ABOUT US
Still Earth Capital Finance Limited (SE Cap, We, Our) is a multi-faceted financial services company offering tailored financial services and solutions to individuals, companies and the public sector. Still Earth Limited as a construction member of the same entity is a premier General Contractor and known as one of the leading Engineering and Construction Companies in Nigeria with a portfolio that includes projects in both Public and Private Sectors across the Nation. SEL Cap as a separate entity of the same organization are the controllers of Your Personal Data.
You are not obliged to give us any of Your information above, but if You decide not to give it to us or provide us with false or incorrect information, We may be unable to respond to Your message.
DEFINITIONS
Affiliate means in relation to an entity, a subsidiary or a holding company of that entity, or any subsidiary of the holding company and all of its subsidiaries;
AML/CFT Laws means any Applicable Law concerning anti-money laundering, countering the financing of terrorism, countering the financing of proliferation of weapons of mass destruction and which impose Know-Your-Customer (KYC), Customer Due Diligence (CDD) obligations or other procedures for the mitigation of financial crimes.
Applicable Laws means all laws in force and effect as of the date hereof and which may be enacted or brought into force and effect hereinafter in the applicable Territory, including statutes, rules, regulations, directions, bye-laws, notifications, ordinances and judgments having force of law, or any final interpretation by a court of law having jurisdiction over the matter in question as may be in force and effect during the subsistence of this Privacy Policy;
Cookies means a small data file that is transferred to Your computer or mobile device to enable us remember Your account log-in information, IP addresses, web traffic, number of times You visit, browser type and version, device details, date and time of visits.
Data Protection Authority means the Nigeria Data Protection Bureau, the National Information and Technology Development Agency or any other relevant authority relating to privacy or data protection in the territory and the territory of its Affiliates.
Data Protection Legislation means the Nigerian Data Protection Regulation 2019, the General Data Protection Regulation (Regulation (EU)2016/679) ('GDPR') and all other applicable legislation relating to privacy or data protection in the territory and the territory of its Affiliates.
Data Subject means a living, identified or identifiable individual about whom We hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
Personal Information means any information that can be used to identify a living person including Identity Data such as Your full name and government issued identification number, Contact Data such as contact and email address, Financial Data such as credit or debit card information, bank account number, etc., taxpayer identification, it may also include anonymous information that is linked to You, for example, Your internet protocol (IP),log-in information, address, location, device or transaction data and/or such other data personally identifiable to You as specified in this Privacy Policy.
Platform means the computer equipment, website, network, software and API that are proprietary or licensed to SEL Cap or its Affiliates from time to time and utilized by SEL Cap to provide the Services
Privacy Policy means this privacy policy.
Services means the goods, products and services provided by Us.
Territory means the location of the User whether Nigeria (as may be applicable);
User or You or Your means anybody who uses or accesses Our Platform or Services
Special Categories of Personal Data means details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Your health and genetic and biometric data.
INTRODUCTION
This privacy policy will help You understand what Personal Data We collect, what We use it for and how You can exert Your rights with respect to Personal Data.
SEL Cap operates on Personal Data for a variety of purposes. We retrieve this Personal Data if You submit Your contact details to receive newsletters and email campaigns concerning Our products and services (old and new), and marketing communications. Our website uses cookies to collect anonymous and aggregated statistical data about users’ visits on Our website. Alternatively, We process Your Personal Data in the context of providing professional services to Your employer or service provider, for example, conducting an audit of Your bank or payroll for the company You work for. Finally, We obtain Your Personal Data via publicly available sources, such as LinkedIn. Unless You set up Your internet browser (e.g., Mozilla Firefox or Google Chrome) not to accept cookies, it will accept the use of them. You can always disable cookies in Your browser’s preferences even if You have consented to the use of cookies in the past. You may also delete cookies stored on Your computer at any given time. Please note that disabling cookies may negatively impact Your online experience on SEL Cap website. Click on the links in Our index to take You to the more detailed information regarding various purposes for which We process Personal Data.
We collect Personal Data from the following
· Individuals who sign up to Our newsletters.
· Clients who book consumer or SME loans.
· Visitors to SEL Cap.
· Individuals whose Personal Data We obtain in connection with providing services to Our clients.
· Insolvency services.
· Contacts in Our customer relationship management(CRM) systems.
· Individuals who use Our applications.
· Individuals who visit Our social media sites, social media plugins and tools.
· Individuals who correspond with SEL Cap via email.
