OUR PRIVACY POLICY
At Zeta-Web, your privacy and data are as important to us as it is to you.
YOUR PRIVACY COMES FIRST, ALWAYS!
At Zeta-Web, we put YOU first; and we’re committed to protecting and respecting your privacy.
We are also committed to being transparent about how we collect, process, share and manage your data (our customers, vendors, suppliers, etc. where applicable).
1. ZETA-WEB AND YOU
This Privacy Policy stipulates the company’s approach to handling your data and your rights with regards to our collection, use, storage and sharing of your personal data which may be collected by us in the course of providing you with exceptional services and solutions, across all our delivery channels to meet your needs.
2. YOUR PERSONAL INFORMATION
In other for Zeta-Web to meet your needs, we collect information you provide us via forms, phone calls, and correspondence by mail or emails, and any other channels we make available to you from time to time in the course of consuming services provided to you.
The information we collect may include but not limited to:
- company representatives or contact person(s) of record,
- email address(es) of representatives
- phone number (s) of representatives
- designation of representatives
- services/solutions types, and services/solutions desired/required,
- mode of delivery,
- business location,
- instructions and transactions relating to the services/solutions offered.
3. CONSENT
Your personal information collected is used for the sole purpose of improving our products and services for you. We want to be sure we have your consent to collect, use and, where necessary, share your information with our partners and suppliers that help us serve you.
Whenever we introduce new services and technologies, we’ll ensure you understand and agree to any new ways in which your information will be handled.
Do note that you will be considered to have given your consent to us for the processing of your personal data when:
- You complete any form, brochure or material issued by Zeta-Web by our Sales Consultants, IT Engineers, Support Desk (mobile, online, etc.) requesting for such personal information.
- You register, check or tick the acceptance box on any of our electronic platforms (Online or Mobile) relating to terms and conditions of any service or product offered by Zeta-Web.
- You send a request, complaint or other communication to Zeta-Web.
- You use any service, solutions or product offered by Zeta-Web.
4. USE OF YOUR INFORMATION
Zeta-Web will process your personal information for the following purposes;
- To offer and provide our Products and Services tailored to meet your unique needs
- To fulfil the terms of any service contract(s) you might have with us
- To improve your service experience with us
- To conduct our business
- To manage our relationship with you
- To comply with Laws and Regulations
- To update your records
- To develop statistics as may be required
- To comply with our Internal Policies
- To communicate with you when and where necessary
Zeta-Web will limit the collection and use of your personal information for the stated purposes.
5. COOKIES
Please note that for our digital channels, we may collect information about your computer (or mobile device), including where available or necessary, your IP address(es), operating system and browser type for system administration or for our own commercial purposes. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
6. DATA SHARING AND DISCLOSURE
Why might you share my personal information with third parties?
We will only share your personal information with our approved partners (OEMs) for the purposes of processing your application and to render services to your business.
Zeta-Web will not sell or rent your personally identifiable information to anyone.
Zeta-Web may share or disclose your personal information to other third parties where:
- We have your consent to share or disclose such personal information;
- We are required by law to share or disclose such personal information
- We respond to subpoenas, court orders or other legal processes;
- We find that your actions on our electronic platforms violate any of our Policies for the purpose of investigations, reporting and enforcing any of our rights.
- Required for audit purposes.
Within the group, we have in place robust IT systems and processes as well as ongoing monitoring and compliance. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Zeta-Web may also disclose or share your personal information where it is necessary to enforce the terms and conditions of any of our Products and Services or any of our rights as well as to protect our operations and customers.
7. DATA PROTECTION AND RETENTION
DATA SECURITY
Zeta-Web will always ensure that your personal information is adequately protected. We have put appropriate security measures in place – processes and technologies – to ensure your personal information is not modified, lost, damaged or destroyed.
In addition, we limit access to your personal information to those employees, agents, and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
Our people are trained to ensure that your personal information is not disclosed and safe as stated in this policy.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DATA RETENTION
We will retain your personal information for such length of time as may be required by law, regulation, the internal policies of Zeta-Web; but not later than two (2) years after discontinuation of our services to your business.
8. YOUR RIGHTS UNDER THIS POLICY
The following rights are available to you under this Policy:
- You may at any time request for access to your personal information held by Zeta-Web or request that your personal information be made available to a third party. Your request may specify the format in which the information should be made available subject to Zeta-Web having the capacity to provide the personal information in the requested format.
- You may request to update your personal information with Zeta-Web at any time – this enables you have any incomplete or inaccurate information we hold about you corrected.
- You may elect to withdraw your consent at any time; Save where there is a legal or operational reason to continue with the processing of your personal data, Zeta-Web shall discontinue the processing of your personal data upon receipt of your notice withdrawing consent. Such withdrawal however may impact Zeta-Web ability to provide some products or services to you if your consent is mandatory for the execution for providing such services.
