(HAVILAH MERCHANTS NIGERIA LIMITED)

PRIVACY NOTICE

 

Havilah Group (HMNL) Data Privacy Notice

Havilah Group (HMNL) is committed to safeguarding the personal data of its Data Subjects. We respect your privacy and ensure that all personal data collected in the course of business or employment relationships is handled in accordance with applicable laws, regulations, and Havilah Group’s Privacy Policies. This notice outlines our practices regarding the management of your personal data and your rights as a Data Subject.

 

1. Collection and Use of Personal Data

We collect, process, and transfer personal data through computerized and appropriate systems for the following purposes:

• Ensuring compliance with data protection regulations
• Managing personal data of employees, customers, and third parties
• Meeting legal obligations and mitigating risks
• Satisfying statutory requirements set by the government
• Protecting our reputation and integrity
• Serving the vital interests of the government and Data Subjects
• Supporting other legal and customary business-related objectives

 

Where required by applicable law, we will obtain your explicit consent before processing your data. You may withdraw your consent at any time, subject to legal or contractual restrictions.

 

2. Processing of Sensitive Personal Data

We may process sensitive personal data (such as race, political opinions, sexual orientation, or health information) when it is necessary to achieve business objectives, to protect the vital interests of the Data Subject, or to comply with legal requirements. Sensitive personal data will only be collected, processed, or transferred where sufficient privacy protections are in place.

Sensitive personal data will only be processed under the following circumstances:

• To comply with legal obligations
• With explicit consent from the Data Subject
• Where necessary to protect the vital interests of the Data Subject or another individual (e.g., in medical emergencies)

 

3. Data Subject Rights

As a Data Subject, you have the following rights:

• Right to Access: You may request access to the personal data we hold about you.
• Right to Rectification: You have the right to request corrections to inaccurate or incomplete personal data.
• Right to Erasure: You may request the deletion of your data under certain circumstances.
• Right to Object: You have the right to object to the processing of your data in certain situations.
• Right to Data Portability: You can request that your data be transferred to another organization.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time.

 

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided at the end of this notice.

 

4. Disclosure of Personal Data

Your personal data may be disclosed to the following entities:

• • Government Ministries, Departments, Agencies, and Regulatory Bodies: For the purposes mentioned above.
  • Data Processors: Acting on our behalf, who use the data solely for our purposes.
  • Service Providers: Companies that provide benefits and services to us.
  • Legal Compliance: Where required by law.
  • Vital Interests: Where permitted by law, without obtaining consent, when vital interests or contractual obligations are at stake.
  • Emergencies: In the event of an emergency where the Data Subject’s life or safety is at risk.

 

All processing and transfers of personal data are subject to reasonable confidentiality and privacy safeguards. We take shared responsibility with the Data Subject for ensuring the accuracy of the personal data.

 

5. Data Retention Policy

Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws. After this period, the data will be securely deleted, anonymized, or destroyed.

6. Security Measures

We implement appropriate technical and organizational measures to protect personal data from unauthorized access, loss, or misuse. These measures include:

• • Encryption of sensitive data
  • Access control mechanisms to limit data access to authorized personnel
  • Regular security audits and monitoring of data processing activities
  • Data anonymization where necessary

These measures ensure that personal data is handled securely, reducing the risk of breaches and unauthorized disclosure.

 

7. Legal Compliance

This privacy notice is governed by applicable data protection regulations, including (but not limited to):

• • The Nigerian Data Protection Regulation (NDPR)
  • Other relevant local and international data protection laws

We ensure that personal data is processed in compliance with these regulations and that adequate safeguards are in place to protect the privacy and rights of Data Subjects.

 

8. International Transfer of Personal Data

As part of our business operations and the technologies we use, personal data may be transferred and accessed by our employees and third-party service providers in locations outside Nigeria. These locations may have different levels of data protection compared to the requirements set by the Nigeria Data Protection Regulation (NDPR).

We ensure appropriate safeguards to protect your data during such transfers. This includes the use of data transfer agreements and other lawful mechanisms, such as Standard Contractual Clauses, to ensure that your personal data is processed in accordance with this policy and applicable data protection laws.

Where necessary, country-specific data protection requirements will apply, as detailed in the relevant country supplements.

 

9. Data Collected by Third Parties at Our Events

In certain situations, third parties attending our events may collect personal information about you. For example, they may take a photograph of your business card or scan your visitor badge using event mobile apps. We are not the data controllers of such information, do not have access to this data, and are not responsible for how third parties use it. For further details, please refer to the relevant third-party privacy policies or terms of use for the respective app.

