OUR DATA PRIVACY POLICY NOTICE
- Welcome to our website. We are Araba Technologies Ltd the owner of the ARABATECH, ARABAHOST, ARABCERT, and ARABADOMAIN services brands. Araba Technologies Ltd is an incorporated limited liability company that collects and processes data in furtherance of business interest, and the legitimate interest of our individual clients and visitors to our website i.e., data subjects in line with the provisions and guidelines of the Nigeria Data Protection Regulation (NDPR2019).
- We collect and process various categories of your data based on the type of engagement we have with you.
- We use Cookies which are small files stored on a user’s computer. Cookies are used to hold a modest amount of data specific to you and our website and can be accessed either by the web server or by your computer. They are also embedded applications or codes on our website that may be used to process your pattern of interaction with our website and thereby create automated responses and notifications that seem most likely to suit your interest.
- We encourage you to Click and Read Carefully our DATA PRIVACY POLICY, please note that this notice applies to all Araba Technologies Ltd services hosted online including service brands; ARABATECH, ARABAHOST, ARABADOMAINS, ARABACERT, and other future services that will be hosted online including our online meetings and interactions with our clients and visitors to our sites.
- We consider and accept your continued interaction and engagement with our website as your CONSENT to the collection and processing of your personal data in line with our legitimate business interest subject to the provisions and requirements of NDPR 2019.
OUR DATA PRIVACY POLICY
- OUR GUIDING PRINCIPLES ON DATA PROCESSING
In processing your personal data, we adhere strictly to the principles of data processing as set out in Article 2.1 of the NDPR. Thus, we shall ensure that Personal Data shall only be:
a) Collected and processed in accordance with specific, legitimate and lawful purpose consented to by the Data Subject.
b) Adequate, accurate, and without prejudice to the dignity of the human person.
c) Stored only for the period within which it is reasonably needed; and
d) Secured against all foreseeable hazards and breaches such as theft, cyber attack, viral attack, dissemination, manipulations of any kind, damage by rain, fire, or exposure to other natural elements.
2.0 CONSENT OF DATA SUBJECT
Except as otherwise required by the operation of law or principles of law, your consent as the Data Subject is the entry point for our data collection and processing. You have the right to give, withhold or otherwise withdraw your consent to data processing. For further understanding of the operation of the principle of consent under data-processing see Articles 2.1(a), 2.2, 2.3, and 2.4 of the NDPR. Those who seek information on our website or other platforms shall be deemed to have given constructive consent to receiving information of a specific or of general nature through us from time to time.
3.0 OUR SCOPE OF DATA PROCESSING
In varying degrees vis-à-vis the service, we provide for you or your level of engagement with us, we do process your personal data. Below is a table containing the major types of personal data, the purpose and the lawful basis for processing them:
| S/N | PURPOSE OF COLLECTION | TYPE OF DATA | LAWFUL BASIS |
| 1 | REGISTRATION | Name, Phone, Email Address, Contact Address, National Identity Number, International passport number, location, Sex, Date of Birth, passport and educational record. | To provide public service to data subjects as requested by the Central Bank of Nigeria and legitimate partners |
| 2 | NOTIFICATIONS | Name, Phone, Email Address, Contact Address, Sex, and Date of Birth. | To provide public service to data subjects as requested by the Central Bank of Nigeria and legitimate partners |
| 3 | DATA ANALYTICS | Name, Phone, Email Address, Contact Address, Sex, and Date of Birth. | To ensure that our services suit the purpose of data subjects and to measure our performance |
| 4 | SECURITY | Name, Phone, Email Address, Contact Address, Sex, Date of Birth and passport. | For the safety and security of lives and property. |
| 5 | PARTNERSHIP /EMPLOYMENT | Name, Phone, Email Address, Contact Address, location, Sex, Date of Birth, passport, medical record, and educational record. | For due diligence |
| 6 | CONTRACT | Name, Phone, Email Address, Contact Address, Sex, | For due diligence |
Please note that the categories of data and the lawful basis provided are not exhaustive. We are governed by the NDPR as to the requirement for consent in all circumstances.
4.0 RIGHTS OF DATA SUBJECTS
We hold your privacy rights very dear to our operations. Apart from the right to give, withhold or withdraw consent, you have the right to all relevant information that may guide you in making informed decisions about your personal data. For example, you have the right to be notified of anyone or any place to which we may transfer your personal data. Your rights under the NDPR include but are not limited to the following:
a) right to data portability,
b) right to erasure,
c) right to limit processing and
d) right to obtain your data.
