Privacy Notice
Introduction
This privacy Notice (“Notice”) will help you understand how Personal Data Protection Awareness (PDPA) Initiative (“PDPA Initiative”, “We”, “Us”, “Our”) collect, uses, stores, protects and generally processes the personal data you provide to us when you visit and use https://pdpainitiative.com/ (“website”). We understand that you have other things going on, so in order to encourage you to read through this notice, we have made it simple, concise and straight to the point.
We reserve the right to change this policy at any given time, of which you will be promptly updated. If you want to ensure that you are updated with the latest changes, we advise you to visit this page frequently.
Who we are
We are a Nigerian not-for-profit Civil Society Organisation working to promote the right to privacy and data protection globally. This Notice applies to the information obtained by us through your use of our Website.
What User Data We Collect
When you visit the website, based on the category you fall under, we may collect the following data:
Members;
- Full name
- Email address
- Username
- Financial details
All Website Visitor
- Your IP address.
- The domain name of the Internet service provider (ISP)
- Web pages visited, duration and frequency of visit
- Date and time of visit
- The Internet protocol address used to connect your device to the Internet for identification purposes
- Data profile regarding your online behaviour on our website.
We do not collect sensitive data. However, if we do begin to collect sensitive personal data from you at some point, you will be notified, and your consent will be sought.
Why We Collect Your Data
We are collecting your data for several reasons:
- To contact you to fill out surveys and participate in advocacies and projects.
- To help us to develop, improve, customize or restructure our projects
- To enforce our terms of service and any terms and conditions of any other agreement for our services
- to enhance data security.
- identify your device when you access your account.
- process statistical data to improve our engagement.
- To manage your account.
- Send data protection updates through our newsletter.
- To communicate with you.
- Send data protection updates through our newsletter.
- To enable registered users to log in to our ‘Member’s page’.
- To enable you to make donations to our projects.
- To install non-strictly necessary cookies on your device.
- To notify you of any changes to any of our services.
- To fulfill legal requirements where needed.
The Lawful Bases Upon Which We Process Your Personal Data
We are required to process your data under at least one of 6 lawful bases available under data protection laws. The specific bases upon which we process your personal data are;
- Legitimate interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided your rights and interests do not outweigh those interests.
- Consent: You have given explicit consent for us to process your data for a specific purpose.
- Contract: If your data processing is necessary for a contract with us or because we have asked you to take specific steps before entering that contract.
- Legal obligation: If the processing of your data is necessary where there is a statutory obligation on us.
Safeguarding and Securing the Data
PDPA Initiative is committed to securing your data and keeping it confidential. We have done all in our power to prevent data theft, unauthorized access, and disclosure by implementing the latest technologies and software, which help us safeguard all the information we collect online. Some of the safeguards we use are firewalls and data encryption, physical access controls, and information access authorization controls
Our Cookie Policy
Kindly see our cookie notice here.
Links to Other Websites
Our website contains links that lead to other websites for purposes of news updates. If you click on these links, PDPA Initiative will not be held responsible for your data and privacy protection. Visiting those websites is not governed by this privacy notice. Make sure to read the privacy notice documentation of the website you go to from our website.
Data Subject Rights
At some point, you might wish to exercise your rights as a data subject. You can achieve this by doing the following:
When you are filling out the forms on the website, make sure to check if there is a box which you can leave unchecked if you don’t want to disclose your personal information.
If you have already agreed to share your information with us, feel free to contact our Data Protection Officer (DPO) via o.nwogbo@dpainitiative.com if you desire to change any information already given, and we will be more than happy to change this for you. You can also reach complaint@pdpainitiative.com
Your rights as a data subject are;
- access personal data we hold about you by requesting a copy of the personal data we hold about you;
- rectify such information where you believe it to be inaccurate;
- restrict the processing of your data in certain circumstances;
- object to the processing of your data where we intend to process such data for marketing purposes;
- where feasible, receive all personal data you have provided to us —in a structured, commonly used, and machine-readable format—and transmit the information to another data controller;
- request the erasure of your data (also known as the right to be forgotten);
- withdraw your consent to the processing of your personal data; and
- complain with a relevant authority where you have reason to believe that we have violated the term(s) of this Privacy Notice. (You may complain or seek redress from us within 30 days from the time you first detected the alleged violation.)
If you suspect any violation of your right, you can send your complaint to the Data Protection supervisory authority in Nigeria, the Nigerian Data Protection Commission (NDPC), at info@ndpc.gov.ng
Marketing
We will not lease, sell or distribute your personal information to any third parties unless we have your permission.
Third parties we share your data with
- We may share your data with financial institutions we use to ensure financial transactions on our platform
- We may disclose your data to law enforcement and government agencies pursuant to a subpoena, or court order, when we need to do so to comply with law or credit/debit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
- We may disclose your data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, audit, or to protect the safety of any person, to address fraud, security or technical issues.
However, if you wish to prevent your device’s operating system from sharing your Personal Data with PDPA Initiative or with the third parties mentioned for profiling purposes, you can do so by setting up your device appropriately – namely, by changing the privacy settings on your device to disable/restrict any advertising tracking features. For more information on this, please see the following links:
iOS Devices: https://support.apple.com/en-us/HT202074;
Android Devices: https://support.google.com/ads/answer/2662922?hl=en
Retention of your data
We shall only keep your personal data collected from you for as long as necessary to fulfill the purposes described in this Notice. However, we will also retain personal data based on relevant provisions of applicable laws to resolve disputes and enforce our legal agreements and policies. In addition, we delete your data for targeted marketing purposes once you unsubscribe from our marketing communications.
Contact Us
If you wish to gain more clarity on how we manage your personal data or have any questions relating to this Notice, or your rights under this Notice, kindly reach out to us at complaint@pdpainitiative.com, and we will respond as soon as possible