CONFIDENTIALITY

This document is a property of Interconnect Clearinghouse Nigeria Limited and shall under no circumstances, be copied, sold or reproduced for private or commercial use without the express permission of the Company.

Privacy Policy

Interconnect Clearinghouse Nigeria Limited (“ICN”) understands that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with ICN's business activities, client services, and on websites and communications that post a link to this Privacy Policy (collectively, “the Sites”), in our capacity as data controllers.

Please see our Terms of Use for more information about our online terms and policies in general.

Information we collect

ICN collects personal data in the course of its business activities, in connection with client services or other matters associated with the company’s business. The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, company name, and background information required to apply for a job.

COOKIES:

We do not use Cookies on our website at the time of writing this policy. However, if or when the circumstances change, we will update our policy accordingly to include a Cookies Policy.

Use of Information

ICN uses your personal data to fulfill your requests for information, process your requests for service provision, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyze the Sites’ performance and functioning, prevent fraud, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce ICN’s agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Site, or we may use it in the course of our business activities, including in connection with some client services. We may combine and/or analyze personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you.

Our Site does not track you by collecting personal data about your online activities over time and across third-party websites or online services. Accordingly, we do not alter our data collection and use acceptable practices in response to “do not track” signals transmitted from web browsers.

The legal basis by which we process your personal data

Our processing of your personal data for the purposes mentioned above is based:

  • on our legitimate interests in promoting and protecting ICN, building and maintaining business relationships, recruitment, and providing our services;
  • on your consent, for example, if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our websites;
  • to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.

Disclosure of personal data: data recipients and international data transfers

Personal data collected in the course of ICN business activities, including in connection with some client services and on the Site may be transferred from time to time to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Site may be viewed and hosted by ICN and our third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by ICN and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. If you would like more information about these legal mechanisms, please contact us at the address below. By using any of the Site and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information. Personal data collected in the course of ICN business activities, including in connection with some client services and on the Site may be transferred from time to time to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Site may be viewed and hosted by ICN and our third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by ICN and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. If you would like more information about these legal mechanisms, please contact us at the address below. By using any of the Site and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

ICN will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. ICN may provide access to your personal data to third party service providers engaged by ICN to provide services related to the Site as well as related to ICN’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data. Also, we may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you.

In addition, we may disclose information about you:

  • If we are required to do so by law or legal process;
  • To law enforcement authorities or other government officials;
  • When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  • If disclosure is necessary to protect the vital interests of a person;
  • To enforce our Terms of use;
  • To protect our property, services and legal rights;
  • To prevent fraud against ICN, our subsidiaries, affiliates and/or business partners;
  • To support auditing, compliance, and corporate governance functions; or
  • To comply with any and all applicable laws.

Merger, Sale or Acquisition Event

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

User forums

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. ICN is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Site.

Link to third party sites

ICN may provide links to third party websites or information as a service to our users. If you use these links, you will leave the Site. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by ICN of the third party, the third party website, or the information contained therein, and ICN shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Social Networking

The Site may allow you to sign into and associate your social network accounts including, but not limited to Twitter, LinkedIn, Facebook and YouTube, with ICN. The Site may allow you to log in to an ICN account using certain social network account credentials. By associating your social network account with ICN or logging in to an ICN account using your social network account credentials, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with ICN and other connected applications and to manage the data that is shared through your account, including information about your activities using our Site.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.

Security

ICN has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized ICN personnel and third party service providers are provided limited access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions, however, ICN cannot guarantee that unauthorized persons will not obtain access to your personal data.

Data retention

ICN retains personal data, as necessary, for the duration of the relevant business relationship.

We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, ICN will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Children

The Site is not designed for or directed at children who are 16 years of age or younger, and ICN does not intentionally collect or maintain personal data about anyone under this age.

Your rights

If we collect or process your data in the context of our operations within Nigeria, you have the following rights under the National Data Protection Regulation (NDPR) 2019:

  • The right to request access to your data
  • The right to request a copy of your data in a portable format
  • The right to request the correction of data we hold about you
  • The right to request that we erase your data
  • The right to request restriction of the processing of your data
  • The right to object to our processing of your data
  • Where we process data based on your consent, the right to withdraw that consent at any time

To exercise any of these rights, kindly contact us at dpo@interconnectnigeria.com or dataprotection@interconnectnigeria.com

You also have the right to file a complaint with the applicable Data Protection Authority, such as the Nigeria Data Protection Bureau.

Contact us

If you have any questions about our Privacy Policy or if you would like to communicate with our Data Protection Officer (DPO) or the Data Privacy Team, please contact us at:

Interconnect Clearinghouse Nigeria Limited
15th Floor, NECOM House
15, Marina, Lagos State
Nigeria

dpo@interconnectnigeria.com
dataprotection@interconnectnigeria.com