Last update: Nov 01, 2022
1. INTRODUCTION AND ACCEPTANCE
Fatherland Badagry Real Estate PLC and its subsidiaries (hereinafter called “Fatherland Badagry”/ “We”/ “Our”) treats personal information of users (“Users”/ “You”/ “Your”) of the FATHERLAND BADAGRY Website https://fatherlandbadagry.com/ and its other digital platforms (hereinafter called the “Site”) as private and confidential.
This Policy applies to usage of the Site as well as information contained on the Site, particularly, information related to products and services offered by Fatherland Badagry.
Fatherland Badagry is committed to ensuring that Your privacy is protected. Should We ask You to provide certain information by which You can be identified when using this Website, then You can be assured that it will only be used in accordance with this Policy.
What we collect
We may collect the following Personal Data:
- Personal identification information – We collect and use information about You to administer Our business. Information collected shall include
- Your contact information such as Name, contact address, email addresses, gender, and telephone numbers and details of next of kin;
- Demographic information;
- Occupation, Career history, professional background and other CV related information;
- International and National passport, driving license or any other form of proof of identification;
- Transactional data, including financial details, your photograph; and
- And any other information We may deem necessary and which may be determined by extant Nigerian laws and regulations as well as the EU and the U.S.
- Non-personal identification information – This is information received whenever You interact with Our Site. Non-personal identification information may include:
- Unique IDs such as your mobile device identifier or cookie ID on your browser;
- IP address and information that maybe derived from IP address, such as geographic location; and
- Information about a device you use, such as browser, device type, operating system and the internet service providers utilized.
Why we collect your Personal Data
- You have given consent to the processing;
- Processing is necessary for the performance of a contract to which you are a party or take steps to enter into a contract;
- Processing is necessary for compliance with a legal and regulatory obligations to which we are subject;
- Processing is necessary in order to protect your vital interests or another natural person; and
- Processing is necessary for the performance of a task carried out in the public interest.
What we do with the information we gather?
We require this information to understand your needs, and provide you with better service, particularly with regard to the following:
- Internal record keeping;
- To respond to your enquiries about Fatherland Badagry;
- To improve our products and services;
- To improve customer service delivery;
- To send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided;
- To contact you occasionally for market research purposes. We may contact you by email, phone, fax or mail;
- To deliver technical and functional management on our site;
- To provide specific services in accordance with an agreement you are entering, or have entered into with us;
- To manage the security of our sites, networks and systems;
- To comply with applicable laws and regulations and to operate our business;
- To run a promotion, contest, survey or other site feature; and
- To improve our Site through feedback you provide on our products and services.
Fatherland Badagry will not share with other parties, information which you may provide when using the Site, except to the extent necessary to provide services to you, further, to obtaining your consent.
With your express consent, we will share your personal data among subsidiaries within Fatherland Badagry, only to the extent of your permission, and which is necessary to provide services to you. In this case, your right to withdraw consent shall be exercisable at all times.
We may wish to share with you, information about our products and services which we think you may be interested including those of our subsidiaries. If you have agreed to receive marketing materials, you can always opt out at a later date. You reserve the right at any time and at no cost to you, to stop us from contacting you for marketing purposes or giving your data to our subsidiaries
How we collect Personal Data
We collect information about you and any other party whose details you provide to us when you:
- Provide feedback on our products and services to improve our Site;
- Complete online forms;
- Take part in surveys;
- Interact with us using our social media platforms;
- Download information such as publications or participate in any other interactive areas that appear on our website or portals;
- Contact us offline, for example by telephone, SMS, email, post or any other means of communication;
- Access and use any of our websites or portals from your devices (including mobile devices) and applications; and
- Share Personal Data with third parties that are entitled to share that data, but in each case as permitted by applicable laws.
Where We Store Your Personal Data
The Personal Data that we collect from you will be transferred to and stored at destinations within Nigeria, USA and E.U. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy.
Cookies are a kind of short-term memory for the web. They are stored in your browser and enable a site to ‘remember’ little bits of information between pages or visits. Cookies can be used by web servers to identify and track users as they navigate different pages on a website, and to identify users returning to a website. Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Our Website cookies
We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on Your device until you delete them). We need the cookies to enable technical performance of Our websites and allow us to ‘remember’ the choices you make and your preferences (Functionality) and to allow us collect certain information about how You navigate the Sites (Performance/Analytical).