· Visitors to SEL Cap office.
It is important that the Personal Data We hold about You is accurate and current. Please keep us informed if Your Personal Data changes during Your relationship with us.
OBJECTIVE
This Privacy Policy provides all persons whose Personal Data We hold with a description of the types of Personal Data We collect, the purposes for which We collect that Personal Data, the other parties with whom We may share Personal Data with, and the measures We take to protect the security of the data in relation to the Services. We have outlined Our Privacy Policy below.
OUR PRIVACY PRINCIPLES
SEL Cap focuses on the following core principles:
(a) To Empower the individual: SEL Cap wants You to bein charge of Your Personal Data and to make Your own voluntary choices about Your Personal Data;
(b) To keep and secure Personal Data: SEL Cap does not take Your trusting us with Your information for granted. We take responsibility to ensure that appropriate security measures are put in place and Your Personal Data is protected;
(c) To be transparent and to educate Users: For You to know what Personal Data is, how We collect Personal Data, the purpose for collecting Personal Data and how We secure Personal Data;
(d) To abide by privacy laws in the Territory: SEL Cap is committed to complying with privacy laws in the Territory; and
(e) To collect and store Personal Data on a “need to collect” basis: SEL Cap collects Personal Data to perform its services for You. We implement measures to prevent collecting and storing Personal Data beyond what We need.
WHAT IS PERSONAL DATA
To define Personal Data, account must be taken of all the means available to the “data controller” to determine whether a person is identifiable. According to the law, it means any information relating to an identified or identifiable individual; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM, Personal Identifiable Information (PII) and others;
YOUR RIGHTS WITH REGARDS TO YOUR PERSONAL DATA
You have the right:
· To access the information that We have on You. We will make sure to provide You with a copy of the Personal Data We process about You. In order to comply with Your request, We may ask You to give us some additional information that We will use to verify Your identity. If You fail to provide such information or if the information that You have already given to us is not enough to identify You, We may refuse to provide You with information by contacting us.
· We will fulfil Your request by sending Your copy electronically, unless the request expressly specifies a different method.
· To have Your Personal Data corrected, for example, if it is in complete, out of date or incorrect.
· To opt out or unsubscribe from receiving marketing campaign communications at any time. If You register on Our Platform, Your Personal Data will be stored in Our CRM system. If You have unsubscribed or opted out, your contact details will remain on Our opt-out list to ensure we do not inadvertently contact You in the future and Your Personal Data will be erased completely.
· To provide You with relevant information if We need to further process Your Personal Data other than the reasons for its collection.
· To disapprove the processing of Personal Data or request obliteration of Personal Data (in certain circumstances and subject to Data Protection Legislation). These circumstances occur in the event where the Personal Data is no longer necessary for the purpose it was collected or processed, or You withdraw your consent, or if the Data Subject objects to the processing and there are no overriding legitimate grounds, if the Personal Data was unlawfully processed, and if erasure is required to comply with Applicable Laws.
· Where You have provided Personal Data voluntarily, or otherwise consented to its use, You have the right to withdraw Your consent. Such withdrawal does not affect the lawfulness of processing of Your Personal Data up to that time.
· You have the right to complain to a Data Protection Authority or refer the matter to a court of competent jurisdiction where the need arises.
· If You have a query or wish to exercise Your rights, please speak to the person You usually deal with at SEL Cap or contact the SEL Cap team.
GRIEVANCE
If You are concerned about an ostensible violation of privacy law or any other regulation by SEL Cap, You can contact the person You usually deal with at SEL Cap. ASEL Cap privacy leader will investigate Your complaint and give You information about how it will be handled. You also have the right to complain to the NDPB or refer the matter to a court of competent jurisdiction.
CONSENT
By using Our services, You consent to the collection, use, processing, and sharing of Your Personal Data as outlined in this privacy policy. We will only collect and process Your Personal Data for the specific purposes stated in this Policy, such as providing You with Our services or communicating with You about Our products and promotions. We will not share Your Personal Data with third parties without Your explicit consent, except in cases where We are legally required to do so. You have the right to withdraw Your consent at any time by contacting us at [dpo@stillearthcapital.com]. Please note that withdrawing Your consent may impact Our ability to provide You with Our services. Also note that, subsequent withdrawal of Your consent will not affect the lawfulness of Personal Data earlier obtained with consent.
