PRIVACY POLICY – SOFT ALLIANCE AND RESOURCES LIMITED

 

  1. Introduction

 

Soft Alliance and Resources Limited (“Soft Alliance”, “we“, “our”, “us”, “The Company”) takes the protection of privacy and protection of personal information seriously. By visiting our website or using our services, You (“users”, “visitors”) acknowledge and accept the practices and policies outlined in this Privacy Policy (the “Privacy Policy”, “Document’ ‘).  This Privacy Policy applies to all information collected from or about You by Soft Alliance through any of our Products. The purpose of this document is to help You understand what information is collected from or about You, how this information is used and protected, and what options You have with regard to this information. This document also describes your privacy rights and how the law protects You.

 

  1. Definitions

 

For the purposes of this Privacy Policy:

“Account” means a unique account created for You to access our Service or parts of our Service.

 

“Business” refers to the Company as the legal entity that collects personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in Nigeria.

 

“Company” referred to as either “the Company ”, “We “,”Us’ ‘ or “Our’’ in this document refers to Soft Alliance and Resources Limited.

For the purpose of the NDPA, the Company is the Data Controller.

 

“Country” refers to Nigeria.

 

“Consumer”, for the purpose of this document means a natural person who is a Nigerian Citizen. An individual who is domiciled in Nigeria for other than a temporary or transitory purpose.

 

“Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

 

“Data Controller”, for the purposes of the NDPA (Nigeria Data Protection Act, 2023), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

 

“Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet.

 

GDPR means the General Data Protection Regulation.

 

“Information” means any and all information we receive from or about You.  This may include (without limitation) information collected from You directly or indirectly, manually or otherwise, or via electronic, automatic or other means, including (without limitation) via stationary, mobile or any other devices. Such information may include information (i) which You provide during the course of Your use of our website (the “Site”), or Your use of our services or our products (the “Services”); (ii) collected about You, Your business, and the technology You are using, and (iii) which we receive about You from third parties or other sources.

 

NDPA means the Nigeria Data Protection Act, 2023

 

NDPC means the Nigeria Data Protection Commission

 

“Personal Data” is any information that relates to an identified or identifiable individual. For the purposes of NDPA, Personal Data means any information relating to You such as a name, an identification number, location data,  e-mail addresses, facial recognition data and phone numbers, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

 

“Service” refers to the Website.

 

“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the NDPR. Service Providers are considered Data Processors.

 

“Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.

 

“Website” refers to https://softalliance.com/

 

“You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under NDPA, You can be referred to as the Data Subject or as the User as You are the individual using the Service.

 

  1. Acceptance of Terms

 

We obtain and use Information in accordance with this Privacy Policy.  We will ask for your consent before using Personal Information in a manner other than as set out in this Privacy Policy.

 

BY USING OUR SERVICES OR VISITING OUR SITE OR SUBMITTING INFORMATION THROUGH THE SERVICES OR VIA OUR SITE, YOU EXPRESSLY CONSENT TO THE COLLECTION, PROCESSING, AND USE OF YOUR INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, INCLUDING THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND PROCESSING OF YOUR INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, AS DESCRIBED HEREIN.  YOUR INFORMATION, INCLUDING YOUR PERSONAL IDENTIFIABLE INFORMATION, MAY BE PROCESSED IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS IN OTHER COUNTRIES WHERE LAWS REGARDING THE PROCESSING OF INFORMATION, INCLUDING PERSONAL INFORMATION, MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.

 

IF YOU DO NOT AGREE WITH OUR PRIVACY POLICY, PLEASE DO NOT USE OUR SITE, PRODUCTS, OR SERVICES.

 

  1. Obtaining and Using Personal Data.

4.1         Types of Data Collected.

We collect the following personal information:

 

4.1.1      While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • First and last names
  • Gender
  • Date of birth
  • Government-issued identification and/or number
  • Photo identification
  • Address
  • Country of residence
  • Nationality
  • Place of birth/Country of birth
  • Email address
  • Telephone number
  • BVN
  • Account Number
  • Your company name, job title, company’s industry, trade details and regulated status
  • General information about Your interest in our products and services
  • Information provided when You correspond with us
  • Any updates to information provided to us; information You provide to help us provide You with improved services; information about You marketing preferences
  • Personal information we collect about You or that we obtain from our third party sources.

 

4.2         Data Collection

4.2.1      Data is collected automatically when using the Service. Whenever You contact us or respond to our communications (e.g., in email, telephone, or writing), we receive Your contact information and any other personal information You choose to provide us. We will use such information to fulfill Your requests or to provide services.

 

4.2.2      We collect Personal Information when You use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for and/or attend events we participate in.

 

Your communications with other users of the Services or the Site may be monitored, recorded and/or reviewed by Soft Alliance.

