Presence Secure (“PS”, “we”, “us”, or “our”) privacy notice (“Privacy Notice”) communicates how the we collects, shares, retains, uses and your rights regarding the (“Data Subject”) personal data we process and how you can get in touch with us. Please note that if you disagree with anything in this Privacy Notice, you must not use the website www.presencesecure.com (the “Site”), or provide personal information to us in connection with Presence Secure’s services.

TABLE OF CONTENTS

1. Contact of Data Controller
2. Collection of Personal Information
3. Condition for Processing Personal Data
4. How we use your Personal Information
5. User Rights
6. Data Collection Methods
7. Transfer of Personal Data
8. Securing your Personal Data
9. Modifications to this Privacy Notice
10. Questions, Concerns or Complaints

1. CONTACT OF DATA CONTROLLER

Presence Secure Data Protection Officer’s Contact:

Email: [email protected]

2. COLLECTION OF PERSONAL INFORMATION
   Personal information refers to data that could identify a specific individual such as names, e-mail addresses, and telephone numbers. Depending on your medium of interaction with Presence Secure (online, offline, mobile phone, social media etc.), we collect various types of information from you, as described below.

• Contact information- This includes any information you provide to PS that would allow us to contact you personally, such as your name, residential address, e-mail address, phone number information or type of business.
• Payment and Financial information:  Any information that we need in order to make payments to you, including bank details such as bank name, account name and number, etc.
• Demographic information & interests- Any information that describes your demographic or behavioral characteristics. Examples include your date of birth, age or age range, gender, geographic location (e.g. postcode/zip code), hobbies and interests, and or lifestyle information. We use such information for improving the quality of our service offerings.
• Sensitive Personal Data. We do not seek to collect or otherwise process sensitive personal data in the ordinary course of our business. Sensitive information includes a number of types of data relating to: race, ethnicity, political opinions, religious or other similar beliefs, trade union membership, physical or mental health or criminal record. Where it becomes necessary to process your sensitive personal data for any reason, we rely on your prior express consent for any processing which is voluntary. We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from other companies, search information providers or public sources (e.g. for due diligence purposes), but in each case as permitted by applicable laws.
• Information You Share on Third-Party Websites or through Social Media Services.  The Site may include links to third-party websites and social media services where you will be able to post comments, stories, reviews or other information outside of PS’s control. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We are not responsible for the security or privacy of any information collected by other websites or other services. Information collected by third parties is governed by their privacy practices. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.
• Information Collected by Third-Party Analytics Services.  We may work with third-party analytics services to help us understand how the Site are being used, such as tracking the frequency and duration of use of the Site. We may use Adobe Analytics and Google Analytics, and web analytics services provided by Adobe and Google (“Analytics Tools”) to collect information about your use of the Site. These Analytics Tools may use cookies to collect information about the content you view, what websites you visit immediately prior to and after visiting the Site, and your system information and geographic information. The information generated by these cookies about your use of the Sites will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyze your use of the Site. The Analytics Tools may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Site. By using the Site, you consent to the processing of data about you by Adobe and Google in the manner and for the purposes set out above. You can opt-out of Google Analytics by installing Google’s opt-out browser add-on, and out of interest-based Google ads using Google’s Ads Settings.

3. CONDITION FOR PROCESSING PERSONAL DATA

• PS Personnel or any third party acting on its behalf shall only process your personal data if at least one of these conditions are met.
• Consent: this refers to any freely given, specific, informed and unambiguous indication through a statement or a clear affirmative action that signifies your agreement to the processing of your Personal Data by Presence Secure.
• Contract: processing is necessary for the performance of a contract or entering into a contract at the request of the Data Subject only.
• Legal obligation: processing is necessary for compliance with a legal obligation to which Presence Secure is subject;
• Vital interest: processing is necessary in order to protect the vital interests of the Individual or of another natural person;
• Public interest: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official duties of PS.
• Proper Motives: Presence Secure shall not seek consent that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.

