Privacy Policy—Nigeria
Innovations for Poverty Action LTD/GTE (“IPA”) takes its responsibilities with regard to the management of personal data very seriously and we do not take lightly the trust you have reposed in us, in providing us with your personal information. This Policy describes how IPA processes your personal data, but it may not address all possible data processing scenarios. This Privacy Policy is a guide to help you understand:
- The Information We Collect
- How We Collect and Use Your Data
- Consent and Access Rights
- Personal Data Protection Principles
- User Responsibility
- Data Security
- Links to Third-Party Sites
- Third-Party Access
- Violation of Privacy
- Data Retention
- How to Contact Us
1. The Information We Collect
IPA may collect the following information: name, date of birth, residential and contact address, telephone number, fax numbers, email address, marital status, nationality, gender, sexual orientation, social security number, tax identity number, debit/credit card number, card expiry date and Card Verification Value/Code, trade union membership bank details, posts on social networking information regarding data subjects and their family members, online usernames, license numbers, medical information and records, health plan beneficiary information, race or ethnic origin, political opinions, educational background, genetic data, biometric data (ex. thumb print), passport number and other identity numbers, location, geospatial data, photograph, audio and video recordings, IP address, MAC address, IMEI number, IMSI number and other device identifiers and serial numbers, vehicle identifiers and serial information, and any other information relevant which constitute Personal Data (“personal data”).
2. How We Collect and Use Your Data
2.1 IPA collects the above-mentioned information using surveys, forms, email, physical requests, cookies, subscribe to IPA newsletter, fill out a form, JWT, and web tokens.
2.2 When you send email or other communications to IPA, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services. When you access IPA’s services, our servers automatically record information that your browser sends whenever you visit a website.
2.3 We use the above-mentioned information for research, regulatory compliance, marketing, business development, to process donations, to send periodic emails, development of outreach materials and policy documents, publicity, human resources management, talent and recruitment, benefits administration, events planning, and hosting, in-house security and analysis, key business operations, evaluation of the success of our marketing and promotional efforts, analysis of our website usage, and improvement of our website’s content, layout, and services, processing or carrying out tasks to fulfill business goals or objectives.
3. Consent and Access Rights
3.1 We usually require your consent for the processing of your data. We shall obtain your consent for/to individual matters, where any document deals with different matters.
3.2 We can process your personal data in the absence of consent where:
a. processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
b. processing is necessary for compliance with a legal obligation to which you are subject;
c. processing is necessary in order to protect your vital interests or that of another natural person; and
d. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in us.
3.3 If we intend to use your data for a purpose that is different from the purpose(s) for which your data was obtained, we will seek your consent prior to the use of your data for that other purpose as required by law.
3.4 In the event of any arrangement whereby IPA sells or transfers all, or a portion of, its business or assets (including in the event of a reorganization, dissolution, or liquidation) to third parties, you hereby consent that your personal data held with IPA can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by IPA prior to such arrangement. IPA shall at all times ensure that you are notified when your personal data is intended to be transferred to third parties in the circumstances outlined in this clause.
3.5 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 conduct.
3.6 You may withdraw your consent at any time and may request access to your personal information in our possession. We can, however, deny you access to the information where we determine that your request is unreasonable.
3.7 You reserve the right to request the modification or amendment of your personal data in our possession.
3.8 In all cases of access or modification/amendment of personal information, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed or modified/amended.
4. Personal Data Protection Principles
When we process your personal data, we are guided by the following principles, which require personal data to be:
a. processed lawfully, fairly, in a transparent manner and with respect for the dignity of the human person.
b. collected only for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
c. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
d. accurate and where necessary kept up to date.
e. removed or not kept in a form which permits identification of data subject for longer than is necessary for the purposes for which the personal data is processed.
f. processed in a manner that ensures its security, using appropriate technical and organizational measures to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage.
5. User Responsibility
You are required to familiarise yourself with this policy and to ensure that the information you provide to us is complete, accurate, and up to date.
6. Data Security
6.1 IPA implements and maintains appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorized or unlawful processing or accidental loss, destruction of, or damage to their personal data.
6.2 Safeguarding will include the use of encryption and pseudonymization where appropriate. It also includes protecting confidentiality (i.e. that only those who need to know and are authorized to use personal data have access to it), integrity, and availability of the personal data. We regularly evaluate and test the effectiveness of those safeguards to ensure the security of our processing of personal data.
6.3 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot guarantee absolute security. IPA, therefore, accepts no liability for any damage or loss, however, caused, in connection with transmission over the Internet or electronic storage.
7. Links to Third-Party Sites
The IPA website may contain links to other websites owned and operated by third parties. These links are provided for your information and convenience only and are not an endorsement by IPA of the content of such linked websites or third parties. The information that we collect from you will become available to these websites if you click the link to the websites. These linked websites are neither under our control nor our responsibility. IPA, therefore, makes no warranties or representations, express or implied about the safety of such linked websites, the third parties they are owned and operated by, and the suitability or quality of information contained on them. This Privacy Policy does not apply to these websites, thus, if you decide to access these linked third-party websites and/or make use of the information contained on them, you do so entirely at your own risk. IPA accepts no liability for any damage or loss, however, caused, in connection with accessing the use of or reliance on any information, material, products, or services contained on or accessed through any such linked website. We advise that you contact those websites directly for information on their privacy policy, security, data collection, and distribution policies.
8. Third-Party Access
8.1 IPA only shares personal information with other companies, entities, or individuals in the following limited circumstances:
a. We have your consent.
b. We provide such information to other professional advisers or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
c. We have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request, (b) enforce applicable terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of IPA, its users or the public as required or permitted by law.
8.2 IPA is at all times, responsible for the security and appropriate use of that data as long as it remains with IPA.
9. Violation of Privacy
9.1 We have put in place procedures to deal with any suspected personal data breach and will notify you of any personal data breach and let you know the steps we have taken to remedy the breach and the security measures we have applied to render your personal data unintelligible.
9.2 All suspected breach of personal data will be remedied with 1 (one) month from the date of the report of the breach.
9.3 If you know or suspect that a personal data breach has occurred, you should immediately contact the IPA team at NIA_dpo@poverty-action.org.
9.4 IPA will not be responsible for any personal data breach which occurs as a result of:
a. an event which is beyond the control of IPA;
b. an act or threats of terrorism;
c. an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves, and floods) which compromises IPA’s data protection measures;
d. war, hostilities (whether war be declared or not), invasion, acts of foreign enemies, mobilization, requisition, or embargo;
e. rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises IPA’s data protection measures;
f. the transfer of your personal data to a third party on your instructions; and
g. the use of your personal data by a third party designated by you.
10. Data Retention
We shall retain your personal data for as long as necessary to carry out the purpose for which the personal data was collected, as stated in the consent, or, if your personal data was lawfully collected and processed without obtaining consent per Section 3.2 of this Policy or the law, for a period no longer than necessary to continue the lawful processing of your personal data.
You may always contact us and we will remove your personal data upon your written request.
11. How to Contact Us
For any inquiries you have in relation to this Privacy Policy, please feel free to contact our Data Protection Officer at +234704 100 0531 or NIA_dpo@poverty-action.org.