- Your right to withdraw consent extends to objecting or restricting the processing of your personal data by Zeta-Web.
- You may request that your personal information be deleted. We may continue to retain such personal information as may be required for compliance with legal, regulatory or policy requirements.
9. DATA BREACH MANAGEMENT PROCEDURE
- A Data Breach Procedure is established and maintained in order to deal with incidents concerning Personal Data or privacy practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
- All employees must inform their designated line manager or the DPO of Zeta-Web immediately about cases of violations of this Policy or other regulations on the protection of Personal Data, in accordance with Zeta-Web’s Personal Data Breach Management Procedure in respect of any:
- improper transmission of Personal Data across borders;
- loss or theft of data or equipment on which data is stored;
- accidental sharing of data with someone who does not have a right to know this information;
- inappropriate access controls allowing unauthorized use;
- equipment failure;
- human error resulting in data being shared with someone who does not have a right to know; and
- hacking attack.
9.3 A Data Protection Breach notification must be made immediately after any data breach to ensure that:
- immediate remedial steps can be taken in respect of the breach;
- any reporting duties to NITDA or any other regulatory authority can be complied with;
- any affected Data Subject can be informed; and
- any stakeholder communication can be managed.
9.4 When a potential breach has occurred, Zeta-Web will investigate to determine if an actual breach has occurred and the actions required to manage and investigate the breach as follows:
- Validate the Personal Data breach;
- Ensure proper and impartial investigation (including digital forensics if necessary) is initiated, conducted, documented, and concluded;
- Identify remediation requirements and track resolution;
- Report findings to the top management;
- Coordinate with appropriate authorities as needed;
- Coordinate internal and external communications; and
- Ensure that impacted Data Subjects are properly notified, if necessary.
10. DATA PROTECTION IMPACT ASSESSMENT
Zeta-Web shall carry-out a Data Protection Impact Assessment (DPIA) in respect of any new project or IT system involving the processing of Personal Data to determine whenever a type of processing is likely to result in any risk to the rights and freedoms of the Data Subject.
Zeta-Web shall carry out the DPIA in line with the procedures laid down in the Zeta-Web Data Protection Impact Assessment Policy (DPIA).
11. DATA SECURITY
- All Personal Data must be kept securely and should not be stored any longer than necessary. Zeta-Web will ensure that appropriate measures are employed against unauthorized access, accidental loss, damage and destruction to data. This includes the use of password-encrypted databases for digital storage and locked cabinets for those using paper form.
- To ensure security of Personal Data, Zeta-Web will, among other things, implement the following appropriate technical controls:
- Industry-accepted hardening standards, for workstations, servers, and databases;
- Full disk software encryption on all corporate workstation/laptops operating systems drives storing Personal and Personal/Sensitive Data;
- Encryption at rest including key management of key databases;
- Enable Security Audit Logging across all systems managing Personal Data;
- Restrict the use of removable media such as USB flash, disk drives;
- Anonymization techniques on testing environments; and
- Physical access control where Personal Data are stored in hardcopy.
12. DATA PROTECTION OFFICER
Zeta-Web has appointed an interim Data Protection Officer(s) (DPO) pending when all documentations are completed. He will be responsible for overseeing the Company’s data protection strategy and its implementation to ensure compliance with the NDPR requirements. The DPO is knowledgeable in data privacy and protection principles and is familiar with the provisions of the NDPR.
The contact details of the interim Data Protection officer are as follows:
Name: Kunle Oyetola
Address: 32 Providence Street, Lekki Phase 1. Lagos, Nigeria
Email: koyetola@zeta-web.com
Tel: 01-270 1222
The main tasks of the DPO include:
a) administering data protection policies and practices of Zeta-Web;
b) monitoring compliance with the NDPR and other data protection laws, data protection policies, awareness-raising, training, and audits;
c) advice the business, management, employees and third parties who carry on processing activities of their obligations under the NDPR;
d) acts as a contact point for Zeta-Web;
e) monitor and update the implementation of the data protection policies and practices of Zeta-Web and ensure compliance amongst all employees of Zeta-Web;
f) ensure that Zeta-Web undertakes a Data Impact Assessment and curb potential risk in Zeta-Web data processing operations; and
g) maintain a Data Base of all Zeta-Web data collection and processing operations of Zeta-Web.
13. REMEDIES
Where you have concerns relating to the processing of your personal information by Zeta-Web, or require any clarification on this policy, please notify us through or contact details provided below:
Email: info@zeta-web.com
Phone: 01- 270 1444
We will respond to your concerns within 5 working days of receiving your notice.
UPDATES TO THIS PRIVACY POLICY
We may update this policy from time to time. Where there are changes in the way we use your personal information we will notify you by posting a notice on our website.