Data and Privacy Policy

1.0 INTRODUCTION

Proliance Ltd is a registered business and management consulting, supply chain management, learning and development services in the Energy and Natural Resources, Manufacturing, Technology and Communication, Food and Agriculture, Healthcare Industries, Government and International Development Agencies. All our services are carried out with the clear understanding that our customer data privacy is important and we are committed to the protection of personal information in accordance with the Nigeria Data Protection Act and other relevant global privacy regulations.

2.0 DEFINITIONS

3.0 SCOPE

This policy covers Proliance Ltd requirements for the processing, protection and storage of data in manual, electronic or any other documented format for execution of our services.

4.0 INFORMATION COLLECTION AND USE

We collect different types of information for various purposes to provide and continually improve our services to you.

5.0 TYPES OF DATA COLLECTED

5.1 Personal Data

For the purposes of service delivery, we may request that you provide us with certain personal information for identification that we can use for your identification and to contact. Such personally, identifiable information may include, but is not limited to:

• Name and Contact Data: We may collect your first name, middle and last name, email address, postal address, phone number, signature, date of birth, an identifiable document such work identity card, national identity card, and any other similar contact and identity data.
• Credentials: When you make use of any of our digital products, apply for a job position or as a supplier or register for our training programmes, you may be required to provide credentials such as educational or professional licenses, registration documents and statutory licenses to show evidence of qualifications for the particular services. We may also request for these credentials for reference when delivering services to you as a client and as may be needed. You may also be required to provide a user ID or password when using our digital products.
• Usage Data: We may collect certain information that your browser sends whenever you access our website or online platforms. This may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, time and period of your visit, duration spent on pages, geo-location information, mobile device access, mobile device data, tracking and cookies data and any other diagnostic data.
• Cookies Data: We use cookies and similar tracking technologies to track the activity on our services. Cookies are files with small amount of data which may include an anonymous unique identifier. We do not use cookies to track you or to retain any personal information, the cookies are used to store some information about the technical capabilities of your computer or device in order to give you a better experience. You can instruct your browser to refuse all cookies or to indicate when cookie is being sent.

5.2 Web Analytics

We use Google Analytics to measure behavior of users on the website. Google Analytics cookies records data about a user as well as remember user behavior across websites. A unique ID is assigned to users which does not identify personality and is not used to track personal information. It only enables Google to track individual activity and return visits. If you wish to prevent the collection of data regarding your activity on our website by Google Analytics, you can use Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout/. You can also prevent the storage of cookies by adjusting your browser software accordingly. For more information on the privacy policies of Google, please visit the Google Privacy & Terms web page at https://policies.google.com/privacy?hl=en

5.3 Links to Other Sites

Our website and online platforms may contain links to other sites that are not operated by Proliance Ltd or her partners. If you click on a third-party link, you will be directed to that third-party site. It is recommended that review the "Privacy Policy" of every site you visit and interact with.

5.4 Use of Data

Proliance Ltd collects Personal Data provided to us only for the purpose(s) identified accordingly by the Data Subject and for which consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except if a new Consent is obtained. The purposes for which we will use your personal data include:

• For the provision of services to you. For example, when you request for our services or apply for a job opening, we will use your personal data to process your requests.
• To process and issue completion certificates, display customized service and training content, and facilitate communication with other users, as applicable.
• For customer care and billing, as may be applicable. When you use our services, we will use your personal information to bill you and to respond to inquiries and concerns that you may have about our services.
• Customer service messages. We will use your personal data to keep you updated with the latest information or changes about our products and services.
• For marketing purposes. To serve you better, we will use your personal data to market our products and services to you.
• To comply with relevant laws and regulations and internal policies of the Company.
• Fraud prevention and security. We will process your personal and traffic data to protect you against and detect fraud, to protect and detect misuse or damage to our platforms, services or products.

6.0 BASIS FOR LAWFUL PROCESSING

The personal data we collect and how we collect it depends on the nature of services or requests we receive. Please note that we only process your personal data in line with the Nigeria Data Protection Regulation and the Nigeria Data Protection Act, 2023. We rely on the basis of the following for lawful processing:

• Where you give us consent to the processing of your Personal Data for one or more specific purposes. You are at liberty to withdraw the consent and Proliance Ltd will cease to process your Personal Data where there is no other basis to do so.
• Where the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
• Processing is necessary for compliance with a legal obligation to which Proliance Ltd is subject.
• Processing is necessary to protect the vital interests of the Data Subject or of another natural person.
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in Proliance Ltd.
• For the purpose of legitimate interests pursued by the data controller or data processor or by a third party to whom the data is disclosed so such legitimate interests are within the scope of the Nigeria Data Protection Act, 2023.

7.0 TRANSFER OF DATA

Proliance Ltd will not share your personal data with a third party. Where it becomes necessary to do so, for security reasons and as maybe required by law, adequate security measures will be taken to protect the data from access by recipients other than those for which it is intended.