 

10. Aggregated or Anonymized Personal Information

We may create anonymized or aggregated data from the personal information we collect about you and other individuals. This data could include statistical information or analytics, which we may share with third-party partners. Such data will not identify you personally and will be used for purposes like improving our services or conducting business analysis.

In some cases, your employer or another organization may provide you access to our services. In those instances, your employer will only receive aggregated information, not your personal data. For example, we may share statistics, such as the percentage of employees who have completed a certification course, but we will not disclose individual engagement details. However, in rare cases where there is a breach of our Terms of Service or community standards (e.g., severe harassment or fraud), we reserve the right to notify your employer of actions taken, such as banning you from our services.

 

11. Children’s Personal Information

Our services and products are intended for business professionals and are not designed for individuals under the age of sixteen. We do not knowingly collect personal data from children under this age. If we become aware of any such collection, we will delete the data. In cases where children’s data is collected, it will only be through direct input by parents, guardians, or teachers, and its use will be governed by clear terms in accordance with applicable laws.

 

12. Third-Party Links

This website may contain links to external websites operated by third parties. Please note that these websites are governed by their own privacy practices, which may differ from ours. Havilah Group (HMNL) is not responsible for the privacy policies or content of third-party websites and accepts no liability for how your personal information is handled by them.

We strongly encourage you to review the privacy policy of each third-party website you visit through links on our platform to understand how your personal data will be processed and used.

 

 

 

 

 

 

 

Havilah Group (HMNL) Cookie Policy

At Havilah Group (HMNL), we are committed to protecting your personal data and ensuring compliance with the Nigeria Data Protection Regulation (NDPR). This Cookie Policy explains how we use cookies and other tracking technologies on our website, the type of information we collect, and how you can manage your preferences.

 

1. What Are Cookies?

Cookies are small text files that are stored on your device (computer, tablet, or mobile) when you visit websites. Cookies help websites function more efficiently, improve user experience, and provide relevant information to website owners. Some cookies are essential for the website to function, while others collect data to enhance your experience or for analytical purposes.

 

2. Types of Cookies We Use

We use the following types of cookies on our website:

• Essential Cookies: These are necessary for the website to function properly. Without these cookies, certain services or features of the website may not be available.
• Performance Cookies: These cookies help us understand how visitors interact with our website by collecting anonymous data on website traffic, visitor behavior, and any errors encountered. This helps us improve the website’s performance.
• Functional Cookies: These cookies allow the website to remember your choices, such as your username, language preferences, and region. This helps us offer a more personalized browsing experience.
• Analytics and Advertising Cookies: These cookies track your browsing habits and allow us to provide you with personalized content and advertisements based on your interests. We may also share this information with third-party service providers for analytics purposes, in line with NDPR requirements.

 

3. How We Use Cookies

We use cookies to:

• Ensure that our website functions properly and securely.
• Monitor and analyze website performance and traffic.
• Personalize your experience by remembering your preferences and past interactions.
• Deliver targeted advertisements and content based on your browsing behavior.
• Improve our services by understanding how visitors interact with our website.

 

4. Third-Party Cookies

We may allow third-party service providers to set cookies on your device to help us analyze website traffic or for advertising purposes. These third parties are responsible for their own cookie policies, and we encourage you to review their privacy and cookie policies to understand how they use your data. We ensure that all third parties comply with NDPR and other applicable data protection regulations.

 

5. Managing Cookies

You can manage or disable cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of our website and limit your ability to use some features. Below are links to help you manage cookies on popular browsers:

• Google Chrome
• Mozilla Firefox
• Microsoft Edge
• Apple Safari

 

6. Your Rights Under NDPR

Under the NDPR, you have the following rights regarding your personal data:

• Right to Access: You may request access to any personal data collected through the use of cookies.
• Right to Object: You have the right to object to the processing of your personal data for certain purposes, such as analytics or advertising.
• Right to Erasure: You may request the deletion of your personal data collected through cookies, where applicable.

To exercise any of these rights, please contact us at:

 

Data Protection Officer
Havilah Group
The Villa, 2 Akin-Taylor Estate, Off Allen Avenue, Ikeja, Lagos, Nigeria
Phone: +234 908 169 1714
Email: info@havilahgroup.ng

 

7. Updates to This Policy

We may update this Cookie Policy periodically to reflect changes in our use of cookies, legal requirements, or for other operational reasons. Please check this page regularly for any updates. The date of the last revision will be indicated at the top of this policy.

 

 

 

For Further Inquiries

If you have any questions or concerns regarding this notice or the handling of your personal data, please contact:

 

Data Protection Officer:
Havilah Group
The Villa, 2 Akin-Taylor Estate, Off Allen Avenue, Ikeja, Lagos, Nigeria
Phone: +234 908 169 1714