Last updated: February 13, 2023
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At Squareroof, we understand the importance of safeguarding your personal information. We have formulated this Data Protection Privacy Policy to inform you of how we maintain the confidentiality of the information, and data we receive on this Platform.

The purpose of this Data Protection Privacy Policy is to inform you of: 
1. Personal Information we may collect from you when you avail yourself of the opportunities provided on this Platform. 
2. How we use and secure such Personal Information, 
3. The choices you have regarding our use of your personal information,
4. Your ability to review, correct and object to the use of such Personal Information, in accordance with the Nigeria Data Protection Regulations, 2019, its subsequent amendments and other regulations or law regulating the collection and processing of personal data in Nigeria.
5. Access (if any) of third parties to personal data and purpose of access.
6. Available remedies in the event of violation of the privacy policy.

What Information is collected from you? 
In general, you can visit the Platform without telling us who you are or revealing any Personal Information. For each visitor to the Platform, our Web server automatically recognises only the visitor’s domain name, but not the email address (where possible). 

We may track the Internet Domain Address from which people visit us and analyse this data for trends and statistics, but individual users will remain anonymous, unless you voluntarily tell us who you are. 

Once you decide to avail any of the opportunities presented on this Platform, you will be required to provide us with certain object identifiable information that can be used to contact or identify you.
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These Object Identifiable Information usually include but without limitation to: 
a.   Your Email Address.
b.   First Name and Last Name.
c.    Phone Number.
d.  An identity document/number
e.   Address, State, Country, ZIP/Postal Code and Nationality. 

The decision to provide the object identifiable information is completely your own choice but if you choose not to provide this information, you will be unable to avail any of the services on our Platform.  

The Object Identifiable Information we collect from you, as well as others, are treated as confidential and we keep them on a secure server. However, we reserve the right to disclose the information in the circumstances set out in this Policy and in accordance with the Nigeria Data Protection Regulation, 2019 or such other regulations or law relating to data protection in Nigeria and international best practices on data protection. 

We may also use your Object Identifiable Information to contact you with newsletters, marketing or promotional materials or other information that may be of interest to you.

You may opt out of receiving any, or all, of these communications from us by clicking on the unsubscribe link or following the instructions provided in any email we send.

You shall have the right to rectify inaccurate data and update data concerning you and any such rectification and update of your data shall be reflected in our Database Management System.

We may retain a copy of your Information for compliance reasons. When you update your Information, we may retain a copy of the prior version for our records.
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How do we use your Personal Information? 
We use the information you provide us to customize your experience on the Platform or to serve you specific content or ads that are relevant or personalised to you.
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We may also use aggregate information and statistics for the purposes of monitoring Platform usage in order to help us develop the Platform and our Services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.
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We gather this Information to allow us to process any request you may make; and to also administer your contractual relationship with us.

We also collect this Information in order to grant you access to our Services, monitor your usage of our Platform and Services, and/or participation in online activities including reviews.

From time to time we may provide your Object Identifiable information to our customer service agencies or customer service unit, for research and analysis purposes, so that we can monitor and improve the Platform, online experience and our services to you. We may contact you by email or telephone to ask you for your feedback and comments on our services.
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The information we obtain are also useful in aiding investigations and attending to your complaints or enquiries within reasonable time.

Cookies Policy  
Cookies are used to uniquely identify a person, consequently we treat them as object identifiable information. They are used for analytics and advertising to improve the experience and relevance of our Platform.

When you first visit our Platform, we ask you via a pop-up banner to accept or reject the use of cookies. This pop-up clearly explains why we use them and asks you to make an affirmative action by clicking Continue. If you do click accept or such other similar command prompt then you unlock the full functionality of our Platform. However, if you refuse to accept cookies on this Platform, it will affect how our Platform works and you may not be able to access or use certain areas of our Platform or its full functionality.

Third Party Access
‍We are bound to keep your Object Identifiable Information private, except as provided in this Privacy Policy, we will not sell, rent or loan any of your Information to third parties for their marketing purposes without your explicit consent.
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We will not disclose any Personal Information to third parties unless:  
a. the disclosure is required or authorised by law,
b. or you have consented to a disclosure of your Personal Information,
c. or for other purposes (relating to the primary purpose for collecting that information, including the processing of your personal data or Personal Information by our agents or data processors) that is reasonably expected including the sale or disposal of any part of our business or rights.
d. It is necessary in order to protect the vital interests of another natural person
e. or in circumstances where the concealment is likely to endanger the life of another natural person. 
f. It is necessary for the prevention and detection of an unlawful act.
g. It is necessary to protect against malpractice or misfeasance. 

We may also collect, and our third party providers of advertisements and content may collect certain user information such as information relating to computer location, URL and IP address and domains, your browser type, the country and telephone area code where your computer is located, the pages of our Platform that were viewed during your visit, the advertisements you clicked on, and any search terms that you entered on our Platform.
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We may contract with third party companies, sub-contractors, service providers, agents or other persons to provide certain services including data management, web development, promotional services and such other ancillary services for the fulfilment of our obligation to you as our user.