PERSONAL DATA WE MAY COLLECT FROM YOU AND THE PURPOSE FOR COLLECTING AND PROCESSING THEM
Information That You Provide Voluntarily
We retrieve Personal Data that You Provide voluntarily through Our website when You:
· Complete Our forms to contact us.
· Subscribe to Our newsletter.
· Subscribe to receive Our marketing messages.
· Participate in Our surveys.
We may also receive Personal Data about You from other sources, including publicly available databases and combine this Personal Data with Personal Data We already have about You, this helps us to update, expand and analyze Our records and provide services that may be of interest to You.
The information We retrieve includes:
· Name
· Email Address
· Company data
· Contact information
· Information relevant to surveys
· Demographic information and other Personal Data You decide to give us
Kindly note that We do not collect or process Special Categories of Personal Data unless You provide such Personal Data. You are not required to provide or disclose sensitive Personal Data in free text boxes. If You choose to provide such Personal Data, You should acknowledge Your consent to the operation of this Personal Data.
INFORMATION THAT WE COLLECT AUTOMATICALLY
When You visit Our site, We collect Personal Data automatically from Your device such as Your IP address, device type, geographic location such as the country and city, last activity time on Our website, browser and OS. We also collect information about how You have interacted with Our website and content that You are interested in, We use these details for tracking purposes to improve the quality of Our site to the visitors. This information will be collected using cookies and other tracking technology.
For detailed information on cookies and other tracking technology as well as how we use them, see our Cookie Policy.
We process Your Personal Data to:
· Authenticate Your identity and prevent unauthorized access to restricted data.
· To manage Our website.
· To analyze individual’s data on Our site.
· To develop business relationship with Our customers.
· To determine the organization that You work for or with.
· To provide You with relevant information of Our products and services.
· To provide necessary updates and news to Our customers.
· To monitor and enforce compliance.
· To conduct data analysis.
· To understand how visitors, use the various aspects of Our site; and
· any other purpose for which You have provided the Personal Data.
We process Personal Data of individuals with whom We do not have direct relationship. Our engagement team will be required to audit Our client’s book, We seek confirmation from Our clients that they have the authority to provide Personal Data to us in accordance with the Data Protection Legislation.
Given the services We provide, We process special categories such as:·
Financial information – salary, payroll, income, Investment, and tax status.
Employment – role, position, and employment numbers.
Anonymized Data
We may also collect, store, use and transfer non-Personal Data or anonymized data such as statistical or demographic data. Anonymized data could include Your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal Your identity. For example, We may aggregate Your usage data to calculate the percentage of users accessing a specific website feature. However, if We combine or connect aggregated data to include Your Personal Data so that it can directly or indirectly identify You, We treat the combined data as Personal Data, which will be subject to the terms of this Privacy Policy and the Data Protection Legislation.
LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
We only use Your Personal Data for a specific purpose; and before We do so, We must have a legal reason. For example, when it is necessary for us perform a contract with You, for Our legitimate interest, where You have given us Your consent, or to fulfil Our legal obligations. These are all known as the “legal or lawful basis for processing”.
The legal or lawful basis We rely on for processing Your Personal Data by using Our services:
Your consent: Where You agree to us collectingYour Personal Data by using Our Services. With Your consent, We may sendmarketing and promotional communications by email, SMS and push notifications(depending on Your choice of contact). For more information, please see theMarketing section of this policy;We may send targeted marketing about Ourservices on third-party online services such as Google, Instagram and Facebookif We believe that You are likely to be interested in using Our services basedon Your profile. Your consent to receive targeted adverts would have beenobtained by these third parties on Our behalf;
Surveys: Engaging with You for the purposes of obtaining Your views on Our Apps or Services.
We have a contractual obligation: Where it is required to perform the contract We are about to enter into or have entered into with You.
We have a legal obligation: To ensure We are fully compliant with all Applicable Laws including AML/CFT Laws, We must collect and store Your Personal Data.
We have a legitimate interest: We may also collect Your Personal Data where We have a legitimate interest to do so, provided that Your rights do not override such interests.
THIRD-PARTY LINKS
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.
DISCLOSURE OF YOUR PERSONAL DATA
We handover or divulge the Personal Data We collect from You to third-parties such as legal advisors, professional advisors, such as law firms, tax advisors or auditors, insurers, tax and customs, regulatory bodies, stock exchange authorities, providers of identity verification services, credit reference agencies, law enforcement agencies, government agencies, third-party service providers that provide, run and support Our IT infrastructure (such as CRM solutions, identity management, hosting, data analysis, back-up, security and cloud storage services) and for the storage and secure disposal of Our hard copy files.