By this, we are able to understand which parts of Our websites are interesting to You and which are not, as well as what We can do to improve them.
Cookies do not contain any information that personally identifies You, but Personal Data that We store about You may be linked, by us, to the information stored in and obtained from cookies. The cookies used on Our website include those which are strictly necessary for access and navigation, cookies that track usage (performance cookies) and those used to remember your choices (functionality cookies). We may use the Personal Data We obtain from Your use of our cookies for the following purposes:
- To provide you with a better website experience by enabling us to monitor which pages You find useful and which you do not;
- To recognise Your computer and track you when You visit Our website;
- To retain investors’ email addresses and passwords when they log in to Our investment centre; and
- To analyse the use of Our website – such as how many people visit us each day.
Accepting, Declining and Disabling Cookies
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but You can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. You can also disable cookies if You wish. However, this will affect the functionality of Our website and many other websites that You visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
Links to other websites
This website uses Google Analytics, which is a web analytics service provided by Google. Google Analytics enables us to recognise repeat visitors to the site and to analyse how users use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Please note that Fatherland Badagry has switched on the IP Anonymisation feature in Google Analytics.
We may use advertising cookies to help us deliver more relevant, targeted online advertising. This means that based on the pages you visit on our site, you may see our advertisements on selected other websites. The information collected is anonymous and does not contain any personal information
Controlling your Personal Data
You may choose to restrict the collection or use of your Personal Data in the following ways:
- If You have previously agreed to us using Your Personal Data for direct marketing purposes, You may change Your mind at any time by emailing us at [email protected]
We will not sell, distribute or lease Your Personal Data to third parties unless we have Your permission or are required by law to do so. We may use Your Personal Data to send You promotional information about third parties which We think You may find interesting subject to your written permission to do so.
How we protect your Personal Data
We are committed to ensuring that Your Personal Data information is secure. In order to prevent unauthorised access or disclosure, We have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the Personal Data We collect online.
In particular, We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your personal transaction information and data stored on our Site.
Sensitive and private data exchange between the Site and its Users happens over a secured communication channel and is encrypted and protected. Transactions are also handled over a secure payment gateway. Also, Fatherland Badagry has implemented appropriate technical, physical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorised disclosure or access, as well as all other forms of unlawful processing.
Retention of your Personal Data
We maintain Personal Data not longer than we need to use it in accordance with Fatherland Badagry’s Data Retention Policy. In some circumstances, we may retain your Personal Data for longer periods if it is in accordance with regulatory, legal, tax or accounting obligations. Fatherland Badagry has an established retention procedure it applies to records and Personal Data collected and stored. In all cases, where your Personal Data is no longer required or you request for deletion, we will ensure it is disposed of in a secure manner.
Sharing your Personal Data
We do not sell, trade, or rent Users Personal Data to others. We may share generic aggregated demographic information not linked to any Personal Data regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We will not disclose Your Personal Data to anyone outside Fatherland Badagry without Your consent to do so unless one of the following circumstances applies:
- With your consent
We will share Personal Data with companies, organizations or individuals outside of Fatherland Badagry when We have your consent to do so. We shall obtain your consent before sharing of any sensitive Personal Data.
- Processing of Personal Data of minors
Where we collect the Personal Data of a minor, we shall obtain the consent of a parent or guardian and we shall ensure that the purpose of processing or collecting the Personal Data is clear to both the minor and the parent or guardian.
- For external processing
- For legal reasons
We will share Personal Data with companies, organizations or individuals outside of Fatherland Badagry if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, such as the Nigeria Data Protection Regulation (NDPR), legal process or enforceable governmental request.
- detect, prevent, or otherwise address fraud, security or technical issues.
protect against harm to the rights, property or safety of Fatherland Badagry, our Users or the public as required or permitted by law.
Your acceptance of these terms
By using this Site, You signify Your acceptance of this policy. If You do not agree to this policy, please do not use Our Site. Your continued use of the Site following the posting of changes to this policy will be deemed Your acceptance of those changes.
