Privacy Policy
PRIVACY POLICY FOR ALBERTA & HONORIA
At Alberta & Honoria, we understand and recognize the importance of safeguarding the personal data of our users, and to show our commitment, we have formulated this Data Protection and Privacy Policy to reflect our commitment to maintaining the confidentiality of the information we receive from you via this Platform.
The purpose of this Data Protection and Privacy Policy is to inform you of:
1. Personal Data we may collect from you when you visit our Platform or when you avail our Services and other incidental services provided on our Platform.
2. How we use and secure such Personal Data.
3. The choices you have regarding our use of, and your ability to review and correct the Personal Data, in accordance with the Nigeria Data Protection Regulation (NDPR), 2019 and the Nigeria Data Protection Act, 2023, its subsequent amendments and other regulations or laws regulating the collection, and processing of Personal Data in Nigeria.
4. Access (if any) of third parties to the Personal Data we collect on this Platform and the purpose of such access.
5. Available remedies in the event of a violation of the Privacy Policy.
1. What Personal Data is collected from you?
1.1 In general, you can visit our Platform without telling us who you are or revealing any Personal Data. For each visitor to the Platform, our Web server automatically recognises only the visitor’s domain name, but not the email address (where possible).
1.2 We may track the Internet Domain Address from which people visit us and analyse this data for trends and statistics, but individual users will remain anonymous, unless you voluntarily tell us who you are.
1.3 Once you decide to avail our Services on this Platform, you shall be required to provide us with certain personally identifiable information that can be used to contact or identify you.
1.4 These Personally Identifiable Information usually include but without limitation to the following:
a) Full Name.
b) Email Address
c) Phone Number
d) An identity document/number
1.5 The decision to provide the Personally Identifiable Information is completely your own choice but if you choose not to provide this information, you will be unable to avail any of the services on our Platform.
1.6 The Personally Identifiable Information we collect from you, as well as others, are treated as confidential, and we use appropriate technical and organisational measures to ensure the integrity and confidentiality of your personal data at all times. However, we reserve the right to disclose your data on the grounds of public interest, public health, and in accordance with the Nigeria Data Protection Act, 2023, and its subsequent amendments, as well as international best practices on data protection.
1.7 We may also use your Personally Identifiable Information to contact you with newsletters, marketing or promotional materials or other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by clicking on the “unsubscribe” link or following the instructions provided in any email we send you.
1.8 You shall have the right to the rectification, blockage, or erasure of inaccurate, false or unlawfully processed personal data without delay and free of charge. Any such rectification and erasure of your data shall be reflected in our Database Management System.
2 How do we use your Personal Data?
2.1 We use the information you provide to us to process your orders for any of the Services offered on this Platform or any other request you may make, and to administer your contractual relationship with us. We also use the information to customize your experience on the Platform or to serve you specific content or ads that are relevant or personalised to you.
2.2 We may also use aggregate information and statistics for the purposes of monitoring Platform usage in order to help us develop the Platform and our Services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.
2.3 We also collect this information in order to grant you access to our Services, monitor your usage of our Platform and Services, and/or participation in online activities, including reviews.
2.4 From time to time we may provide your Personally Identifiable Information to our customer service agencies or customer service unit, for research and analysis purposes, so that we can monitor and improve the Platform, online experience and our services to you. We may contact you by email or telephone to ask you for your feedback and comments on our services.
2.5 The information we obtain are also useful in aiding investigations and attending to your complaints or enquiries within reasonable time.
3 Cookies Policy
3.1 Cookies are used to uniquely identify a person, consequently we treat them as Personally Identifiable Information. They are used for analytics and advertising to improve the experience and relevance of our Platform.
3.2 When you first visit our Platform, we may ask you via a pop-up banner to accept or reject the use of cookies. This pop-up clearly explains why we use them and asks you to make an affirmative action by clicking continue or accept cookies. If you do click accept or such other similar command prompt, you unlock the full functionality of our Platform. However, if you refuse to accept cookies on this Platform, it will affect how our Platform works and you may not be able to access or use certain areas of our Platform or its functionality.
4 Third Party Access
4.1 We are bound to keep your Personally Identifiable Information private. Except as provided in this Privacy Policy, we will not sell, rent or loan any of your information to third parties for their marketing purposes without your explicit consent.
4.2 We will not disclose any Personal Data to third parties unless:
a) The disclosure is required or authorised by law,
b) Or you have consented to a disclosure of your Personal Information,
c) Or for other purposes (relating to the primary purpose for collecting that information, including the processing of your personal data or Personal Information by our agents or data processors) that is reasonably expected including the sale or disposal of any part of our business or rights.
d) It is necessary in order to protect your vital interest or of another natural person, especially where you are physically or legally incapable of giving consent.
e) Or in circumstances where the concealment is likely to endanger the life of another natural person,
f) It is necessary for the prevention and detection of an unlawful act.
g) It is necessary to protect against malpractice or misfeasance.
4.3 We may also collect, and our third-party providers of advertisement and content may collect certain personal data such as information relating to computer location, URL and IP address and domains, your browser type, the country and telephone area code where your computer or mobile device is located, the pages of our Platform that were viewed during your visit, the advertisements you clicked on, and any search terms that you entered on our Platform.