We call them our “Service Providers” and we shall be entitled to provide our Service Providers with the information needed for them to perform these services.

We also ask our Service Providers to confirm that their privacy practices are consistent with ours.
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In sharing your information, we will ensure compliance with the Nigeria Data Protection Regulations, 2019 and any such laws in existence now or to be developed later with respect to data protection/privacy policy.

How do you give consent?
By submitting your personal information on this Platform, you consent to the use of that information as set out in this Data Protection Privacy Policy. If we change our Data Protection Privacy Policy, we will post the changes on the Platform and send you an email notifying you of the change, so that you may be immediately aware. 

You agree that you do not object to us or our Service Providers, contacting you for statistical or survey purposes, to improve this Platform and its services to you. You consent to such contact whether by telephone, email or in writing.

What happens when we expand; form an alliance or sell our business?
If all or part of our business is sold, (whether by sale of shares or assets) or integrated with another business, your details and Information may be disclosed to our adviser and any prospective purchaser or purchasers and their advisers and will be passed on to the new owners of the business. We will notify you (via a message to the email address associated with your account) of any such deal and outline your choices in that event. 

Following completion of any such sale or transfer, your Information shall be disclosed and transferred to such new owner or third party.

How we protect your data.
‍The Platform is committed to online security. We maintain security measures to protect sensitive data on our Platform and to prevent unauthorised access of user information transmitted to our servers. 
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We cannot however guarantee the security of any data sent over the internet but we have put in place appropriate physical, electronic and managerial procedures to protect, secure and safeguard personal data and information collected on or through our Platform, which measures are reviewed from time to time. Some of the unique measures include but are not limited to the following; 

a. We always use industry-standard encryption technologies when transferring and receiving user data exchanged on our Platform.
b. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you on our Platform.
c. We ensure that handshakes (requests and responses) between user devices/browsers and our servers take place over a Secure Socket Layer (SSL/HTTPS) to keep out any middleman attack.
d. We scrutinise and sanitise every request to our servers to prevent common security exploitations such as Query Injections and Script Injections.
e. We sign every resource-mutating request to our servers with unique security tokens to prevent security breaches such as Cross-Site Resource Forgery (CSRF) and Session Hijacks.
f. Every sensitive data collected from our users are hashed and/or encrypted on our servers with AES-256 and AES-128 encryption.
g. All encrypted data are also signed using a message authentication code (MAC) so that their underlying values cannot be modified once encrypted. 

Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. For this reason, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any Personal Information you transmit to or from our Platform, and you do so at your own risk. Once we receive your transmission, we will do our best to protect its security on our systems.
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All our employees are briefed on the importance of personal data, security and confidentiality of information obtained. They are also trained on practical aspects of the Nigeria Data Protection Regulation, 2019.
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In respect of detection and investigation of breaches where they occur, we have in place relevant controls which should alert us to a breach of security. We endeavor to investigate every notified breach of security.

The personal data and information held by us are currently stored on a relevant technology system, mass email programme database, individual account contact manager’s systems together with the training booking spreadsheet, invoicing spreadsheet, Excel spreadsheets and paper form.
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We have implemented internet security technology to ensure that it is safe for you to avail our services on this Platform. We are constantly updating our technology to provide you with the maximum practicable level of security.

What are the Data Protection rights?
‍The right to your data privacy as a data subject is enshrined in the Nigeria Data Protection Regulations, 2019 with all the applicable exceptions as stated therein.

They include: 
a. Right to request that the data collected by us on this Website be made available to you in an electronic format or that it should be sent to a third party (Kindly note that we reserve the right to decline such request where they are manifestly unfounded or excessive, in particular because of their repetitive character).
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b. Right to request the Controller to delete personal data without delay.
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c. Right to obtain from the Data processor restriction of processing.
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d. Right to transfer data from one data controller to another.
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e. Right to request that we delete your personal data without delay and we shall delete same where one of the following grounds applies:
i.   the personal data are no longer necessary in relation to the purposes for which they were collected or processed; 
ii.   The data subject has withdrawn his or her consent on which the processing is based; 
iii.    There is an objection to the processing and there are no overriding legitimate grounds for the processing; 
iv.   the personal data has been unlawfully processed; and 
v.   the personal data has to be erased for compliance with a legal obligation in Nigeria.
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How long do we store your personal data/information for?
‍We retain the information provided to us for as long as necessary for the purpose(s) for which it was collected and not longer than one (1) year from the date of collection. The period of data storage is also subject to legal, regulatory, administrative and operational requirements.

What are the remedies available to you in case of a breach?
‍In case of a breach or complaints about the handling of your personal information, you may lodge a complaint with us via email to hello at mysquareroof dot com. and we will ensure to resolve your complaints in the shortest possible time.
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Your Feedback
‍To help us improve our privacy policy and practice, please give us your feedback. You may email us at hello at mysquareroof dot com.