All data we collect will reside in Proliance Ltd computer systems in Nigeria and any other of her locations as may be applicable. Where cloud services are used, adequate governance measures that apply to such cloud services will be complied with.

Proliance Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to another organization that is not part of Proliance Ltd or country unless there are adequate controls in place including the security of your data and other personal information.

Transfer of Personal Data to a Foreign Country

Where Personal Data is to be transferred to a country outside Nigeria, Proliance Ltd shall put adequate measures in place to ensure the security of such Personal Data. In particular, we shall, among other things, conduct a detailed assessment of whether the said country is on the Nigeria Data Protection Commission's White List of Countries with adequate data protection laws.

Transfer of Personal Data out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation, 2019 (NDPR) and the Nigeria Data Protection Act, 2023. Proliance Ltd will therefore only transfer Personal Data out of Nigeria or process data on one of the following conditions:

• The consent of the Data Subject has been obtained.
• It is necessary for the performance of a contract between Proliance Ltd and the Data Subject or implementation of pre-contractual measures taken at the Data Subject's request.
• It is necessary to conclude a contract between us and a third party in the interest of the Data Subject.
• It is necessary for reason of public interest.
• It is for the establishment, exercise or defense of legal claims.
• It is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
• It is necessary for the purposes of the legitimate interests pursued by Proliance Ltd or by a third party to whom the data is disclosed. Provided, in all circumstances, that the Data Subject has been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where the Data Subject is answerable in duly established legal action for any civil or criminal claim in a third country. Proliance Ltd will take all necessary steps to ensure that the Personal Data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Nigeria shall be provided upon the Data Subject's request. Where the recipient country is not on the Whitelist and none of the conditions stipulated in this Privacy Policy are met, Proliance Ltd will engage with relevant authorities for approval with respect to such transfer.

8.0 DISCLOSURE OF DATA

Proliance Ltd will only share and disclose your information in any of the following situations:

• Compliance with relevant laws: We may disclose your information where we are legally required to do so in order to comply with applicable law, security purposes, governmental requests, a judicial proceeding, court order, or legal process, such as response to a court order or subpoena.
• Performance of contractual obligations: We may disclose your data to perform and conclude a contract to which the Data Subject is party.
• Vital interests and Legal Rights: We may disclose your personal data where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• External Service Provider: We may disclose your data with third-party external service providers (suppliers, contractors, or company agents) who perform services on our behalf and require access to such information to perform assigned functions accordingly.
• Business Partnership and Continual Improvement: We may share your information in the event of negotiations of any business partnership or acquisitions, sale of company assets, or financing.
• We may disclose your information other than the listed on your consent.

9.0 PROTECTION OF YOUR DATA

Proliance Ltd have established adequate controls to protect the integrity and confidentiality of Personal Data, both in digital and physical format, and to prevent personal data from being accidentally or deliberately compromised. Personal information of Data Subjects must be protected from unauthorized viewing or access and from unauthorized changes to ensure that it is reliable and correct.

Our website is secure and duly encrypted to ensure adequacy in protection of your personal data. We shall carry out routine maintenance and reviews to ensure only authorised party have access to your personal information.

10.0 GENERAL PRINCIPLES FOR PROCESSING OF PERSONAL DATA

Proliance Ltd is committed to maintaining the principles in the NDPR regarding the processing of Personal Data. To demonstrate this commitment as well as our aim of creating a positive privacy culture within the company, Proliance Ltd adheres to the following basic principles relating to the processing of personal data:

10.1 Lawfulness, Fairness and Transparency

Personal Data must be processed lawfully, fairly and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of Proliance Ltd must be in accordance with the specific, legitimate and lawful purpose consented to by the Data Subject, save where the processing is otherwise allowed by law or within other legal grounds recognized in the NDPR and the Nigeria Data Protection Act 2023.

10.2 Data Accuracy

Personal Data must be accurate and kept up to date. In this regard, Proliance Ltd shall:

• Ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to the Data Subject.
• Make efforts to keep Personal Data updated where reasonable and applicable.
• Make timely efforts to correct or erase Personal Data when inaccuracies are discovered.

10.3 Purpose Limitations

Proliance Ltd collects Personal Data only for the purposes identified in the appropriate Privacy Notice provided to the Data Subject and for which consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except a new consent is obtained, save where the processing is otherwise allowed by law or within other legal grounds recognized in the NDPR and the Nigeria Data Protection Act 2023.

10.4 Data Minimization

We limit Personal Data collection and usage to data that is relevant, adequate, and necessary for carrying out the purpose for which the data is processed. Proliance Ltd will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized and/or pseudonymized data must be used.

10.5 Integrity and Confidentiality

Proliance Ltd shall establish adequate controls in order to protect the integrity and confidentiality of Personal Data, both in digital and physical format and to prevent personal data from being accidentally or deliberately compromised. Personal data of Data Subjects must be protected from unauthorized viewing or access and from unauthorized changes to ensure that it is reliable and correct.

