I. Requests to Access, Rectify or Erase
1. Access Request
You have the right to ask us whether we hold any Personal Data relating to you and, if we do, to be provided with a copy of that Personal Data in electronic form, unless you want to receive it in another way (for example, a paper copy). In addition, you can ask us for information on how we use your Personal Data, who we share it with, how long we keep it, where it is stored, and other information to help you understand how we use it.
2. Rectification Request
You have the right to ask us to correct your Personal Data (including by means of providing a supplementary statement) if it is inaccurate and to have incomplete Personal Data updated without undue delay. If we cannot correct the Personal Data, we include a note on our files regarding your request to correct your Personal Data.
3. Erasure Request
You have the right to ask us to erase your Personal Data if:
- Your Personal Data are no longer necessary for the purpose(s) they were collected for
- Your Personal Data have been unlawfully processed
- Your Personal Data must be erased to comply with a regulation
- You withdraw your consent for the processing of the Personal Data (and if this is the only basis on which we are processing your Personal Data)
- You object to processing that is based on our legitimate interests, provided there are no overriding legitimate grounds for continued processing, or
- You object to processing for direct marketing purposes.
If we have made the Personal Data concerned public, we will also take reasonable steps to inform other data controllers processing the data so they can seek to erase links to or copies of your Personal Data.
We may refuse to act on your request to erase your Personal Data if the processing of your Personal Data is necessary:
- To exercise our right of freedom of expression and information
- To comply with the NDPR and relevant Nigerian laws
- For the performance of a task carried out in the public interest or to exercise official authority vested in us
- To establish, exercise or defend legal claims.
In these cases, we can restrict the processing instead of erasing your Personal Data if requested to do so by you.
- Requests to Object
You have the right to object at any time to the processing of your Personal Data if we process it based on our legitimate interests. This includes any so-called “profiling”. Our privacy notice informs you when we rely on legitimate interests to process your Personal Data. In these cases, we will stop processing your Personal Data unless we can demonstrate compelling legitimate reasons for continuing the processing. We may reject your request if the processing of your Personal Data is needed to establish, exercise or defend legal claims. You have the right to object at any time if we process your Personal Data for direct marketing purposes. You may also object at any time to profiling supporting our direct marketing. In such cases, we will stop processing your Personal Data when we receive your objection.
III. Requests to Restrict
You have the right to ask us to restrict the processing of your Personal Data if:
- You contest the accuracy of your Personal Data and we are in the process of verifying the Personal Data we hold
- The processing is unlawful and you do not want us to erase your Personal Data
- We no longer need your Personal Data for the original purpose(s) of processing, but you need them to establish, exercise or defend legal claims and you do not want us to delete the Personal Data as a result, or
- You have objected to processing carried out because of our legitimate interests while we verify if our legitimate grounds override yours.
If processing is restricted, we may process your Personal Data (except for storage purposes), only:
- If you have given us your consent
- For establishing, exercising or defending legal claims
- For protecting the rights of another natural or legal person, or
- For reasons of important public interest as defined under the NDPR and relevant Nigerian laws
Once processing is restricted following your request, we will inform you before we lift the restriction.
IV. Requests for Portability
You have the right to ask that we transfer any personal information that you have provided to us to another third party. Once transferred, the other party will be responsible for safeguarding such personal information.
Even if you request the portability of your Personal Data, you retain your right to also request their erasure.
V. Requests to Object to Automated Decisions
Generally, you have the right to object to any decision producing a legal effect concerning you or which otherwise significantly affects you if this is based solely on the automated processing of your Personal Data. This includes automated decisions based on profiling.
We may refuse your request if the decision in question is:
- Necessary to enter into a contract with you, or for the performance of your contract with us
- Permitted by regulations, or
- Based on your explicit consent.
We will only make decisions relying solely on automated processing that involve your sensitive Personal Data if you have given your explicit consent or the processing is necessary for reasons of substantial public interest, based on the NDPR and relevant laws.