Accessing and updating your Personal Data
Whenever You use Our services, We aim to provide You with access to Your Personal Data. If that Personal Data is wrong, We strive to give You ways to update it quickly or to delete it – unless We have to keep that Personal Data for legitimate business or legal purposes. When updating Your Personal Data, We may ask You to verify Your identity before We can act on Your request.
We shall, at your request, can confirm what Personal Data We hold about You and how such Personal Data is processed. The following Personal Data are available upon Your request.
- Contact details of the Data Protection Officer, where applicable;
- The purpose of the processing as well as the legal basis for processing;
- The categories of Personal Data collected, stored and processed;
- Recipient(s) or categories of recipients that the data is/will be disclosed to;
- Information about how We ensure transfer of Personal Data to a third party or international organisation is done securely. The Attorney General of the Federation will approve sending Personal Data to some countries because they meet a minimum standard of data protection. In other cases, We will ensure there are specific measures in place to secure your information;
- How long the data will be stored;
- Details of Your rights to correct, erase, restrict or object to such processing;
- Information about Your right to withdraw consent at any time;
- How to lodge a complaint with the supervisory authority, National Information Technology Development Agency (NITDA);
- Whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Data and the possible consequences of failing to provide such data;
- The source of Personal Data if it was not collected directly from you; and
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Your Rights as a Data Subject
At any point while we are in possession of or processing your Personal Data, You, the data subject, have the following rights:
- Right of Access – You have the right to request a copy of the information that We hold about you
- Right of Rectification – You have a right to correct data that We hold about You that is inaccurate or incomplete
- Right to be Erased/Forgotten – In certain circumstances You can ask for the data We hold about You to be erased from our records
- Right to Restriction of Processing – Where certain conditions apply to have a right to restrict the processing
- Right of Portability – You have the right to have the data We hold about you transferred to another organisation (to be reused for Your own purposes)
- Right to Object – You have the right to object to certain types of processing such as direct marketing
- Right to Object to automated processing, including profiling – You also have the right to be subject to the legal effects of automated processing or profiling
- Right to Withdraw – You have the right to withdraw Your consent at any time
Dispute Resolution or Filing A Complaint
You acknowledge and agree that it is Your responsibility to review this Policy periodically and become aware of modifications. The most up-to-date version can be found on this website.
Compliance with the Regulations
According to the Regulation, Fatherland Badagry shall notify NITDA within 72 hours of knowledge of a breach of security leading to accidental or unlawful destruction, loss, alteration unauthorized disclosure of, or access to your Personal Data.
If you feel that your Personal Data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your Personal Data, you have a right to lodge a complaint with the NITDA. The contact details are:
National Information Technology Development Agency
Tel: +234929220263, +2348168401851, +2347052420189
Email: [email protected]
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR.
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at [email protected]
In certain circumstances, you have the following data protection rights:
0.1. the right to access, update or to delete the information we have on you;
0.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
0.3. the right to object. You have the right to object to our processing of your Personal Data;
0.4. the right of restriction. You have the right to request that we restrict the processing of your personal information;
0.5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
0.6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)
According to CalOPPA we agree to the following:
0.1. users can visit our site anonymously;
0.4. users are able to change their personal information by emailing us at [email protected].
Our Policy on “Do Not Track” Signals:
We honour Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the California Consumer Privacy Act (CCPA)
If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:
0.1. What personal information we have about you. If you make this request, we will return to you:
0.0.1. The categories of personal information we have collected about you.
0.0.2. The categories of sources from which we collect your personal information.
0.0.3. The business or commercial purpose for collecting or selling your personal information.
0.0.4. The categories of third parties with whom we share personal information.
0.0.5. The specific pieces of personal information we have collected about you.
0.0.6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
0.0.7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.
0.2. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
0.3. To stop selling your personal information. We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time.
If you submit a request to stop selling your personal information, we will stop making such transfers.
Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.
To exercise your California data protection rights described above, please send your request(s) by email: [email protected]
Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.
Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
How Can You Contact Us?
Contact details of the Data Protection Officer:
The Fatherland Organization
Attn: Privacy Matters
8500,Lorem Street, Nigeria