 

4.2.3      Technical information, including the Internet protocol (IP) address used to connect Your computer to the internet address; the website address and country from which You access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform.  We use this personal information to administer our Site, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our web pages;

 

4.2.4      Information about Your visit and Your behavior on our Site or our Services. This may include the website You visit before and after visiting our Site (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.

 

4.2.5      You may provide us with your personal information voluntarily.  However, we may also receive personal information about You from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants of our Affiliates, Your colleagues and business contacts, public websites, and public agencies.

 

4.2.6      We collect Personal Information that You give us by filling in forms, using our Services, contacting us, setting up an account with us, or by contacting us by phone, email or other means; and that we learn about You from our business interactions, communications, and dealings with You.

 

4.2.7      We also collect Personal Information You communicate to other users of the Services or the Site through the Services or the Site.  However, we are under no obligation to review, and assumes no responsibility or liability relating to, such communications.

 

4.2.8      We also collect Personal Information automatically when we receive and store certain types of information automatically when You interact with the Sites or use the Services.

 

  1. Cookies

 

We, and third parties we may partner with, may store and retrieve information on and from Your browser by placing a small text file called a “Cookie” in the browser files of Your computer, smartphone, or other device.  By using the Services or the Site, You agree that we may use, store, and access Cookies on and from Your computer, smartphone, or other device.

 

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

 

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

 

  1. Non-Personal Information

 

Non-Personal Information may be collected, processed, and used in accordance with applicable law, for any and all purposes we deem fit.  Generally, the information Soft Alliance collects is used only for our own internal purposes, for example, to improve the Services and the Site, to improve our marketing and promotional efforts, to improve customer service, and to improve Soft Alliance’s content and Site offerings, and may also be used by Soft Alliance to contact You to provide You with information which we believe may be useful to You.  Soft Alliance believes that these uses allow it to improve the Services and our Site and to better tailor them to meet customers’ needs.

 

  1. Use of Personal Information

 

In general, Personal Information You submit to us, or that is obtained by us, is used:

  • To create and manage the business relationship,
  • To provide and support our services to the organization You represent,
  • To improve our Services,
  • To communicate with You about our Services,
  • To send You notifications regarding the use of the Services or the Site,
  • To send You notifications by various means, including regular mail, email, telephone, including voicemail, or SMS (text message)
  • To respond to requests that You make,
  • To bill You, to resolve fee disputes and for other associated billing services,
  • To further new services or products,
  • To operate, maintain, and improve the features, functionality, and performance of our Site and Services,
  • To comply with our legal obligations;
  • To comply with our regulatory obligations;
  • To monitor compliance with our rulebooks and contractual terms of use;
  • To better understand our customers and the way they use and interact with our Site and our Services;
  • To enhance security, prevent fraud or market abuse, monitor and verify identity or service access, combat spam or other malware or security risks;
  • To provide You with news and general information
  • To deliver targeted marketing and service update notices;
  • To facilitate events we participate in and communicate with You about those;
  • To enforce our agreements with third parties;
  • To protect our business and to enforce and exercise our rights.
  • For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and You experience.

 

  1. Disclosure of Personal Information

 

Except as otherwise stated in this Privacy Policy, we will not disclose or share Your Personal Information with third parties, unless your consent is obtained.

 

We may share You personal information in the following situations:

 

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
  • With Employer: or colleagues within the organization that You represent.
  • With a legal, regulatory or governmental body that we are required to disclose information (a) to comply with relevant laws, (b) to respond to court orders, subpoenas, or warrants served on us, (c) to respond to an emergency, or (d) to protect and defend Soft Alliance’s rights or property.
  • For business transfers: In the event Soft Alliance goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, Your Personal Information will likely be among the assets transferred. You acknowledge that such transfers may occur, and that any acquirer of Soft Alliance, or a portion or all of its assets may continue to use You Personal Information as set forth in this Privacy Policy.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions; and (a) to provide You with some of the Services of the Site, (b) to operate, improve, understand, customize, and support the Services or the Site, (c) to help us communicate with our customers, (d) to assist us in our marketing, advertising and promotional activities (e) to analytics and search engine providers that assist us in the improvement and optimization of our Services or our Site and (f) to help us with our business and informational needs. However, we do not grant these business partners, service providers, and suppliers any independent right to use this information except to help us provide the Services, operate the Site, or for our legitimate business interests.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

 

Please note that third parties You interact with, including Your employer, may have their own privacy policies, and Soft Alliance is not responsible for their operations, including, but not limited to, their personal information practices. Personal Information collected by third parties, which may include contact details, is governed by their privacy practices. We encourage You to learn about the privacy practices of those third parties.

