Privacy
Table of content
INTRODUCTION
Privacy Policy
This privacy policy sets out how we - Gapcot.com use and protect your personal data.
PRIVACY POLICY
This privacy policy gives you information about how we collect and use your personal data through your use of this website, including any data you may provide when you register with us.
This website is not intended for children, and we do not knowingly collect data relating to children.
Personal data means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped as follows:
Identity Data includes first name, last name, any previous names, username or similar identifier, title, date of birth, and gender.
Contact includes billing address, delivery address, email address, and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting, and location, browser plug-in types and versions, operating system and platform, device ID, and other technology on the devices you use to access this website.
Profile Data includes your username and password, orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you interact with and use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
- HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
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- Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by phone, email, or otherwise. This includes personal data you provide when you:
- create an account on our website;
- subscribe to our service or publications;
- request marketing communications to be sent to you;
- enter a competition, promotion, or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
LEGAL BASIS
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- To perform our obligations under our contract: We collect and process your personal data to fulfil our contractual obligations when necessary.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data. We have also identified what our legitimate interests are where appropriate.
|
Purpose/Use |
Type of data |
Legal basis |
|
To register you as a new client |
(a) Identity (b) Contact |
Performance of a contract with you
When you register for an account to with us, we may need to verify your identity to ensure that you are eligible to enter into a contract with us and to prevent fraud or unauthorised access to your account.
|
|
To process and deliver your request to conduct verification (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you by facilitating payment processes. (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you by ensuring effective communication in regard to provision of our products and services. (b) Necessary to comply with a legal obligation as required by relevant data protection laws. (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you. |
|
To enable you to partake in promotions or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you to enable access to and communication of promotions and discounts (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business to ensure that your needs are being met.) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
|
|
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study the effectiveness of the advertising we serve to you, including measuring click-through rates, conversion rates, and other metrics, to understand the impact of our marketing efforts and optimize our advertising strategy).
|
|
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
|
|
To carry out market research through your voluntary participation in surveys |
Including but not limited to: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). Participation in these surveys is entirely optional, and your responses may be anonymised and aggregated to ensure confidentiality
|
DIRECT MARKETING
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage, and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
OPTING OUT OF MARKETING
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product/service warranty registration, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.
- CROSS BORDER DATA TRANSFER POLICY
We operate in Nigeria and are bound by the data protection laws of Nigeria. However, performing our contractual obligations may require the transfer of your data outside Nigeria. We will ensure that your data shall be processed ethically ensuring that same is always protected no matter the jurisdiction it is transferred to.
As stipulated under the Nigerian Data Protection Act, 2023, we shall only transfer or allow third parties outside Nigeria to process your data if they have an adequate level of data protection as determined by relevant authorities in Nigeria.
- DATA TRANSFER TO THIRD PARTIES
We may share your personal data with our service providers, financial institutions, vendors, affiliates, subsidiaries, parent companies, contractors, government agencies, etc. to assist us in providing, delivering, analysing, administering, improving, and personalising the content that is delivered to you as part of our services. These include third parties who assist us in performing, delivering, or enhancing certain products and services related to the delivery and operation of our services; or who provide technical and/or customer support on our behalf; or who provide application or software development and quality assurance; or who provide verification functions, who process transactions and payment requests, research on user demographics, interests, and behaviour, and other products or services. These third-party service providers may also collect personal information about or from you in performing their services and/or functions on our website or platforms. We may also pass certain requests from you or your organisation to these third-party service providers. Regardless of the third party involved, any disclosure shall only be for a lawful purpose.
- DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data where necessary with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- CHILDREN'S PRIVACY
Our services are strictly for businesses and incorporated entities and do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Please note that this policy does not apply to data that is already in the public domain through no fault of ours.
- ANTI - SPAM
While email marketing is an essential tool to enable communication with our clients ensuring a spam-free environment, we adhere to all relevant anti-spam laws and regulations to ensure the protection and privacy of our users.
SENDING UNSOLICITED COMMUNICATIONS
We shall not send unsolicited emails, messages, or other electronic communications to individuals who have opted out of receiving such communications.
CONSENT REQUIREMENT
We shall obtain valid consent from recipients before sending any commercial electronic messages.
IDENTIFICATION
All commercial electronic messages sent by us shall identify us as the sender and provide accurate contact information, including a physical mailing address.
UNSUBSCRIBE MECHANISM
We shall provide you with a clear and conspicuous mechanism to unsubscribe from receiving further emails. Unsubscribe requests shall be honoured promptly, and we shall ensure that such recipients are removed from mailing lists without delay.
REPORTING SPAM
If you believe you have received spam or unsolicited communication from a user of our website, or any feedback regarding same, please report it immediately by contacting our support team at 0909 999 6734.
- DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
- YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to rectification of any inaccurate, incomplete information
- Right to data portability
- Right to information regarding automated decision-making
- Object to processing of your personal data. where we are relying on a legitimate interest as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.
You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case.
If you wish to exercise any of the rights set out above, please contact us at 0909 999 6734.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- INCIDENT REPORTING AND NOTIFICATION
In the event of a data breach or security incident that may compromise the confidentiality, integrity, or availability of personal information collected by us, we have established procedures for reporting and responding to such incidents. Our incident reporting process includes:
- Prompt internal reporting of the incident to designated personnel responsible for managing data security incidents.
- Immediate action to contain and mitigate the impact of the incident, including isolating affected systems and preventing further unauthorized access.
- Documentation of the incident, including the nature of the breach, affected systems or data, and actions taken in response.
If a data breach or security incident occurs that may impact your personal information, we will notify you as required by applicable laws and regulations.
- CONTACT DETAILS
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: Info@gapcot.com
Telephone number: 0909 999 6734.
You have the right to make a complaint at any time to the Nigerian Data Protection Commission (the “NDPC”) which is mandated to oversee the implementation of the Nigerian Data Protection Regulation (the “NDPR”). We would, however, appreciate the chance to deal with your concerns before you approach the NDPC so please contact us in the first instance.
We keep our privacy policy under regular review. This version was last updated on May 20, 2024. The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example, a new address or email address.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.