1.0 INTRODUCTION /SCOPE 

1.1 This privacy policy is prepared in accordance with the provisions of the Nigeria Data Protection Act (NDPA), and by extention, the EU General Data Protection Regulation (GDPR). It establishes how Patrons applies and complies with the data privacy principles in processing the personal data of customers, staff, vendors, visitors and third parties that interact with Patrons. 

1.2 For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed, in compliance with the NDPA.

1.3 This privacy policy describes why and how we collect and use personal information about our customers, clients, vendors, and visitors (data subjects). It also highlights with whom we might share Personal Information and how long we keep such information. It also makes data subjects aware of their rights under the regulation.

 

2.0 POLICY STATEMENT

2.1 Patrons is committed to protecting the privacy and security of personal data. We are responsible for determining how we hold and use personal information about our data subjects. According to the Nigeria Data Protection Act (NPDA), Patrons is required to notify data subjects of the information contained in this document.

 

3.0 CONSENT

3.1 You accept this privacy policy when you give consent upon access to our platforms, or use our services, content, features, technologies or functions offered on our website, digital platforms or visit any of our offices for official or non-official purposes (collectively the “Patrons Services”). This privacy policy governs the use of the Patrons Services and intervention projects by our users and stakeholders, unless otherwise agreed through a written contract. We may amend this privacy policy at any time by posting a revised version on our website, or placing such notice at conspicuous points at our office facilities. The revised version will be effective 7 days after publication.

 

4.0 YOUR PERSONAL INFORMATION

4.1 When you use the Patrons Services, we collect information sent to us by your computer, mobile phone or other electronic access device. The automatically collected information includes but is not limited to data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, standard web log data, still and moving images.

4.2 We may also collect information you provide us including but not limited to- information on web form, survey responses account update information, email address, phone number, organization you represent, official position, correspondence with the Patrons support services. We may also collect information about your transactions, enquiries and your activities on our platform or premises.

4.3 We may also use information provided by third parties like social media sites. Information about you provided by other sites are not controlled by the Patrons and we are, therefore, not liable for how such third parties use your information.

 

5.0 WHAT WE DO WITH YOUR PERSONAL INFORMATION

The purpose of our collecting your personal information is to give you efficient, enjoyable and secure service. We may use your information to:

1. a) provide the Patrons Services and support;
2. b) process applications and send notices about your transactions to requisite parties;

1. c) verify your identity;
2. d) resolve disputes, collect fees, and troubleshoot problems;
3. e) manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities; detect, prevent or remediate violation of laws, regulations, standards, guidelines and frameworks;

1. g) improve the Patrons Services by implementing aggregate customer or user preferences;
2. h) measure the performance of the Patrons Services and improve content, technology and layout;
3. i) track information breach and remediate such identified breaches;
4. j) manage and protect our information technology and physical infrastructure; or

1. k) contact you at any time through your provided telephone number, email address or other contact details.

 

6.0 COOKIES

6.1 Cookies will typically be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serve a number of purposes. 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.

On some of our websites, a notification banner will appear allowing you to manage your consent to collect cookies (cookie banner). Below is a summary of the categories of cookies collected on our websites, and how your consent may impact your experience of certain features as you navigate those websites:

6.2 Note that if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our website may not work properly if you elect to refuse cookies.

 

7.0 PROCESSING OF PERSONAL DATA BASED ON CONSENT

7.1 Where applicable Patrons will require the explicit consent of customers, visitors, and other relevant stakeholders to process collected personal data. 

Visitors to the Patrons website are expected to read and understand the website privacy notice, and then agreeing to the website’s terms of use. And by consenting to the privacy policy, data subjects are giving Patrons the permission to use/process their personal data specifically for the purpose identified before collection.

On this ground, if any data subject (customer, client, visitor, vendor, staff, or thirdparty) does not agree to Patrons collecting and processing their personal data, such individual is not allowed to enjoy the Patron’service(s) where applicable.

7.2 If, for any reason, the Patrons is requesting sensitive personal data from its stakeholders (external and internal), the individuals will be rightly notified why and how the information will be used. 

7.3 Where processing relates to a child under 18 years old, as in the case of NDPA or 16 years in the case of GDPR, Patrons shall demonstrate that consent has been provided by the person who holds parental responsibility over the child. Patrons shall demonstrate that reasonable efforts have been made to verify the age of the child and establish the authenticity of the parental responsibility taking into consideration available technology.

 

8.0 YOUR RIGHTS

At any point while Patrons is in possession of or processing  your personal data, you have the following rights:

8.1 Access and correction: You have the right to access that data. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.

8.2 Object to processing: You have the right to object to us processing your personal information if we are not entitled to use it anymore.

8.3 Right to Data Portability: You have the right to transfer your personal data to a third party or another organization.

8.4 Rights to withdraw consent: You have the right to withdraw, at any time, your consent to the processing of your personal data

 

9.0 Data security and integrity

Patrons has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite Patron’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

9.1 We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual’s request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to the requirements of i)–iii) above, personal information will not be retained for longer than necessary.

 

10.0 LINKS TO OTHER WEBSITES

10.1 Please be aware that Patrons’ websites will typically contain links to other sites. We encourage users to review the privacy policy of each website visited before disclosing any personal information.

10.2 By registering on Patrons’ website and then navigating to other sites affiliated to Patrons while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the affiliated site you are visiting.

 

11.0 MODIFICATIONS AND UPDATES 

Patrons may modify this Privacy Policy from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal data as described in this Privacy Policy affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

 

12.0 COMPLAINTS

12.1 Patrons is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at +234 803 041 0086 or art@patronsmcaa.com