4.4 We may contract with third-party companies, sub-contractors, service providers, agents or other persons to provide certain services including data management, web development, promotional services and such other ancillary services for the fulfilment of our obligation to you as our user. We call them our “Service Providers” and we shall be entitled to provide our Service Providers with the information needed for them to perform these services. We also ask our Service Providers to confirm that their privacy practices are consistent with ours.
4.5 In sharing your personal data, we will ensure compliance with the NDPR 2019 and any such laws in existence now or to be developed later with respect to data protection and privacy policy in Nigeria.
5 How do you give consent?
5.1 You give consent by expressing a positive action to opt in and it is usually a clear affirmative action expressed by ticking a box next to wordings such as “I acknowledge and agree to be bound by the Privacy Policy” or any other similar wordings.
5.2 By submitting your Personal Data on this Platform, you consent to the use of that information as set out in this Privacy Policy. If we change our Privacy Policy, we will post the changes on this Platform and send you an email notifying you of the change, so that you may be immediately aware.
5.3 You agree that you do not object to us or our Service Providers contacting you for statistical or survey purposes, to improve this Platform and its services to you. You consent to such contact whether by telephone, email or in writing.
6 What happens when we expand; form an alliance or sell our business?
6.1 If all or part of our business is sold (whether by sale of shares or assets), or integrated with another business, your details and information may be disclosed to our adviser and any prospective purchaser or purchasers and their advisers and passed on to the new owners of the business.
6.2 We will notify you (via email to the email address associated with your account) of any such deal and outline your choices in that event before your information is disclosed and transferred to such new owner or third party.
7 How we protect your Personal Data
7.1 The Platform is committed to online security. We maintain security measures to protect personal data on our Platform and to prevent unauthorised access of member information transmitted to our servers.
7.2 We cannot guarantee the security of any data sent over the internet but we have put in place appropriate physical, electronic and managerial procedures to protect, secure and safeguard personal data and information collected on or through our Platform, which measures are reviewed from time to time.
7.3 Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. For this reason, while we strive to protect your Personal Data, we cannot guarantee or warrant the security of any Personal Data you transmit to or from our Platform, and you do so at your own risk. Once we receive your transmission, we will do our best to protect its security on our systems.
7.4 All our employees are briefed on the importance of personal data, security and confidentiality of information obtained. They are also trained on practical aspects of the Nigeria Data Protection Regulation, 2019, and the Nigeria Data Protection Act, 2023.
7.5 In respect of detection and investigation of breaches where they occur, we have put in place relevant controls which should alert us to a breach of security. We endeavour to investigate every notified breach of security.
7.6 The personal data and information held by us are currently stored on a relevant technology system, mass email programme database, individual account contact manager’s systems together with the training booking spreadsheet, invoicing spreadsheet, Excel spreadsheets and paper form.
8 What are the Data Protection rights?
8.1 The right to your data privacy as a data subject is enshrined in the Nigeria Data Protection Regulations, 2019 and the Nigeria Data Protection Act, 2023, with all the applicable exceptions as stated therein and they include:
a) Right to request that the data collected by us on this Platform be made available to you in an electronic format or that it should be sent to a third party, except to the extent that providing such data would impose unreasonable costs on us, in which case you may be required to bear some or all of such costs. (Kindly note that we reserve the right to decline such request where they are manifestly unfounded or excessive, in particular because of their repetitive character).
b) Right to obtain from the Data processor restriction of processing.
c) Right to transfer data from one data controller to another.
d) Right to request that we delete your personal data without delay and we shall delete same where one of the following grounds applies:
i. The personal data are no longer necessary in relation to the purposes for which they were collected or processed;
ii. The data subject has withdrawn his or her consent on which the processing is based;
iii. There is an objection to the processing and there are no overriding legitimate grounds for the processing;
iv. The personal data has been unlawfully processed; and
v. The personal data has to be erased for compliance with a legal obligation in Nigeria.
e) Right to withdraw, at any time, consent to the processing of your personal data. However, your decision to withdraw your consent shall not jeopardize the lawfulness of the processing of your personal data based on the consent given prior to the withdrawal.
9. How long do we store your personal data for?
9.1 We retain the information provided to us for as long as necessary for the purpose(s) for which it was collected and the said information shall be deleted once the purpose for which it was collected and processed has been achieved. The period of data storage is also subject to legal, regulatory, administrative and operational requirements.
10. What are the remedies available to you in case of a breach?
10.1 In case of a breach or complaints about the handling of your personal data, you may lodge a complaint with us via email to support@albertaandhonoria.com and we will ensure to resolve your complaints in the shortest possible time. In the event that you are unsatisfied with our resolution, you have the right to lodge a complaint with the Nigeria Data Protection Commission.
11. Your Feedback
11.1 To help us improve our privacy policy and practice, please give us your feedback. You may email us at support@albertaandhonoria.com.
12. Information on our Identity and Place of Business
12.1 Alberta & Honoria Limited is a company duly registered under the Laws of the Federal Republic of Nigeria with registration No: RC 7791017. Our principal place of business is situated at Yaba, Lagos, and our means of communication is as contained in our “Contact Us or Info” page.