4. HOW WE USE YOUR PERSONAL INFORMATION

To the extent permissible under applicable law, we may use your information for the following legitimate actions:

• Provide any information and services that you have requested;
• Compare information for accuracy and to verify it with third parties
• Manage our relationships with you
• Recruitment processing and human capital management
• Processing of employee benefit plan
• To monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
• If you are an event attendee, speaker, or partner, certain items of your information may be included in the event roster, which will be publicly disclosed, and may also be shared with third-party event sponsors and exhibitors.
• Furthermore, by your partnership with PS, you agree, with no compensation to you, that PS or any third party who is acting on our behalf may create images, videos and/or sound recordings of the services we offer you, provided they pose no cybersecurity risk to you, for marketing purposes

5. USER RIGHTS

As a Data Subject, you have rights when it comes to our handling of your Personal Data. Those rights include:

• The right to request for access to your Personal Data where those requests are reasonable and permitted by law or regulation. Presence Secure shall provide reasonable and accessible means for Individuals to submit their requests, which do not have to take any specific form and can be submitted by any method.
• The right to request that PS erase your Personal Data if it is no longer valid or necessary for the purposes for which it was collected or if it is incomplete or inaccurate.
• The right to rectify or amend inaccurate or incomplete Personal Data.
• The right to withdraw your Consent at any time. This can be initiated by contacting the Data Protection Office of Presence Secure.
• The right to object to PS’s processing of their Personal Data if there are compelling legitimate grounds to do so and to the extent permitted by law or regulation. Individuals have the right to object to PS’s processing of their Personal Data for direct marketing purposes.
• The right to receive your Personal Data in a commonly used and machine-readable format and the right to transmit these data to another Data Controller when the processing is based on (explicit) consent or when the processing is necessary for the performance of a contract.
• This Privacy Notice agrees with Nigeria Data Protection Regulation 2019 (NDPR) and other relevant international information security standards such as ISO 27001:2013.

6. DATA COLLECTION METHODS

• Digital Messages: We keep record of your interactions with us via electronic media (such as email, text message, web forms etc.) in a secure manner while maintaining accuracy. When necessitated by legal or vital obligations, we archive these communications.
• Hard Copy Forms: We maintain accurate records of the information that you provide to us via hard copy forms in a secure manner. When necessitated by legal or vital obligations, we archive these communications.

7. TRANSFER OF PERSONAL DATA

Personal data collected by Presence Secure may be transferred among its various divisions and affiliated companies, around the world, as well as transferred to select partners with your consent. The following describes the various scenarios for which we may share your Personal Data to a third party.

• Transfer for Service Provision: We employ other companies and individuals to perform functions on our behalf as service providers. Service providers, and their selected staff, are only allowed to access and use your Personal Data on Our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.
• Transfer as a legal requirement: We may share your information with other parties when required by law or as necessary to protect our service.  We may also share your information in connection with a transfer of assets, or if we are otherwise involved in a merger or transfer.
• Inter-Company transfers: Your Personal Data may be transferred to or accessible by other entities within the Presence Secure. However, these entities will be bound by the terms of this Policy.
• Out of Country Transfer: Your Personal Data may be transferred to a foreign country for storage or processing where it is necessary to do so in line with the permissible conditions defined by the NDPR. We will ensure that appropriate defenses are in place to ensure the protection of your Personal Data being stored or processed out of the country.

8. SECURING YOUR PERSONAL DATA

We use appropriate measures including physical, technical and operating environments to keep your Personal Data you provided through the Site or in connection with PS services in a confidential and secure manner. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Presence Secure cannot guarantee or warrant the security of any information you transmit and was intercepted by a man-in-the-middle or other forms of web attacks and you do so at your own risk.

Data Retention Policy: Presence Secure retains data for the duration of the customer’s or partner’s business relationship with PS and otherwise as required under applicable law. Personal data will be kept for no longer than is necessary for the purposes for which your personal data are processed. Unless we are required to retain this personal data by law or to comply with our regulatory obligations. In such a case, we will only keep this personal data for as long as necessary.

Personal Data Breach Notification: PS will inform relevant authorities and if necessary, affected individuals of personal data breach within 72 hours of being aware of the breach where Personal Breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes

9. MODIFICATIONS TO THIS PRIVACY NOTICE

From time to time, Presence Secure may need to update or modify this Privacy Notice, to reflect changes in our business practices or data collection practices. We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on the Site. It is strongly recommended that you check back frequently to see any updates or changes to our Notice.

10. QUESTIONS, CONCERNS OR COMPLAINTS

Any questions or concerns about this Privacy Notice can be addressed to the Data Protection Officer at: [email protected]