 

  1. Retention of Your Personal Information.

 

We keep Your Personal Information for as long as is necessary for the purposes for which the Personal Information is processed.  The length of time for which we retain Personal Information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

 

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

 

  1. Transfer of Data

 

We may transfer the Information, including Personal Information, we collect about You to recipients in countries other than Nigeria in accordance with Section 41 and 43 of the NDPA, which is permissible when the recipient of the personal data is subject to a law, binding corporate rules, contractual clauses, code of conduct, or certification mechanism.

Such cross-border transfer of personal data shall require the approval of the Nigerian Data Protection Commission first sought and obtained.

 

  1. Legal Bases for Our Use of You Personal Information

 

We rely on both Your consent and our legitimate business interests as the legal bases for processing Personal Information.

In this regard, we use You Personal Information under the following conditions; however not limited to  (a) to perform our obligations under any contract with You; (b) to comply with our legal obligations (for example, complying with our legal and regulatory obligations); and (c) for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Site or Services).  (d) You have given Your consent for processing Personal Data for one or more specific purposes. If we rely on our (or another person’s) legitimate interests for using Your Personal Information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by Your interests or fundamental rights and freedoms which require protection of the Personal Information.

 

If we rely on Your consent for us to use Your Personal Information in a particular way, but You later change Your mind, You may withdraw Your consent by contacting us at the e-mail address set forth in the “Contact Us” section below, and we will stop doing so.

 

  1. Links to Other Websites

 

Our Services and/or the Site may contain links to other websites that are not owned or controlled by us. The provision of such links does not signify our endorsement of such websites or their content.  We have no control over, do not review and are not responsible for, the privacy policies, terms of use, or content displayed on such other websites.  Please be aware that the terms of our Privacy Policy do not apply to any outside websites. We strongly advise You to review the Privacy Policy of every site You visit.

 

  1. Security and Confidentiality

 

The Company has put in place commercially reasonable protections and procedures to safeguard and secure the Personal Information we collect.  However, even with these measures, we cannot guarantee the security of Personal Information 100%.  By using our Services or our Site, You acknowledge and agree that we make no such guarantee.

 

  1. Access to, Correcting or Deleting You Personal Information

 

If we hold Personal Information about You, You may request that we correct, amend, or delete certain information where it is inaccurate, within reason and in accordance with applicable laws. Prior to fulfilling any request for information or deletion, we may require You to provide information so that we may verify Your identity. Subject to applicable laws, we reserve the right to decline requests that are unreasonable, present risk to the privacy of another individual, may jeopardize the confidentiality of another party, are excessively repetitive, may require significant technical modifications to our systems.  Please contact us at the address set forth in the “Contact Us” section below if You need assistance in updating or reviewing Your information.

 

  1. Your Rights with Respect to Your Personal Information

 

Both Nigerian (NDPA) and EU (GDPR) data protection laws make a distinction between organizations that process personal information for their own purposes (known as “Data Controllers”) and organizations that process personal information on behalf of other organizations (known as “Data Processors”).

 

In the limited circumstances where we act as a Data Controller, citizens have certain data protection rights, including:

  • The right to access Your Personal Information;
  • The right to restrict the use of You Personal Information;
  • The right to have incomplete or inaccurate data corrected;
  • The right to ask us to stop processing You Personal Information; and
  • The right to require us to delete Your Personal Information in some limited circumstances.
  • The right in some circumstances to request for us to “port” Your personal data in a portable, re-usable format to other organizations (where this is possible).
  • The right to request the transfer of Your personal information.
  • The right to withdraw You consent.

 

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of Your request unless we tell You we are entitled to a longer period allowed by applicable law). Please note, however, that certain Personal Information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.  If an exception applies, we will tell You this when responding to Your request. We may request You provide us with information necessary to confirm Your identity before responding to any request You make.

 

  1. Marketing Activities

 

We may collect and use Your personal information for undertaking marketing by email telephone and mail.  We may send You certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.

 

We will always obtain Your consent to direct marketing communications where we are required to do so by law (for example, if You have provided a personal email address to us) and if we intend to disclose Your personal information to any third party for such marketing.

 

If You wish to stop receiving marketing communications, You can contact us at the address set forth in the “Contact Us” section below.

 

  1. Changes to this Privacy Policy

 

We may change this Privacy Policy at any time by posting a new version on this page or on a successor page.  The new version will become effective on the date it is posted.  We reserve the right to modify this Privacy Policy at any time, and You agree that You continued use of our Services or our Site shall constitute Your acceptance of any modifications to such Privacy Policy, so please review it frequently.

 

  1. Contact Us and Opting-Out

 

If You wish to exercise any of Your rights in relation to Your Personal Information, including exercising Your opt-out rights, please send us an email to our Compliance Officer at info@softalliance.com

 

If You have any questions regarding our Privacy Policy or the collection or use of Your Information, please contact our Compliance Officer at info@softalliance.com