Any personal data processing undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties is un-authorized. Employees may have access to Personal Data only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Data for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way. All employees are required to be fully informed about this privacy policy during induction and on a continual basis through awareness and signed declarations.

10.6 Personal Data Retention

All personal information shall be retained, stored and destroyed by Proliance Ltd in line with legislative and regulatory guidelines. For all Personal Data and records obtained, used and stored within the company, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and to the extent permitted by applicable laws and without prejudice to the company's document retention process, the length of storage of Personal Data shall, amongst other things, be determined by:

• The contract terms agreed between the Company and the Data Subject or as long as it is needed for the purpose for which it was obtained.
• Whether the transaction or relationship has statutory implication or a required retention period.
• Whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where there are no legal or regulatory requirements to keep such data, or the Data Subject is not under any investigation which may require us to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data.
• Whether Proliance Ltd has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose. Notwithstanding the foregoing and pursuant to the NDPR and the Nigeria Data Protection Act, 2023, we shall be entitled to retain and process Personal Data for archiving, scientific research, historical research or statistical purposes for public interest.

Proliance Ltd would forthwith delete Personal Data in the Company's possession where such Personal Data is no longer required by the Company or in line with Proliance Ltd's Retention Policy, provided no law or regulation being in force requires the Company to retain such Personal Data. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law.

10.7 Accountability

Proliance Ltd demonstrates accountability in line with the NDPR obligations by monitoring and continuously improving data privacy practices within the company.

Any individual or employee who breaches this Privacy Policy may be subject to internal disciplinary action (up to and including termination of their employment); and may also face civil or criminal liability if their action violates the law.

When a potential breach has occurred, Proliance Ltd will investigate to determine if an actual breach has occurred and take the necessary actions required to manage and investigate the breach. Such actions include:

• Validating the Personal Data breach.
• Ensuring proper and impartial investigation (including digital forensics if necessary) is initiated, conducted, documented, and concluded.
• Identifying remediation requirements and track resolution.
• Reporting all findings to the company leadership.
• Coordinating with appropriate authorities as needed.
• Coordinating internal and external communications.
• Ensuring that impacted Data Subjects are properly notified, if necessary.

11.0 CONSENT OF MINORS

We do not knowingly collect personally identifiable information from anyone under the age of 18. In the unlikely event that we deal with minors, the consent of minors will always be protected and obtained from minors' representatives in accordance with NDPR and applicable regulatory requirements.

12.0 YOUR PRIVACY RIGHTS

Proliance Ltd collects Personal Data only for the purposes identified in this Policy and such information cannot be reused for another purpose that is incompatible with the original purpose.

You can exercise the following rights with respect to your Personal Data with Proliance Ltd:

• Request for and access your Personal Data collected and stored by Proliance Ltd.
• Withdraw consent at any time. For example, you can withdraw your consent to the receipt of our marketing or promotional materials or unsubscribe to our newsletters.
• Object to automated decision making.
• Request rectification and modification of Personal Data kept by Proliance Ltd.
• Request for deletion of your Personal Data.
• Be informed of and entitled to provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data was collected.
• Request that Proliance Ltd restricts processing of your Personal Data.
• Request for information regarding any specific processing of your personal data.
• Lodge a complaint with the Nigeria Data Protection Commission.

If you wish to exercise any of these rights, you may contact our Data Protection Officer (DPO) using the contact details provided below.

13.0 TRAINING

Proliance Ltd shall ensure that personnel performing work on behalf of the Company and who collect, access and process Personal Data are equipped with the required training and awareness to execute their task impartially and in accordance with requirements of this policy, NDPR and the Nigeria Data Protection Act of 2023.

14.0 DATA PROTECTION OFFICER (DPO)

Proliance Ltd shall appoint a Data Protection Officer (DPO) under the Risk & Compliance Unit of our Corporate Services Division. The DPO has the core responsibility for overseeing the Company's data protection programmes and its implementation to ensure compliance with the NDPR and the Nigeria Data Protection Act (2023) requirements. The DPO shall be a knowledgeable person on data privacy, Quality Assurance, Internal Auditing and protection principles and shall be familiar with the provisions of the NDPR and the Nigeria Data Protection Act (2023) and the European General Data Protection Regulation (GDPR).

15.0 DATA PROTECTION PERFORMANCE EVALUATION

Proliance Ltd shall conduct an annual data protection to verify our compliance with the provisions of the NDPR, the Nigeria Data Protection Act (2023) and other applicable data protection laws.

16.0 REVIEW OF THIS PRIVACY POLICY

Proliance Ltd reserves the right to change, amend or alter this Policy at any point in time. If we amend this Policy, we will provide you with the updated version.

17.0 CONTACT US

If you require any question or comments regarding this policy or any of our policies, email us at: