Privacy Policy

Data Protection Privacy Policy

Welcome to SafeTraxs, a smart tool that helps companies/organizations make visitor management easier and seamless with frictionless, modern and secure sign-in (the “Platform”). You can read more about our services and offerings in our Terms and Conditions (Terms and Conditions should be in hyperlink)

This Privacy Policy governs the website-SafeTraxs.com, including both mobile and online versions (the “Platform”), online and mobile services (e.g., apps), and software made available by Ceedcapital Nigeria Limited ( “we”, “our”, or “us”), including your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other online services that we own and control and that post a link to this Privacy Policy. This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with the Personal Information (defined below) of your data subjects that we have ourselves collected under this Privacy Policy.

We understand and recognize the importance of safeguarding the personal information of your data subjects, and to show our commitment, we have formulated this Data Protection Privacy Policy to reflect our commitment to maintaining the confidentiality of the information and data we receive via this Platform. This Privacy Policy is in consonance with the right to privacy guaranteed to every Nigerian citizen, as enshrined in the Constitution of the Federal Republic of Nigeria 1999, it also takes cognizance of the rights of your visitors/guests/employees being Data Subjects under the Nigeria Data Protection Regulation 2019 and all other applicable laws that protects their privacy.

INTERPRETATION

  • Data Subjects means your visitors/guests/employees being identifiable persons who can be identified directly or indirectly, in particular reference to one or more factors specific to their physical, psychological, mental, economic, cultural or social identity.

  • Personal Information means any information relating to an identified or identifiable natural person (‘data subject’);

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The purpose of this Data Protection Privacy Policy is to inform you of:

  • Personal Information we may collect from your data subjects when you

    avail yourself of the services provided on this Platform,

  • how we use and secure such Personal Information,

  • The choices they have regarding our use of their personal information,

  • Their ability to review, correct and object to the use of such Personal

    Information, in accordance with the Nigeria Data Protection Regulations, 2019, its subsequent amendments and other regulations regulating the collection and processing of personal data in Nigeria.

  • Access (if any) of third parties to personal data and purpose of access.

  • Available remedies in the event of violation of the privacy policy.

    What Information is collected from you as a Customer?

  • The information we collect on our Platform are two pronged; In the first instance we would require Account and Marketing Data from you and they will include without limitation to the following;

  • Information in connection with the creation or administration of your customer account.

  • Information that will enable us to send you updates on our services or our newsletter.

  • The Account and Marketing Data we collect may include company/personal names, usernames, phone numbers, email addresses, office registered address or principal place of business, billing information, information about how you use our Platform or our Services, your IP address and/or other device identifying data, and other information required to provide a service or information you have requested from us.

    What Information is collected from your Data Subjects?

  • In the second instance, we may collect data from your data subjects and the information may include their names, phone numbers, email addresses, locations and photos, times of visit, the data subject’s employer’s name and any other information that you decide to capture about your data subjects.

  • We will treat all personal information obtained from your data subjects as confidential and will keep them on a secure server in acknowledgement of the duty of care that we owe to you and the data

subjects. We reserve the right to disclose the Personal Information in the circumstances set out in this Data Protection Privacy Policy and in accordance with the Nigeria Data Protection Regulation, 2019 and international best practices on data protection.

Other Information We Collect and What Purpose They Serve

  • In general, you can visit the Platform without telling us who you are or revealing any Object Identifiable Information (“OII”). For each visitor to the Platform, our Web server automatically recognizes only the customer’s domain name, but not the email address (where possible).

  • 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.

  • We may also obtain some information through or from cookies or other similar technologies; or the device used to connect to our Platform. This information includes IP address, mobile network, browser and version, unique device identifiers and time zone settings; website visited before you visited our Platform. You may change your cookie settings on your device if you are concerned about us accessing them.

  • We may ask you to give testimonials attesting to the quality of the services rendered on this Platform and we will publicize such testimonials on the Platform as a form of customer accreditation to reel in other customers.

  • In line with international best practices, we do not store your card details. We have adopted a payment process which is in full compliance with the Payment Card Industry Data Security Standard (PCI DSS).

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on our Platform are made via____________; a PCI DSS certified payment

platform with bank level security to ensure your transactions and

Payments

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financial information are always safe and secure.

How do we use your Personal Information?

  • We use the information you provide us to customize your experience on the Platform or to serve you specific content or ads that are relevant or personalised to you.

  • We may also use aggregate information and statistics for the purposes of monitoring Website 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.

  • We gather this Information to allow us to process your registration, process any requests or payments you may make; and to also administer your contractual relationship with us. 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, testimonials or competitions, if any.

  • From time to time we may provide your information and that of your data subjects 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 post, email, telephone or through any of the social media platforms, to ask you for your feedback and comments on our services.

  • The information we collect are also used to communicate with you about your account or transactions with us and send you information or request feedback about features on our Platform and applications or changes to our policies;

  • The information we obtain are also useful in aiding investigations and attending to your complaints or enquiries within reasonable time.

    How can you Access and Amend your Information?

  • You are able to access a broad range of information about your account and your interactions with the Platform for the purpose of viewing and, in certain cases, updating your Information. Examples of information you can access easily on the Platform include:

    1. Your identifiable information (including name, e-mail, password, communications and personalized advertising preferences);

    2. The personal information of your data subjects through the microsite that we will provide you or through this Platform, whichever is appropriate considering the circumstance.

    3. Paymentsettings(includingcredit/debitcardinformation);and

    4. e-mailnotificationsettings.

  • You can opt-out of receiving future marketing communications from us at any time by adjusting your customer communication preferences, through the unsubscribe link within the email communication. For marketing via your mobile application, you will need to adjust your notifications settings in the general section of your mobile.

