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Privacy Policy

1. Introduction

Welcome to the Nigeria SE4All Website (“We”, Our” or “Us”) Privacy Policy.

We respect your privacy and are committed to protecting your Personal Data. This Privacy Policy will inform you as to how we collect, use, share and look after your Personal Data when you visit our Website (regardless of where you visit from) or use our Content and tell you about your privacy rights and how the law protects you.

2. The Information that We Collect

We may collect personal data i.e. any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM, Personal Identifiable Information (PII) and others.(‘Personal Data’).

3. How We Collect, Process and Share Personal Data

3.1
We may collect your Personal Data using forms, email and physical requests, cookies, JWT, web tokens, or third-party applications. You can set your browser to refuse all or some browser cookies, or to alert you if we access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.
3.2
We may use the above-mentioned information for, human resources management; access to computer systems and third party software; due diligence purposes; recruitment purposes; regulatory compliance; compliance with legal obligation; litigation; events planning and hosting; marketing, in-house security; research, analysis, and other business purposes or legitimate interests.
3.3
When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests or improve our services provided on the Website. We may also collect information in the course of providing our services to you. Our servers automatically record information that your browser sends whenever you visit our website.

4. Consent and Access Rights

4.1
We will obtain your consent prior to collecting or processing your Personal Data. Where we intend to use the information for a purpose other than the purpose for which it was collected, prior to such use, we will request your consent.
4.2
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.
4.3
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.
4.4
You have the right to request the modification or amendment of your Personal Data in our possession.
4.5
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.
4.6
Where you provide the Personal Data of a third party to us, you confirm to us that you have informed the owner of the data about the purpose for which the data is required and that you have obtained the consent of the owner of the data to provide the data to us for the purpose for which it is required and in accordance with this Privacy Policy.

5. Personal Data Protection Principles

When we process your Personal Data, we are guided by the following principles. Your Personal Data shall be:

(a)
collected only for specific, legitimate and lawful purpose;
(b)
processed lawfully for the purpose for which it was collected and not further processed in a manner incompatible with such purpose(s);
(c)
processed adequately, accurately and without prejudice to the dignity of the human person;
(d)
adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed;
(f)
accurate and where necessary, kept up to date;
(g)
stored only for the period within which it is reasonably needed, and
(h)
processed in a secure manner and protected against unauthorised or unlawful access or processing or accidental loss, destruction or damage.

6. Security Measures

We have put in place and will maintain appropriate security measures to prevent your Personal Data from being used, accessed, altered or disclosed in an unauthorised way.

7. Third Party Access

We may share your Personal Data with third parties in the following circumstances.

(a)
here we have your consent;
(b)
Personal Data may be shared with our parent company(ies), subsidiaries or affiliates;
(c)
We provide such information to other professional advisers or other trusted businesses or persons for the purpose of processing Personal Data on our behalf or other legitimate business purposes. We would require such parties to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
(d)
We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce applicable terms of service, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to our rights, property or safety as required or permitted by law.

8. Transfer of Personal Data Outside the Country

8.1
We may transfer your Personal Data outside Nigeria in the following circumstances:
(a)
with your consent;
(b)
the transfer is necessary for important reasons of public interest;
(c)
the transfer is necessary for the establishment, exercise, or defence of legal claims;
(d)
the transfer is necessary in order to protect your vital interests; or of other persons, where you are physically or legally incapable of giving consent.
8.2
Upon the transfer of information outside Nigeria, some principles of data protection may be violated in the receiving country. By consenting to the processing of your personal information, you consent to the transfer of your personal information outside Nigeria.

9. Retention of Personal Data

9.1
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 or 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 prospect of litigation in respect to our relationship with you. Where information is kept for a longer period, such as in back up storage, or archives, such information would be safeguarded in accordance with this Privacy Policy.
9.2
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, reporting or other requirements.
9.3
Where any information retained is stored in an encrypted format, considerations must be taken for secure storage of the encryption keys. Encryption keys must be retained as long as data that the keys decrypt is retained.
9.4
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 retain and use this information indefinitely without further notice to you.

10. Violations

10.1
We will take swift action to remedy any suspected breaches of your Personal Data.
10.2
We will not be responsible for any breach of your Personal Data which occurs as a result of:
(a)
an event which is beyond our control;
(b)
an act or threats of terrorism;
(c)
any act of God (including but not limited to fires, explosions, earthquakes, floods, epidemics, or pandemics) which compromises our data protection measures;
(d)
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 which compromises our data protection measures;
(e)
the transfer of your Personal Data to a third party on your instructions; or
(f)
the use of your Personal Data by a third party designated by you.
10.3
Violations of this Privacy Policy by our employees may result in disciplinary action.

11. Legal Rights

11.1
You have the right to:
(a)
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.
(b)
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.
(c)
request erasure of your Personal Data. This enables you to ask us to delete or remove your 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, 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.
(d)
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.
(e)
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:
(i)
If you want us to establish the data's accuracy.
(ii)
Where our use of the data is unlawful but you do not want us to erase it.
(iii)
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.
(iv)
You have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate grounds to use it.
(f)
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.
(g)
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.
11.2
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
11.3
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 your 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.
11.4
We try to respond to all legitimate requests within one (1) 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.

12. Changes to Privacy Policy

12.1
We keep our Privacy Policy under regular review. This version was last updated on 1st September 2020. Historic versions can be obtained by contacting us.
12.2
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.

13. Contact Us

If you wish to exercise any of your rights under this Privacy Policy, or know or suspect that a breach of your Personal Data or a violation of this Privacy Policy has occurred, or if you have any questions about this Privacy Policy or our privacy practices, please contact us at info@power.gov.ng.