WHAT IF THERE IS A CHANGE OF PURPOSE FOR OUR USE OF YOUR PERSONAL DATA?
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHAT THIRD PARTIES MAY WE DISCLOSE YOUR PERSONAL DATA?
We may share your personal data with the parties set out below for the purposes set out in the table above on “Purposes for which We Will Use Your Personal Data”.
- Internal Third Parties, which are other entities within DETAIL acting as joint controllers and who provide IT and system administration services and undertake leadership reporting.
- External Third Parties which are:
- Service providers, acting as processors, who provide IT and system administration services.
- Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. HOW DO WE HANDLE INTERNATIONAL TRANSFERS OF YOUR DATA?
Whenever we transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented. Where we use certain service providers, we will only use providers which give personal data the same degree of protection required under the laws and regulations in Nigeria.
(a) WE MAY ALSO TRANSFER PERSONAL DATA OUTSIDE NIGERIA IN THE FOLLOWING CIRCUMSTANCES:
- Where you have consented to the transfer of your personal data outside Nigeria.
- The transfer is necessary for the performance of a contract between you and DETAIL, or the implementation of pre-contractual measures taken at your request.
- The transfer is necessary for the conclusion or performance of a contract concluded in your interest between DETAIL and another natural or legal person.
- The transfer is necessary for important reasons of public interest.
- The transfer is necessary for the establishment, exercise or defence of legal claims.
- The transfer is necessary in order to protect your vital interest or the vital interest of other persons, where you are physically or legally incapable of giving consent.
(b) BY CONSENTING TO THE PROCESSING OF YOUR PERSONAL DATA, YOU CONSENT TO THE TRANSFER OF YOUR PERSONAL DATA OUSIDE NIGERIA.
7. DO WE HAVE DATA SECURITY IN PLACE?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see section on “YOUR LEGAL RIGHTS” below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. PERSONAL DATA PROTECTION PRINCIPLES
We are guided by the following principles when processing your personal data. The personal data shall be:
- collected only for specific, legitimate and lawful purposes;
- processed lawfully for the purpose for which it was collected and not further processed in a manner incompatible with which that purpose(s);
- processed adequately, accurately and without prejudice to the dignity of the human person;
- adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed;
- accurate and where necessary, kept up to date;
- stored only for the period within which it is reasonably needed; and
- processed in a secure manner and protected against unauthorised or unlawful access or processing or accidental loss, destruction or damage.
10. WHAT ARE YOUR LEGAL RIGHTS?
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish your personal data’s accuracy.
- Where our use of the personal data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our processing of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
(a) WHAT MAY WE NEED FROM YOU?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
(b) WHAT IS THE TIME LIMIT IN WHICH WE ARE TO RESPOND?
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. CONSENT AND ACCESS RIGHTS
We will obtain your consent prior to collecting or processing your personal data. Where we intend to use the information for any purpose other than the purpose for which it was collected, prior to such use, we will request your consent.
No consent shall be sought, given or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.
You may withdraw your consent at any time and may request access to your personal data in our possession. Such withdrawal will not affect the lawfulness of the processing of your personal data prior to the withdrawal of your consent. We can, however, deny you access to the information where we determine that your request is unreasonable.
You have the right to request the modification or amendment of your personal data in our possession.
In all cases of access or request for modification or amendment of personal data, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed, modified or amended.
12. VIOLATIONS OF PRIVACY
We will take all necessary steps and action to remedy all suspected personal data breach within one month from date of breach.
If you know or suspect that a breach of personal data or a violation of this policy has occurred, immediately contact us at firstname.lastname@example.org
We will not be responsible for any personal data breach which occurs as a result of;
- An event which is beyond our control.
- An act or threats of terrorism.
- An act of God (including but not limited to fires, explosions, earthquakes, floods, epidemics, or pandemics) which compromises our data protection measures).
- War, hostilities (whether war be declared or not), invasion, act of foreign enemies, requisition, or embargo, rebellion, revolution, insurrection, or military or usurped power, or civil war.
- The transfer of your personal data to a third-party n your instruction.
- The use of personal data by a third party designated by you.