See Part 3 of the NDPR for details of the rights of data subjects.
5.0 WITHHOLDING RELEVANT DATA
There are types of personal data that are mandatory for us to process in order to carry out your instruction or perform our legal mandate for your benefit. If you withhold such information, it may be impracticable to carry out our mandate in relation to you. If you seek more clarification on our data processing contact our designated Data Protection Officer as provided in section 12 below.
6.0. TRANSFER OF DATA TO A THIRD PARTY
As a public establishment, third parties may wish to provide opportunities on our platform for mutual benefits or in the public interest. The type of data usually processed for this may be your digital contacts such as E-Mail, telephone number, or address, You have the right to decline such third-party offers and further restrict the processing of your personal data. You can simply unsubscribe to the notices sent for the purpose of the offers.
7.0 TECHNICAL INFORMATION
Customarily, websites are designed to collect certain information from the visitor. Our website is also designed to collect your IP address and other information that your web browser typically shares with the websites that you visit. The purpose of this is to know you better and to engage with you automatically and dynamically through your actions on our website.
8.0 PERSONAL DATA SECURITY AND INTEGRITY
We use cutting-edge technologies and foolproof protocols to provide you with comprehensive layers of security in the area of personal data. Thus, we are constantly vigilant in preventing cyber-attacks, fraudulent intrusion, unauthorized access, and loss or corruption of personal data using our best effort. We are equally cognizant of the obligations imposed on us by law in terms of data protection. Accordingly, we conduct reviews of process and privacy impact assessment, carry out training and obtain strict warranties where applicable.
9.0 PURPOSE AND STORAGE LIMITATION
The purpose of data processing usually determines the length of time within which your personal data is stored with us and the residue of data actually stored for this purpose. We collect and store personal data that is reasonably required by law or best practice to serve you or respond to legitimate enquiries about our transaction with you. We take this responsibility very seriously in the knowledge of the need for you to enjoy your privacy as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria and international human rights law.
10.0 WEBSITE LINKS:
Our website may contain links to other websites. Save and except as otherwise expressly stated by us, any link to another website is not covered by our privacy policy. We strongly advise that you should satisfy yourself with the details of any privacy policy provided on other websites or links.
11.0 TRANSFER TO THIRD PARTIES AND COUNTRIES
In carrying out our mandate effectively, we may require the services of third parties who may be within or outside the NDPR jurisdiction (Nigeria). Examples of such services include but are not limited to the following:
a) Internet connectivity,
b) cloud hosting and storage,
c) data analytics,
d) data security,
e) software development,
f) CBN E-Naira speed wallet onboarding and
f) Legitimate Public interest.
In transferring your data to third parties, we shall be guided by extant public policy and the NDPR as regards the adequacy level of the foreign jurisdictions. See PART 2 Article 2.11 and PART 3 under the NDPR for details of your right under this section.
12.0 USE OF SPECIAL DATA PROCESSING CODES (COOKIES)
“Cookies”, in computer parlance, are text files that are downloaded to your browsing devices such as phones or computers when you browse pages of websites. They contain small amounts of data, and their essential function is to intelligently memorize your preferences and therefore present them to you as choices when you are browsing – even at different times. Note that various websites use cookies for different purposes some of which may undermine your privacy rights. We have taken measures to ensure that all methods adopted by us to engage automatically with you do not violate your privacy rights under the NDPR. In the case of cookies, we ensure that they have security protocols and are not vulnerable to abuse by anyone.
13.0 ARABA DATA PRIVACY UNIT (ADPU).
We have provided a desk to respond promptly and satisfactorily to all your requests, suggestions, and complaints. This is called the ADPU. We have a Data Protection Officer responsible for prompt action on your data privacy. Contact the ADPU via this link: dpo@arabahost.com
Our DPSU serves as the internal mechanism to carry out the following services amongst others:
- Data protection regulations compliance and breach services
- Data protection and privacy advisory services
- Data protection capacity building
- Data Regulations Contracts drafting and advisory
- Data protection and privacy breach remediation planning and support services
- Information privacy audit
- Data privacy breach impact assessment
- Data Protection and Privacy Due Diligence Investigation
- Data Protection Officer
14.0 REMEDIATION
Our data subjects are encouraged to report any complaint or concern about their data privacy through the ADPU. Our team at the ADPU shall take action to redress any grievance within 24 hours.
15.0 ALTERATION OF PRIVACY POLICY
Araba Technologies Limited reserves the right to alter the foregoing policy for the purpose of advancing data privacy rights, and public interest or complying with lawful directives of the Federal Government with or without notice.