INTRODUCTION
Matt O’Bell Limited is committed to safeguarding the privacy and protection of personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID). That is why we treat any data that relates to an identified or identifiable individual, or that is linked or linkable to a person, as personal data.
This Privacy Policy explains how Matt O’Bell Limited collects, shares, uses, stores, and protects your personal data, whether you interact with us through our services, visit our offices, use our website, or interact with us in person. The policy is binding on you by accessing or using the practices described herein.
You accept the terms outlined in this Privacy Policy and hereby give Matt O’Bell Limited consent to collect, store, process, and use your Personal Data to the extent permitted under the Nigeria Data Protection Act (NDPA) by clicking on any of our consent acceptance checkboxes. You have the right to withdraw your consent at any time, provided that we do not have another lawful basis to keep processing your Personal Data.
Matt O’Bell Limited may change this Privacy Policy from time to time without prior notice. If such changes are made, we will notify you by revising the date at the top of this policy, and we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
SCOPE
This Privacy Policy applies to all individuals whose personal data we process, including:
• Clients and Partners
• Employees, Contractors/Consultants, and Applicants
• Regulatory and Compliance Stakeholders
• Visitors to our Website or Physical Offices
1. LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
All Personal Data that we collect and process is justified by at least one of the following lawful bases for processing:
• You have given consent to the processing;
• Processing is necessary for the performance of a contract to which you are a party or to take steps to enter into a contract;
• Processing is necessary for compliance with legal and regulatory obligations to which we are subject.
• Processing is necessary to protect your vital interests or another natural person;
• Processing is necessary for the performance of a task carried out in the public interest.
• Processing is necessary for the purposes of our legitimate interests or those of a third party, provided that such interests are not overridden by your rights and freedoms, are not incompatible with any of the above lawful bases, or beyond your reasonable processing expectations.
2. TYPES OF PERSONAL DATA WE PROCESS
We may collect and process the following information about you:
• Information that you provide to us, for example, when you fill out a contact or web form, or if you register to receive alerts or updates.
• When you provide your Personal Data while signing up for a service.
• Personal Data that we obtain or learn, such as information about the browser or device you use to access this site, how you use this site, and the pages you visit, traffic, and location data
• When you contact our customer support, whether by phone, email, or chat
• We may also ask you for information if you experience problems when using this site. We may also ask you to complete surveys for research purposes, though you are not required to respond.
3. USE OF YOUR PERSONAL DATA
We may use your Personal Data as follows:
• Provide, maintain, and improve our services.
• Process payments, invoices, and contracts.
• Send you technical notices, updates, security alerts and support, and administrative messages in line with our transaction with you.
• Respond to your comments, questions, and requests and provide customer service.
• Monitor and analyse trends, usage, and activities in connection with our services.
• Recruit and manage employees or contractors.
• Communicate with you about services and updates.
• Carry out any other purpose for which the Personal Data was collected.
4. DISCLOSURE OF YOUR PERSONAL DATA
Matt O’Bell Limited will disclose your Personal Data to third parties in the following circumstances:
• With your consent or based on our contract with you, we may provide such Personal Data to affiliated companies or other trusted businesses or persons for the purpose of processing Personal Data on our behalf. We require that these parties agree to process such Personal Data in accordance with our instructions and applicable laws, as well as any other relevant confidentiality and security measures. Where they no longer need your Personal Data to fulfil this service, they will dispose of the details in line with Applicable Laws.
• In response to a request for Personal Data, if we are required by, or we believe disclosure is in accordance with, any Applicable Law.
• With relevant regulatory authorities, law enforcement officials, a court order, and investigators, in line with our legal obligation.
• With your consent or at your direction, including if we notify you that the Personal Data you provide will be shared in a particular manner and you provide such Personal Data.
5. STORAGE We process Personal Data in both digital and physical formats.
Physical records are secured in a fireproof safe, while digital data is stored on cloud platforms with data centres located both within and outside Nigeria.
