This website is operated by Society for
Family Health Nigeria (SFH). SFH is a registered non-governmental and
not-for-profit organisation (CAC/IT/NO.3474). We value your privacy and treat
your personal information as private and confidential.
Introduction
We ask that you read this website privacy
policy carefully. By accessing and using our website, you consent to this
privacy policy. This Privacy Notice explains what personal data we may collect
about you. It also explains how we will store and handle that data and keep it
safe. We are committed to being transparent and fair when we collect and use
your personal information and to complying with the data protection laws that
apply in the countries where we operate.
We may amend this Privacy Policy at any
time by posting a revised version on our website. The revised version will be
effective 7-days after publication.
1.0 Your Privacy Rights
We understand the importance of protecting your personal
information. We are committed to protecting the privacy rights of all donors
and visitors to our website. SFH actively supports the principle of “fair and transparent”
processing of your personal information. We support your rights in relation to
your personal information under the Nigeria Data Protection Regulation,
including the:
l right to be informed (chiefly via this policy)
l right of access
l right to rectification
l right to erasure
l right to restrict processing
l right to data portability
l right to object to data transfer
l rights related to automated decision-making including
profiling
If you wish to
exercise any of these rights, please contact us in writing at No. 8, Port
Harcourt Crescent, off Gimbiya Street, Area 11, Garki, Abuja or via email at info@sfhnigeria.org.
2.0 Our Legal Bases for Processing Your
Personal Information
When we collect or use your personal
information, we are required to have a legal basis for doing so. There are
different legal bases we may rely on depending on what information we process
and our reason for doing so. The legal bases we may rely on include:
- Consent
- Where you have given us clear and
explicit consent to process your personal information for a specific
purpose. For example, when you tick a box to receive email updates or
subscribe to our e-newsletter.
- Contract
- Where our use of your personal information is necessary
for a contract we have with you. For example, when you make a donation to
our organisation.
- Legal Obligation/Legitimate
Interests
- Where our use of your personal information is necessary
for us to comply with the law or for our legitimate interests.
3.0 What data was collect and when
We
may collect and process the following catergories of information about you.
- Personal
information, including contact details (e g, name, email, postal address,
telephone number)
- When you opt in to our mailing
list, take a campaign action on our website, contact us, or donate.
- Bank details: name, sort code and
account number
- When you donate via sending us a
cheque.
- The communications you exchange
with us
- When
you email us, write a letter or call us.
- We collect non-personal data such
as IP addresses, details of web pages visited and files downloaded.
Website usage information is collected using cookies. (Please see the
section on cookies below.)
- When
you use our website.
- Your posts and messages on social
media directed to SFH
- When
you interact with us on social media platforms such as Facebook, Twitter,
Instagram or LinkedIn.
- We collect personal data as part
of our staff or volunteer recruitment processes
- When you apply for a job or for
volunteering opportunities with SFH.
Information
about you provided by third party sites are not controlled by SFH and we are
therefore not liable for how they use it.
4.0 What we do with your personal
information
We use your personal data
for the following purposes:
- To
manage your donations, requests or calls to action
- When
you interact with us, we use your information to perform our services in
relation to your donation, to deal with your queries and requests and to
process responses to our campaigns.
- To
be a part of SFH’s work
- We
know how fundamental our supporters and donors are to the work we do. In
order to develop and foster your ongoing support, we want to keep in
touch with you through feedback and further opportunities and invitations
to support our work in both financial and non-financial ways.
- To
communicate with you and manage our relationship with you
- Occasionally
we may need to contact you by mail, email and/or telephone for
administrative or operational reasons – for example, to send you
confirmation of your donation. Please be aware that these communications
are not made for marketing purposes and as such, you will continue to
receive them even if you opt out of receiving marketing communications
from us.
- We
will also use your personal data if we contact you after you have sent us
a request, filled in a web form through our website or contacted us on
social media.
SFH does
not share your data with any other charity, public body, or commercial
organisation, unless we have to do so either for legal or compliance reasons,
where you have given permission for us to do so, or where it is more cost effective and efficient
for us to use a third party to deliver a product or service on our behalf.
Whenever
we collect or process your personal data, we’ll only keep it for as long as is
necessary for the purpose for which it was collected. At the end of that
retention period, your data will either be deleted completely or anonymised.
