IVYARC PRIVACY POLICY

Last updated on 23^rd June 2021

Introduction

Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how IVYARC (“us”, “we” or “our”) collects, uses and processes your personal data in accordance with the Nigerian Data Protection Act.

For the purpose of the Nigeria Data Protection Act (NDPR), IVYARC, whose address is at 8B Adenubi Close, Allen Avenue, Ikeja, Lagos, Nigeria, is the Data Controller that determines the purposes and means of processing of your personal data collected through websites owned and/or operated by us or on our behalf (including our website - https://www.ivyarc.com) (our website”) or other channels described in paragraph 2 of this document.

This Privacy Policy is designed to help you understand how your provided data is collected, utilised, disclosed, and/or processed, as well as helping you make a more informed decisions when providing your data to us.

Information We Collect

There are two broad categories of information that we may collect from you:

Personal Data

“Personal data” is any information that can be used to identify you.
We may collect certain types of personal data, including, but not limited to, your first and last names, gender, date of birth, identification numbers, company (if applicable), contact information (e.g. phone number, email address), payment information (e.g. credit or debit card information), country of residence, occupation, qualification, year of working experience, interest, e-mail address, photographs and video footages taken at events organized by us and/or our business partners and any other information which you may provide in any forms submitted to us or via other forms of interaction with us.
Personal data is collected by us in various circumstances, including the following:
1. When you register for or use any of our services on our website (e.g. subscription to our magazine(s) or e-newsletter or other);
2. When you take part in any contest, survey or promotion conducted by us and/or our business partners;
3. When you participate in events, exhibitions or roadshows organized by us and/or our business partners;
4. When we receive references from business partners and third parties, for example, where you have been referred by them;
5. When you submit an application to us for employment or an internship; and
6. When you submit your personal data to us for any other reason.
It is voluntary for you to supply your personal data to us, although you may not be able to use our services or acquire our goods if you do not supply your personal data. We may not process your order for goods and/or services, and no contract for the provision of such goods and/or services will be formed if you do not supply the personal data required on our relevant order/subscription forms.
We may also obtain personal data about you from other sources and combine it with the information you provide to us. If you provide us with any personal data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorized representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their personal data for the respective purposes.

Non-Personal Data

We may also collect certain non-personal data when you visit and use our website. Such data is entirely anonymous and is aggregated for statistical analysis (“Aggregate Information”) using Google Analytics.

When you visit and use our website, we may also collect information about you using Cookies, which are small data files sent to your browser or device to store information about you when you visit our website. They perform various website support roles, such as letting you navigate between pages efficiently, identify your behaviour, remembering your preferences and generally improving your user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.

Most likely, your browser is set by default to accept website cookies but you can manually change this through its personal settings, with the risk of the functionality of our website, our third-party sites, or other non-affiliated websites ceasing to function as normal.

Some cookies will not collect information that personally identifies you. They will collect more general information such as how users arrive at and use our website or a user’s general location.
When you visit our website(s), you may also see a pop-up seeking your consent to the placing and use of cookies on your device. You may either give such consent or reject the placing and use of cookies. You can also remove existing cookies from your device using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this.

To learn more about Cookies and how to manage them, please visit https://www.allaboutcookies.org/cookies/.

Legal Reasons for Data Collection/Processing

Under the Nigeria Data Protection Act, your personal data may be collected, used, disclosed and/or processed for one or more of the following purposes:

The delivery of our products and services to you, and the future optimizations of the delivery process,
To manage your subscriptions to our magazines, newsletters, job offerings, publications, and other related offerings,
To send you marketing materials related to any of our products/services,
To send you information updates on any of our administrative changes, updates and/or amendments to any of our Privacy Policies or Terms and Conditions documents
To respond to or follow up on your queries, requests and/or complaints
To protect and enforce our contractual and legal rights and obligations
To comply with any applicable laws and regulations or to assist in law enforcement and/or investigations by any governmental authority, public agency, statutory board or similar authority

Sharing of Personal Data

To optimize the delivery of our products and services, your data might be shared with third-party bodies, including, but not limited to, the following:

Agents, contractors or third-party service providers (“Service Providers”) who provide operational services to us, such as, but not limited to, information technology, training, market research, administration of our website, distribution of magazines or other communications to you about our products, services or events, as well as storage and archival services, and others;
Our subsidiaries and holding companies, and the subsidiaries of our holding companies (collectively, our “Associated Companies”);
The credit bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
Anyone to whom we transfer or may transfer our rights and duties;
Banks, credit card companies and their respective service providers;
Our professional advisors such as our auditors and lawyers;
Relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
Any other party to whom you authorize us to disclose your personal data

Marketing

We intend to use your personal data for direct marketing purpose, but only in accordance with relevant laws and regulations. Our direct marketing may be conducted via various communication channels, such as your email address, phone number and SMS. In this connection, please note that:

(a) Your Personally identifiable information provided by you, such as your name, email address, phone number, and date of birth may be used to identify you and facilitate direct marketing targeted towards you.

You may indicate your consent to the intended use and provision of your personal data for direct marketing purposes above by ticking the box(es) indicating your consent when providing us with your personal data through our website or any associated third-party websites or through order forms or subscription forms.

Your Rights

You may request to access or correct your information.

Also, you have the right to:

Access and rectify your personal data,
Request us to erase your personal data without undue delay;
Restrict how we process your personal data;
Where our processing of your personal data is based on consent, withdraw your consent at any time;
Object to our processing of your personal data based on legitimate interests, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims;
Object to direct marketing (including any profiling for such purposes) at any time;
Receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and transmit such data to another data controller without hindrance from us; and
Lodge a complaint with a supervisory authority.

You may do so by submitting your request to us via email or letter. Please refer to our contact details in the Contact Us section of this Privacy Policy

Retention of Your Personal Data

We will retain your personal data collected for as long as it is necessary to fulfil the purpose for which it is collected, the legal and/or business purposes of Jumpstart, and/or as may be required by applicable law.
When destroying personal data, we will take commercially reasonable and technically feasible measures to make the data irrecoverable or irreproducible, as may be required by applicable law.

Data Security

We take the security and protection of your personal data very seriously. As such, we store your personal data on secure servers and have put in place appropriate security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal of your personal data.
However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are attributable to factors beyond our control and supervision.

Opting Out

If you do not wish to receive any further information from us regarding our magazines, offers, promotions or events via email or any other marketing channel that we have contact you through, you may unsubscribe by clicking the unsubscribe link included in our email correspondence or by directly contacting us via our contact details provided in the Contact Us section of this Privacy Policy document.
Please note that if you withdraw your consent for a limited purpose, we may still contact you or use your information for other purposes for which you have not withdrawn your consent and such personal data may still be shared, as permitted under the NDPR, and other applicable law.

Automated Decision Making and Profiling

In connection with our business, we will use your personal data to make various decisions about you and your eligibility to access our services, to prevent abusive use of our services, to determine what marketing offers are most likely to be of interest, to ensure the security of our systems, to detect fraud or to profile you or assign you to a particular segment. Some of these decisions may be taken on an automated basis including by matching your personal data against other information in our possession or against data models created for us. If you are assigned to a segment, we may use the segment information to tailor our marketing communications (if permitted under applicable laws) to include offers and content that are more relevant to you. You will not be subject to automated decisions that produce legal effects concerning you or similarly significantly affect you, unless we have a lawful basis for doing so.

Third-Party Sites

Our websites may contain links to other websites operated by third parties such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. You are encouraged to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions, and policies of the third-party website to determine how they will handle any information that they collect from you.

Children’s Data

We permit a child under the age of 18 to use our website and to provide his/her personal data to us provided that the child has obtained his/her parent’s or legal guardian’s consent. If you are a child under the age of 18, you warrant and represent that your parent/legal guardian has consented to your use of our website and your provision of personal data.

Once the child reaches 18 years of age, they may review this privacy policy and make the decision of either allowing the continued processing of their personal data, or request the termination of their personal data, facilitated by the means stated in the Opting Out section of this Privacy Policy document.

Please, do not hesitate to contact IVYARC via our info@ivyarc.com email address if you have any enquiries, complaints, requests, or any other information that can improve, modify, or terminate your interactions with us of any kind.

Changes to this Privacy Policy Document

As part of our efforts to ensure that we properly manage, protect, and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. We will notify you of changes to this Privacy Policy by posting the amended policy with the date it was revised on our website.
You are encouraged to visit the websites from time to time to ensure that you are well informed of our latest policy in relation to personal data protection.