1
PERSONAL DATA WE MAY COLLECT FROM YOU

1.1 For the purpose of this Privacy Policy, “personal data” shall have the meaning defined by Section 1.3 (xix) under Part I of the Nigerian Data Protection Regulation.

1.2 Any data or information that is provided by filling in forms on the site (which may be processed in line with our legitimate interest or on contract performance under section 2.2 under Part 2 of the Nigerian Data Protection Regulation.

1.3 This includes information provided at the time of registering to use our site, registering for any service provided by us to you through the service platform on the site.

1.4 We may also ask you for first name, surname, email and phone number when you report a problem with the site or our service (which may be processed in line with our legitimate interest or on contract performance under section 2.2 under Part 2 of the Nigerian Data Protection Regulation.

1.5 If you contact us, we may keep a record of that correspondence as well as your first name, last name, email address and phone number (if provided) (which may be processed in line with our legitimate interest or on contract performance under section 2.2 under Part 2 of the Nigerian Data Protection Regulation.

1.6 We may, by the use of cookies (see clause 10 below) and/or other similar technologies, store details of the data related to your visits to the site, including the type and version of internet browser used, the type, manufacturer and model of the computer or mobile device used, any website or external application from which you have come to access the site, your Internet Protocol address, the operating system of your computer or mobile device, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

1.7 We may track your use of the site using cookies and/or similar tracking devices. For more information, please refer to clause 10 below.

2
THIRD-PARTY WEBSITES

2.1 The collection and processing of personal data by third party websites will depend on and be governed by the privacy policies of said third-party websites, of which we encourage you to review carefully. Moreover, please note that all third-party websites’ transactions are subject to the privacy policies, terms and conditions and other policies of said third-party websites.

2.2 The site or application may also, from time to time, contain links to external websites. We are not responsible for the privacy policies, terms and conditions, other policies or content of such external websites.

3
WHERE AND HOW WE STORE YOUR PERSONAL DATA

3.1 We make our best efforts to ensure your personal data is kept secure and protected from accidental loss or unauthorized access, use or alteration, through the following structural and technical measures:

a. Computers and email accounts of all of our employees being password protected;

b. Encryption of the personal data while in transport through the https protocol;

c. Encryption of the personal data while at rest;

d. Encryption of the backups including personal data;

e. Personal data stored on secured servers and infrastructures;

f. Permissions of access to documents including personal data regularly reviewed and monitored; and

g. Regular monitoring of the usefulness of stored personal data and deletion of all personal data no longer required for the purpose for which it was collected.

3.2 Unfortunately, and despite the best of our efforts, the transmission of information via the internet is not completely safe. Although we will take reasonable precautions to protect your personal data, we cannot guarantee the security of your data transmitted to the site or application; kindly note that any such transmission is at your own risk. Once we have received your personal data, we will utilise our procedures and security features to try to prevent any unauthorised access.

3.3 All personal data you provide to us is stored on our (or our licensors and contractors’) secure servers.

3.4 It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal data if you use a shared computer or a computer in a public place.

4
USES MADE OF THE PERSONAL DATA

4.1 The personal data provided while subscribing to our newsletter may be used for the following purposes:

a.  Send our newsletter;

b.  Address a subscription request.

4.2 The personal data provided while contacting us at the email address provided on the site or application may be used for the following purposes:

a.  Address the person’s request;

b.  Tracking issues with the site or application;

c. Archiving and statistics about our received correspondence.

4.3 The personal data provided for registration on either or all of our ongoing projects (Research Skills Projects, WillFran entrepreneurial session, pull up a seat Lagos Event, SDG STEMs) shall be used solely for its respective purposes.

4.4 We may also use the personal data held about you for the following purposes.

a.  To help us identify you and any account you may have with us;

b.  For the sake of marketing communication (from us or one of our business partners). If you expressly accepted to be contacted for marketing purposes;

c.  Administration;

d.  Ensure that content from the dashboard is presented in the most effective manner for you and for your computer and/or mobile device;

e.  Allow you to participate in interactive features of our service, when you choose to do so;

f.  Identify visitors to the site or application;

g.  Research, statistical and behavioural analysis;

h.  Fraud prevention and detection;

i.  Security vetting;

j.  Notify you about changes to our service; and

k. Address a problem you may face with the site, the application or our service.

 

4.5 We may contact you by electronic means (e-mail), phone, SMS, push notifications or post.

5
DISCLOSURE OF YOUR PERSONAL DATA.

5.1 We may disclose your personal data to any member of the WillFran team.

5.2 We may disclose your personal data to third parties:

a.  In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

b.  If WillFran consulting or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

c.  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions; or to protect the rights, property, or safety of WillFran consulting, our licensors and customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

5.3 We may also disclose your personal data to:

a. Our agents and service providers;

b. The third-party websites as defined in clause 2 above;

c. Our business partners if you agreed to be contacted by them for marketing purposes.

