Privacy Policy

Welcome

Tropical General Investments Nigeria Limited values you as a customer, supplier, or other third party who is interested in or in contact with TGI and its affiliates (“TGI Group” or “Us”), our products, technologies, and services.

When you interact with us, we may collect and process certain personal data about you. This Data Protection Notice explains how the TGI Group uses the personal data you provide and outlines the rights and options available to you in this regard.

It applies to Personal Data that you share with the TGI Group or that is derived from such data. Please note that information gathered through cookies or other web tracking technologies is governed by our Cookie Policy, which is available on the relevant TGI Group website.

WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

Your personal data will be controlled by TGI or its related entities identified as the responsible controller in the communication you receive from us, or by the entity responsible for ensuring the security and integrity of your personal data.

FOR WHICH PURPOSES WILL WE USE YOUR PERSONAL DATA?

We will process your personal data strictly only for the following purposes (“Permitted Purposes”):

  • Planning, performing, managing and administering your (or a third party’s to whom you are related) contractual business relationship with the TGI Group, e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services or providing you with other services or things you may have requested;
  • Maintaining and protecting the security of our products, services and websites or other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
  • Ensuring compliance with legal obligations (such as record keeping obligations), compliance screening or recording obligations (e.g. under antitrust laws, export laws, trade sanction and embargo laws, anti-bribery or corruption laws and internal rules or to prevent white-collar or money laundering crimes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for antitrust purposes;
  • Informing you, where permitted in accordance with applicable laws, within an existing business relationship about the TGI Group’s products or services which are similar or relate to such products and services which have already been purchased or used within that business relationship;
  • Solving disputes, enforcing our contractual agreements and to establish, exercise or defend legal claims; or
  • Ensuring compliance with legal obligations, e.g. to keep sales records for tax purposes or to send notices and other disclosures as required by law.

In compliance with the Nigerian Data Protection Regulation, 2019, upon receipt of your consent, we may process your personal data also for the following purposes:

  • Communicating with you through the channels you have approved to keep you up to date on the latest announcements, special offers and other information about the TGI Group’s products and services (including marketing-related newsletters) as well as events and projects of the TGI Group;
  • Administrating and performing events including customer events, customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events; or
  • Collecting information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

With regard to marketing-related types of communication (i.e. emails and phone calls), we will where legally required only provide you with such information after you have opted in and provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us.

The legal bases for processing of your personal data are set in the Nigerian Data Protection Regulation, 2019. Depending on the above purposes for which we use your personal data, the processing is either necessary for the performance of a contract or other business agreement with any company in the TGI Group or for compliance with our legal obligations. In addition, the processing may be based on your consent where you have expressly given that to us.

SCOPE OF PERSONAL DATA

We may collect and process in particular the following categories of personal data:

  • Contact information, such as full name, work address, work telephone number, work mobile phone number, work fax number and work email address,
  • Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
  • Further business information necessarily processed in a project or contractual relationship with any Company in the TGI Group or voluntarily provided by you, such as orders placed, payments made, requests and projects;
  • Information collected from publicly available resources, integrity data bases and credit agencies; and
  • If legally required for compliance purposes: information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you which may be relevant for antitrust purposes.
  • Special categories of Personal Data. In connection with the registration for and provision of access to an event or seminar, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have. Any use of such information is based on your consent. If you do not provide any such information about disabilities or special dietary requirements, we will not be able to take any respective precautions.
  • Other Personal Data. We may sometimes ask for your date of birth, your habits or your preferences as we would like to send you greeting messages on important days for you. Any use of such information is based on your consent.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We will typically collect your personal data directly from you. We do not obtain personal data from third parties unless specified herein (e.g. information from publicly available resources, based on a contract, integrity data bases and credit agencies).

HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain physical, electronic and procedural safeguards in accordance with the legal data protection requirements to protect your personal data from unauthorized access or intrusion. These safeguards include implementing specific technologies and procedures designed to protect your privacy, such as secure servers, firewalls and SSL encryption. We will comply with applicable laws and regulations regarding the confidentiality and security of personal data.

WITH WHOM WILL WE SHARE YOUR PERSONAL DATA?

We may share your personal data as follows:

  • With our affiliates within the TGI Group worldwide if and to the extent required for the Permitted Purposes and legally permitted. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Data Privacy Notice.
  • We may also instruct service providers (so called data processors) within or outside of the TGI Group, domestically or abroad, e.g. shared service centers, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. The TGI Group will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.
  • With courts, law enforcement authorities, regulators or attorneys if legally permitted and necessary to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
  • Otherwise, we will only disclose your personal data when we are required by applicable law or regulations or judicial or official request to do so, or when we suspect fraudulent or criminal activities.

WHERE WILL YOUR PERSONAL DATA BE PROCESSED?

Our parent company Tropical General Investments Limited is a globally active enterprise. In the course of our business activities, we may transfer your personal data also to recipients in other countries (“third countries”). When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data.

YOUR DATA PROTECTION RIGHTS

Subject to certain legal conditions, you may request access to, rectification, erasure or restriction of processing of your personal data. You may also object to processing or request data portability. In particular, you have the right to request a copy of the personal data that we hold about you. If you make this request repeatedly, we may make an adequate charge for this.

For any of the above requests, please send a description of your personal data concerned stating your name, customer number (or other identification number) to the contact details below. We may require additional proof of identity to protect your personal data against unauthorized access. We will carefully consider your request and may discuss with you how it can best be fulfilled.

If you have given us your consent for the processing of your personal data, you can withdraw the consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. In case consent is withdrawn, we may only further process the personal data where there is another legal ground for the processing.

If you have any concerns about how your personal data is handled by us or wish to raise a complaint, you can contact us at the contact details below to have the matter investigated.

ARE YOU REQUIRED TO PROVIDE PERSONAL DATA?

As a general principle, you will provide us with your personal data entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which the TGI Group cannot take action without certain of your personal data, for example because this personal data is required to process your orders, provide you with access to a web offering or newsletter or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for the TGI Group to provide you with what you request without the relevant personal data.

RETENTION OF YOUR PERSONAL DATA

Your personal data will be deleted when legally required. We will in particular retain your personal data where required for the TGI Group to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.As a general principle, you will provide us with your personal data entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which the TGI Group cannot take action without certain of your personal data, for example because this personal data is required to process your orders, provide you with access to a web offering or newsletter or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for the TGI Group to provide you with what you request without the relevant personal data.

UPDATES TO THIS DATA PROTECTION NOTICE

This Data Privacy Notice was last updated in May, 2022. We reserve the right to update and change this Data Protection Notice from time to time in order to reflect and changes to the way in which we use your personal data or changing legal requirements. In case of any such changes, we will publish the changed Data Protection Notice on our website or otherwise.

HOW TO GET IN TOUCH WITH US

For any questions and comments or in case you want to assert your rights, you can also contact us in writing at: dpo@clicktgi.net

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