1. IMPORTANT INFORMATION AND WHO WE ARE
Full name of legal entity: Robert & John Ltd.
Email address: firstname.lastname@example.org
Postal address: Unit 16, Trocadero Square, Lekki Phase 1, Lagos
Telephone number: +234 904 000 3535
You have the right to make a complaint at any time to the Nigeria Data Protection Bureau (NDPB), Nigeria’s supervisory authority for data protection issues (ndpb.gov.ng/). We would, however, appreciate the chance to deal with your concerns before you approach NITDA, so please contact us in the first instance.
3. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes delivery address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, preferences, feedback, and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.
Academic Data, including test results and scores.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, or trade union membership), nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you, including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below
Technical Data from the following parties:
(a) analytics providers such as Google based outside Nigeria;
(b) advertising networks based inside or outside Nigeria; and
(c) search information providers based inside or outside Nigeria
(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Flutterwave and/or Paystack based inside OR outside Nigeria.
(e) Identity and Contact Data from data brokers or aggregators based inside Nigeria.
(f) Data from your school and Roducate Tutors and Counsellors.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data. Although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below.
|PURPOSE/ACTIVITY||TYPE OF DATA||LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Academic Data (f) Marketing and Communications (g) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Academic Data (g) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
You can ask us or third parties to stop sending you marketing messages at any time by:
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent in compliance with the above rules where this is required or permitted by law.
7. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside Nigeria. If transfers out of the country occur and will involve transferring your data outside Nigeria, we will ensure that your personal data is protected by requiring all our companies to follow the same rules when processing your personal data.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Nigeria Data Protection Bureau(‘NDPB’).
Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Nigeria.
9. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify NDPB of any breach to your personal data within 72 hours of becoming aware of the occurrence of such breach.
10. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA?
We will only retain your personal data until (a) the fulfilment of the purposes we collected it for; (b) the withdrawal of your consent on which the processing is based (subject to other provisions of this policy); (c) any objection by data subject to the processing in the absence of overriding legitimate grounds for the processing; (d) the erasure of the same for compliance with a legal obligation in Nigeria, whichever occurs first. 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, tax, accounting, or other requirements.
11. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
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, excessive, or is of such nature as to warrant the use of additional efforts or resources from us. Alternatively, we could refuse to comply with your request in the foregoing circumstances.
WHAT WE MAY NEED FROM YOU
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 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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Tutors mean accredited teachers on the Roducate platform who conduct individual or group lessons.
Counsellor means a certified guidance counsellor on the Roducate platform who advises student users and/or parents on academic and career issues.
13. THIRD PARTIES
INTERNAL THIRD PARTIES
Other R&J’s parent company and other companies in the group acting as joint controllers or processors and who are based in Nigeria and provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
14. GOVERNING LAW