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 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.