(1) The Information We Collect
(2) How We Collect and Use Your Data
(3) Consent and Access Rights
(4) Personal Data Protection Principles
(5) User Responsibility
(6) Data Security
(7) Link to Third Party Sites
(8) Third Party Access
(9) Violation of Privacy
(10) How to Contact Us
1. The Information We Collect
We collect the following information: First Name, Last Name, Gender, Phone Number, Date of Birth / Age, Address / Postal Address, Email, Country Code, City, Insurance Company, marital status, biometric data, religion or other beliefs, sexual orientation, health, race, ethnicity, political views, trades union membership, criminal records and other information relevant which constitute Personal Data or sensitive data.
2. How We Collect and Use Your Data
2.1 Investsmall collects the above-mentioned information using forms, email, physical requests, cookies, web tokens and pi-sync.
2.2 When you send email or other communications to Investsmall, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. When you access Investsmall’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, listing on pharmaceutical and medical directories, publicity, human resources management, recruitment, events planning
and hosting, in-house security and analysis, key business operation, processing or carrying out tasks to fulfill business goals or objectives and purposes that are agreed with the Data Subject.
3. Consent and Access Rights
3.1 We require your consent for the processing of your data. We shall obtain your consent for individual matters, where any document deals with different matters.
3.2 If we intend to use your data for a purpose which is different from the purpose for which your data was obtained, we will seek your consent prior to the use of your data for that other purpose.
3.2 In the event of any merger, acquisition or other arrangement whereby Investsmall 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 Investsmall can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by Investsmall prior to such merger, acquisition or other arrangement. Investsmall 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.
3.3 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 conducts.
3.4 You may withdraw your consent, in writing, at any time and may request access to your personal information in our possession at [ ]. We can, however, deny you access to the information where we determine that your request is unreasonable.
3.5 You reserve the right to request the modification or amendment of your personal data in our possession.
3.6 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. YOUR RIGHTS
You have rights in relation to the way we handle your personal data. These include the following rights:
a) where the legal basis of our processing is consent, to withdraw that consent at any time;
b) to ask for access to the personal data that we hold;
c) to prevent our use of the personal data for direct marketing purposes;
d) to object to our processing of personal data in limited circumstances; and
e) to ask us to erase personal data without delay:
(i) if it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
(ii) if the only legal basis of processing is consent and that consent has been withdrawn and there is no other legal basis on which we can process that personal data;
(iii) if you object to our processing where the legal basis is the pursuit of a legitimate interest or the public interest and we can show no overriding legitimate grounds or interest; and
(iv) if the processing is unlawful.
f) to ask us to rectify inaccurate data or to complete incomplete data;
g) to restrict processing in specific circumstances e.g. where there is a complaint about accuracy;
h) to ask us for a copy of the safeguards under which personal data is transferred outside of Nigeria;
i) the right not to be subject to decisions based solely on automated processing, including profiling, except where necessary for entering into, or performing, a contract, with Investsmall; it is based on your explicit consent and is subject to safeguards; or is authorised by law and is also subject to safeguards;
j) to prevent processing that is likely to cause damage or distress to you or anyone else;
k) to data portability;
l) to be notified of a personal data breach which is likely to result in high risk to their rights and freedoms;
m) to make a complaint to NITDA or any other regulatory body; and
n) in limited circumstances, receive or ask for their personal data to be transferred to a Third Party (e.g. another company which the client has dealing with) in a structured, commonly used and machine-readable format.
5. 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 organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
6. 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.
7. Data Security
6.1 Investsmall implements and maintains appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to their personal data.
7.2 Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting confidentiality (i.e. that only those who need to know and are authorised 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 security of our processing of personal data.
7.3 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. Investsmall, therefore, accepts no liability for any damage or loss, however caused, in connection with transmission over the internet or electronic storage.
8. Links to third party sites
9. Third Party Access
9.1 Investsmall will only share personal information with other companies, entities or individuals in the following limited circumstances:
a) We have your consent.
c) We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce applicable terms of service, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to the rights, property or safety of Investsmall, its users or the public as required or permitted by law.
9.2 Investsmall is at all times, responsible for the security and appropriate use of that data as long as it remains with Investsmall.
10. Violation of Privacy
10.1 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.
10.2 All suspected breach of personal data will be remedied within1 (one) month from the date of the report of the breach.
10.3 If you know or suspect that a personal data breach has occurred, you should immediately contact the Investsmall team at firstname.lastname@example.org .
10.4 Investsmall will not be responsible for any personal data breach which occurs as a result of:
a) an event which is beyond the control of Investsmall;
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 Investsmall’s data protection measures;
d) war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo;
e) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises Investsmall’s data protection measures;
f) Pandemics or epidemics;
g) the transfer of your personal data to a third party on your instructions; and h) the use of your personal data by a third party designated by you.
11. Data Retention
Investsmall shall retain and use your Personal Data only as long as is necessary to implement, administer and manage your request and contract with Investsmall and a maximum of [•] after the expiration or termination of the contract or as required to comply with legal or regulatory obligations, including under tax and security laws. At your request, at any time, your Personal Data which is in the custody of
Investsmall may be deleted unless we are required by law to retain such information for a certain period of time so at to comply with our obligations under the law.
12. How to Contact Us