5.0 Cookies
Cookies
are small files placed on your computer’s hard drive that enables the website
to identify your computer as you view different pages. Cookies allow websites
and applications to store your preferences in order to present contents,
options or functions that are specific to you. Like most interactive websites,
our website uses cookies to enable the tracking of your activity for the
duration of a session. Our website uses only encrypted session cookies which
are erased either after a predefined timeout period or once the user logs out
of the platform and closes the browser. Session cookies do not collect
information from the user’s computer. They will typically store information in
the form of a session identification that does not personally identify the user.
Kindly refer to our Cookie Policy for more information on cookies.
6.0 How we protect your personal
information
We
have appropriate security measures in place to prevent your personal
information from being accidentally lost or used or accessed in an unauthorized
way.
We store and process your personal
information on our computers and servers in Nigeria. Where we need to transfer
your data to another country, such country must have an adequate data
protection law. We will seek your consent where we need to send your data to a
country without an adequate data protection law.
We protect your information using
physical, technical, and administrative security measures to reduce the risks
of loss, misuse, unauthorized access, disclosure and alteration. Some of the
safeguards we use are firewalls and data encryption, physical access controls
to our data centers, and information access authorization controls.
We also have procedures in place to deal
with any suspected data security breach. We will notify you and the applicable
regulator of any suspected data security breach where we are legally required
to do so.
We are mandated by law to have a
dedicated Data Protection Officer. If you have any enquiries about the handling
of your personal data, you contact our Data Protection Officer, Mr Babatunde
Oyelana, by emailing him at[NC1] boyelana@sfhnigeria.org.
7.0 Security
We will always hold your information
securely. To prevent unauthorized access to your information, we have
implemented strong controls and security safeguards at the technical and
operational levels. This site uses Secure Sockets Layer/Transport Layer
Security (SSL/TLS) to ensure secure transmission of your personal data. You
should see the padlock symbol in your URL address bar once you are successfully
logged into the platform. The URL address will also start with https://
depicting a secure webpage. SSL applies encryption between two points such as
your PC and the connecting server. Any data transmitted during the session will
be encrypted before transmission and decrypted at the receiving end. This is to
ensure that data cannot be read during transmission.
SFH has also taken measures to comply
with global Information Security Management Systems (ISMS). We therefore have
put in place digital and physical security measures to limit or eliminate
possibilities of data privacy breach incidents.
8.0 Data Confidentiality Rights
Your information is regarded as
confidential and will not be divulged to any third party except under legal
and/or regulatory conditions. You have the right to request sight of, and
copies of any and all information we keep on you, if such requests are made in
compliance with the Freedom of Information Act and other relevant enactments. While
SFH is responsible for safeguarding the information entrusted to us, your role
in fulfilling confidentiality duties includes, but is not limited to, adopting
and enforcing appropriate security measures such as non-sharing of passwords
and other platform login details.
We limit access to your personal
information to those who have a genuine business need to know it. Those
processing your information will only do so in an authorised manner and are
subject to a duty of confidentiality.
9.0 Links to Other Websites and Premises
Certain transaction processing channels
may require links to other websites or Organisations other than ours. Please
note that SFH is not responsible and has no control over websites outside its
domain. We do not monitor or review the content of other party’s websites which
are linked from our website or media platforms. Opinions expressed or materials
appearing on such websites are not necessarily shared or endorsed by us, and
SFH should not be regarded as the publisher of such opinions or materials.
Please be aware that we are not responsible for the privacy practices, or
content of these sites. We encourage our users to be aware of when they leave
our site and to read the privacy statements of these sites. You should evaluate
the security and trustworthiness of any other site connected to this site or
accessed through this site yourself, before disclosing any personal information
to them. SFH will not accept any responsibility for any loss or damage in
whatever manner, howsoever caused, resulting from your disclosure to third
parties of personal information.
10.0 How to Lodge a Complaint/Contacting
the Regulator
If you feel that your
data has not been handled correctly, or you are unhappy with our response to
any requests you have made to us regarding the use of your personal data, you
have the right to lodge a complaint with the regulator National Information Technology Development Agency (NITDA). If you are based outside Nigeria, you have the
right to lodge your complaint with the relevant data protection regulator in
your country of residence.
11.0 Governing Law
This
Privacy Policy is made pursuant to the Nigeria Data Protection Regulation
(2019) and other relevant Nigerian laws, regulations or international
conventions applicable to Nigeria. Where any provision of this Policy is deemed
inconsistent with a law, regulation or convention, such provision shall be
subject to the overriding law, regulation or convention.
[NC1]You can change Tunde’s name and email address to mine.