6
MONITORING

We may monitor and/or record our communications with you, on whatever channel, for quality, training, fraud detection and compliance purposes.

7
YOUR RIGHTS

7.1 You have a certain number of rights in relation to our processing of your personal data which are being summarized in this clause 7.

7.2 Right to information: You have the right to be informed about the collection and use of your personal data, which is the purpose of this Privacy Policy.

7.3 Right of Access: You have the right to request access to the personal data we may hold about you. In order for such access to be granted (in cases of personal data not available directly when you login to your account) you should:

a.  put this request in writing;

b.  attach a proof of identity and address;

c.  specify the personal data to which you want to have access.

 

7.4 Right to rectification: You have the right to have the personal data we hold about you rectified if it is inaccurate or incomplete. In order to exercise this right for the personal data not modifiable directly when you login to your account, you should:

a.  put this request in writing;

b.  attach a proof of identity and address;

c.  specify the personal data you want us to rectify.

 

7.5 Right to erasure or right to be forgotten: In some instances, you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. This right is not absolute and only applies if:

a.  the personal data is no longer necessary for the purpose for which it was originally collected or processed;

b.  the personal data was collected and processed relying on your consent and you decide to withdraw such consent;

c.  the processing is based on legitimate interests and there is no overriding legitimate interest to continue this processing;

d.  the personal data is being processed for direct marketing purposes and you object to that processing;

e.  the personal data is being processed unlawfully;

f.  we have to do it to comply with a legal obligation; or

g.  the personal data was processed to offer information society services to a child.

Provided it is applicable, you should do the following in order to exercise this right:

a.  put the request in writing;

b.  attach a proof of identity and address;

c.  specify the personal data you want us to erase.

 

7.6 Right to restrict processing: You have the right to block or suppress the processing of your personal data for the future, in certain conditions described in section 3.1 (7h) under Part 3 of the Nigerian Data Protection Regulation.

a.  put this request in writing;

b.  attach a proof of identity and address;

c.  specify the personal data or processing you want to restrict.

 

7.7 Right to data portability: You have the right to obtain and reuse the personal data we process about you, for your own purposes across different services. In order to exercise this right, you should:

a.  put this request in writing;

b.  attach a proof of identity and address;

c.  specify the personal data you want to obtain for porting.

 

7.8 Right to object: You have the right to object to:

a.  processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);

b.  direct marketing (including profiling); and

c.  processing for purposes of scientific/historical research and statistics.

In order to exercise this right, you should:

a.  put this request in writing;

b.  attach a proof of identity and address;

c.  specify the processing to which you want to object.

 

 

8
CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

You should check our Privacy Policy on a regular basis to ensure you are aware of its most recent version, as it is the latest available version of this Privacy Policy that shall apply each time you access the site or application.

9
CONTACT

Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed by email to willfranconsulting@gmail.com or by post to our registered address mentioned above.

10
WILLFRAN’s USE OF COOKIES

10.1 When you interact with the site or application, we try to make that experience simple and meaningful. When you visit the site or access to the application, a web server sends a cookie or other similar technology to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access to a mobile application and which store and sometimes track information. A number of cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to the site or application and will last for longer.

10.2 We use cookies and/or other similar technologies (including Pixel codes and in-app IDs) for the following purposes:

a.  Strictly necessary cookies

b.  enabling you to navigate round the site or application, managing your login session so you can move easily from one page to another within the site or application and your page requests are loaded in smooth and secure manner;

c.  Performance

d.  collecting anonymous statistical information about how you use the site or application (including how long you spend on the site or application) and where you have come to the site or application from, so that we can improve the site or application and in order to learn which parts of the site and which functions of the application are most popular with users;

e.  Remembering that you have visited us before. This means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get.

f.  Functionality

g.  Customising elements of the promotional layout and/or content of the pages of the site or application in order to improve your experience of the site or application.

h.  Other

i.  Undertaking research and statistical analysis in relation to your browsing of the site or use of the application.

 

10.3 We may store information about you using cookies which we can access when you visit our site or use the application in the future.

10.4 Cookies do not usually include personal data, however they may contain the type and version of internet browser you use, the type, manufacturer and model of the computer or mobile device you use, any website from which you have come to the site or application, your IP address, the operating system of your computer or mobile device and internet log information.

10.5 If you want to delete any cookies that are already on your device, please refer to the instructions for your file management software to locate the file or directory that stores cookies.

10.6 Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site or application.

10.7 We work with certain external suppliers who may also post cookies on the dashboard, such as:

10.8 This list may evolve in the future, in which case this Privacy Policy will be updated accordingly.

10.9 These external suppliers are responsible for the cookies they post on the dashboard and, for more information about these cookies, you should refer to their specific privacy policies.