6. INTERNATIONAL DATA TRANSFER OF YOUR PERSONAL DATA
By accessing or using our Services or otherwise providing information to us, you consent to the processing and transfer of your information within Nigeria and to other countries. When data is transferred outside Nigeria, we ensure the recipient country has adequate, comparable data protection laws. Note that when your data is transferred to other countries, there may be an increased risk that your personal information, particularly in jurisdictions where such protection is not equivalent to that in Nigeria, could be compromised. These risks may include:
• Increased exposure to unauthorized access or misuse due to weaker enforcement mechanisms.
• Lack of enforceable data subject rights, such as the right to access, rectify, or delete personal data.
• Limited recourse for data breaches, meaning individuals may find it difficult to seek legal remedies.
• Potential government surveillance without adequate safeguards or oversight.
• Inadequate technical and organizational measures by recipients to secure data. We take reasonable steps to mitigate these risks, including through contractual safeguards (such as Standard Contractual Clauses), security measures, and ensuring that third parties processing data on our behalf adhere to high data protection standards.
7. DATA SECURITY
Matt O’Bell Limited takes reasonable measures to help protect your personal data from data loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Additionally, we implement policies designed to safeguard the confidentiality and security of your Personal Data. We have also taken measures to ensure the provision of security facilities for the protection of your Personal Data through the setup of firewalls, limited access to authorized individuals, encryption, and continuous capacity building for relevant personnel. We therefore have both digital and physical security measures in place to limit and prevent the possibility of data privacy breach incidents. We have implemented appropriate technical and organizational measures, as required by Applicable Laws, to protect Personal Data. These include data encryption in transit and at rest, role-based access control, multifactor authentication, regular security testing, audit logging, employee training on data protection, and clearly defined data retention policies.
8. PERSONAL DATA RETENTION PERIOD
Matt O’Bell Limited will retain data for as long as necessary to fulfil the purpose for which it was collected. In certain circumstances, we may retain your Personal Data for longer periods if it is in accordance with applicable regulatory, legal, or internal policies. In all cases where your Personal Data is no longer required or you request its deletion, we will ensure it is disposed of securely, subject to applicable law.
9. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance user experience and analyze site usage. You can manage your cookie preferences through your browser settings.
10. YOUR RIGHTS AS A DATA SUBJECT
This policy gives you certain rights regarding the personal data Matt O’Bell Limited holds. At any point while Matt O’Bell Limited is in possession of or processing your Personal data, the data subject has the following rights:
• Right to Access: You have the right to request access to a copy of the information that we hold about you in a commonly structured format.
• Right to Lodge Complaints: You have the right to Lodge a complaint with the Nigeria Data Protection Commission if you have a reason to believe that your rights have been violated
• Right to Rectification: You have the right to correct data that we hold about you that is inaccurate or incomplete.
• Right to Erasure: You have the right to request for the data we hold about you to be erased from our records where there is no compelling legal or regulatory requirement for its continued processing.
• Right to restrict processing: Where certain conditions apply, you have a right to restrict processing or withdraw your consent at any time of our processing of your data
• Right to Data Portability: You have the right to request that the data We hold about you be transferred to another organization
• Right to Object: You have the right to object to automated processing, including profiling of your data.
11. BREACH/PRIVACY VIOLATION
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, Matt O’Bell Limited shall, within 72 (Seventy-Two) hours of having knowledge of such breach, report the details of the breach to the Commission. Furthermore, where we make certain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we, as soon as reasonably practicable upon knowing the occurrence of such breach, take steps to inform you of the breach incident, the risk to your rights and freedoms resulting therefrom, and any course of action to remedy said breach.
12.FILING A COMPLAINT
In the event you are dissatisfied with how we process your data, we advise that you submit your complaint through our Data Protection Officer (DPO), whose details are provided below:
Email: dpo@mattobell.net
Suppose you have reasons to believe that your Personal 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. In that case, you have the right to complain to the Commission. The contact details are:
Nigeria Data Protection Commission
Tel: +234 (0) 916 061 5551
Email: info@ndpc.gov.ng
Website: https://ndpc.gov.ng/
Where you remain dissatisfied, you reserve the right to explore other appropriate legal remedies as guaranteed under Nigerian law.
13. QUESTIONS OR CONCERNS
If you have any questions or concerns about this Privacy Policy or would like to contact
us for any reason, you can contact us at dpo@mattobell.net