  • You may disable Cookies by changing the settings on your browser. If you disable Cookies, it will affect how our Platform works and you may not be able to access or use certain areas of our Platform or its full functionality. For example, performance cookies collect information about how you use our Platform, for instance, which pages you visit most often, which allows us to provide you with targeted and relevant choices that enhance your experience on our Platform.

  • We may retain a copy of your Information for compliance reasons. When you update Information, we may retain a copy of the prior version for our records.

  • You shall have the right to rectify inaccurate data and update data concerning you and any such rectification and update of your data

or that of your data subjects shall be reflected in our Database Management System.

Third Party Access

  • We are bound to keep the Information you provide us and that of your data subjects private, except as provided in this Privacy Policy, we will not sell, rent or loan any of those Information to third parties for their marketing purposes without your explicit consent.

  • We will not disclose any Personal Information of your data subjects to third parties unless:

    1. the disclosure is required or authorized by law, or

    2. they have consented to our disclosing of their Personal

      Information, or

    3. for other purposes (relating to the primary purpose for collecting

      that information, including the processing of their 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.

    4. It is necessary in order to protect the vital interests of the data subject or of another natural person or in circumstances where the concealment is likely to endanger the life of another natural person.

    5. It is necessary for the prevention and detection of an unlawful act.

    6. It is necessary to protect against malpractice or misfeasance.

  • We may also collect, and our third party providers of advertisements and content may collect certain user information 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 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.

  • We may contract with third party companies, sub-contractors, service providers, agents or other persons to provide certain services including debit card processing, data management, web development,

promotional services and such other ancillary services for the fulfilment of our obligation to you as our customer. 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.

  • In sharing your information, we will ensure compliance with the National Information Technology Development Agency Act 2007 and the Nigeria Data Protection Regulations, 2019 and any such laws in existence now or to be developed later with respect to data protection/privacy policy.

  • If we are requested at any time by the police or any other regulatory, investigatory or government authority to provide your customer information, we are entitled to do so in compliance with the law.

    How do your data subjects give consent?

  • By submitting their personal information on this Platform, they consent to the use of that information as set out in this Data Protection Privacy Policy. If we change our Data Protection Privacy Policy, we will post the changes on the Platform and send you an email notifying you of the change, so that you may be immediately aware.

  • 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.

    What happens when we expand; form an alliance or sell our business?

  • 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 will be passed on to the new owners of the business. We’ll notify you (via a message to the email address associated with your account) of any such deal and outline your choices in that event.

  • Following completion of any such sale or transfer, your Information shall be disclosed and transferred to such new owner or third party.

How we protect your data.

  • The Platform is committed to online security. We maintain security measures to protect sensitive data on our Platform and to prevent unauthorised access of customer information transmitted to our servers.

  • We cannot however 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. Some of the unique measures include but are not limited to the following;

    1. We always use industry-standard encryption technologies when transferring and receiving customer’s data exchanged on our Platform. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you on our Platform.

    2. We ensure that handshakes (requests and responses) between user devices/browsers and our servers take place over a Secure Socket Layer (SSL/HTTPS) to keep out any middleman attack.

    3. We scrutinize and sanitize every request to our servers to prevent common security exploitations such as Query Injections and Script Injections.

    4. We sign every resource-mutating request to our servers with unique security tokens to prevent security breaches such as Cross- Site Resource Forgery (CSRF) and Session Hijacks.

    5. Every sensitive data collected from our users are hashed and/or encrypted on our servers with AES-256 and AES-128 encryption. All encrypted data are also signed using a message authentication code (MAC) so that their underlying values cannot be modified once encrypted.

  • Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. For this reason, while we strive to protect

your Personal Information, we cannot guarantee or warrant the security of any Personal Information 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.

  • 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.

  • In respect of detection and investigation of breaches where they occur, we have in place relevant controls which should alert us to a breach of security. We endeavor to investigate every notified breach of security.

  • 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.

  • We do not hold any of your Debit card details on this Platform. Such information would be securely passed on to the electronic payment system provider or processor for authorization by your bank.

  • We have implemented internet security technology to seek to ensure that it is safe for you to avail yourself of our services on this Platform. We are constantly updating our technology to provide you with the maximum practicable level of security.

    What are the Data Protection rights that your data subjects are entitled to?

    The right to privacy of your data subjects is enshrined in the Nigeria Data Protection Rules, 2019 with all the applicable exceptions as stated therein. They include:

  • Right to request that the data collected by us on this Platform be made available to them in an electronic format or that it should be sent to a third party (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).

  • Right to request the Controller to delete personal data without delay.

  • Right to obtain from the Data processor restriction of processing.

  • Right to transfer data from one data controller to another.

  • Right to request that we delete the personal data of your data subjects without delay and we shall delete same where one of the following grounds applies:

    1. the personal data are no longer necessary in relation to the purposes for which they were collected or processed;

    2. The data subject has withdrawn his or her consent on which the processing is based;

    3. There is an objection to the processing and there are no overriding legitimate grounds for the processing;

    4. the personal data has been unlawfully processed; and

    5. thepersonaldatahastobeerasedforcompliancewithalegal

      obligation in Nigeria.

    What are the remedies available to you and your data subjects in case of a breach?

    In case of a breach, you may lodge a complaint with the National Information Technology Development Agency (NITDA) via email toinfo@nitda.gov.ng about the handling of information provided to us.

    How long do we store your personal data/information for?

    We retain the information provided to us for as long as necessary for the purpose(s) for which it was collected and not longer than one (1) year from the date of collection. The period of data storage is also subject to legal, regulatory, administrative and operational requirements.

    Your Feedback

    To help us improve our privacy policy and practice, please give us your feedback. You may email us at__________________ or write to us at____________________

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