We may only share Your Personal Data with external third parties in the following limited circumstances:
(a) We have Your consent. We require opt-in consent for the sharing of any Personal Data; We share Personal Data with third parties directly authorized by You to receive Personal Data, such as when You authorize a third-party application provider to access Your Personal Data with us. The use of Your Personal Data by an authorized third party is subject to the third party's privacy policy and We shall bear no liability for any breach which may arise from such authorization by You;
(b) We provide such information to Our subsidiaries, affiliated companies or other trusted third-party service providers for the purpose of processing Personal Data on Our behalf. We require that these parties maintain appropriate levels of data protection, security and confidentiality, and to process Your Personal Databased on Our instructions and in compliance with Data Protection Legislation as well as any applicable legal requirements for transferring Personal Data outside the jurisdiction in which it was originally collected.
(c) We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to
(d) comply with Applicable Laws; SEL Cap has a legal obligation to report suspicious transactions and other activity to relevant regulatory authorities under relevant anti-money laundering, terrorist financing and proliferation financing regulations.
(e) enforce applicable terms of service, including investigation of potential violations thereof;
(f) detect, prevent, or otherwise address fraud, security or technical issues; SEL Cap reports suspected criminal activity to the police and other law enforcement bodies. We are not always permitted by the law to inform You about this in advance of the disclosure, or at all.
(i) assess financial and insurance risks; or
(ii) protect against imminent harm to the rights, property or safety of SEL Cap, its users or the public as required or permitted by law.
If SEL Cap becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, We will provide notice before Personal Data is transferred and becomes subject to a different Privacy Policy.
PERSONAL DATA PROTECTION
SEL Cap places a strong emphasis on maintaining the confidentiality of all information obtained during a designated period of business operations. To achieve this, access to this Personal Data is restricted to only authorized personnel, and stringent guidelines and procedures are established to safeguard against any loss, misuse, or unauthorized disclosure of the Personal Data. Our commitment to ensuring the confidentiality of Your Personal Data is paramount, and We take all necessary measures to protect the integrity and privacy of Our clients' Personal Data.
UPDATED AND ACCURATE
PERSONAL DATASEL Cap maintains the accuracy of the Personal Data in Our custody. It is essential that You inform us of any updates to Your contact details or other Personal Data so that We have the most up-to-date information about You. SEL Cap may also ask for additional details to update Your Personal Data if the need arises.
RETENTION
We shall only retain Your Personal Data for as long as it is required for the purposes described in the section “Purposes for which We process Personal Data”, To meet Our professional and legal requirements, accounting and reporting obligations, to establish, exercise or defend Our legal rights, for archiving and historical purposes or if We suspect a potential litigation in respect of 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 unauthorized 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. Where We retain Your Personal Data, We do so in compliance with limitation periods under Applicable Laws.
PERSONAL DATA BREACH
We have put in place, a data breach protocol to address incidents that involve accidental or unlawful destruction, loss, alteration, unauthorized access or disclosure of Personal Data that is transmitted, stored, or processed. We will investigate any reported breach to determine its veracity and the necessary steps to manage it. Additionally, We will also notify You and other relevant authorities promptly in line with the NDPR. We shall also agree on appropriate actions to compensate for the breach within a month of notifying you.
CHANGES TO OUR PRIVACY STATEMENT
By submitting Your information, You consent to the use of that information as set out in this Privacy Policy. SEL Cap reviews its Privacy Policy and strive towards making it better and itis in this regard that We reserve the right to amend this Privacy Policy occasionally. If We make any changes in the way We retrieve and share Personal Data, You will be notified of the changes on Our website. We will not reduce any of Your rights stated in this Privacy Policy without asking for explicit prior consent to the changes. It is advisable to check this page occasionally to be enlightened about any changes in this privacy notice.
HOW TO CONTACT US FOR REQUESTS, COMPLAINTS AND DISPUTERESOLUTION
If you have any complaints regarding this privacy policy, please contact us at dpo@stillearthcapital.com. We will investigate and work on resolutions for complaints and disputes regarding the use and disclosure of personal information within a reasonable time, in accordance with this privacy policy and applicable data protection laws. All access requests, questions, comments, complaints, and other inquiries regarding the privacy policy should be made by emailing us at dpo@stillearthcapital.com. We may also request additional details from you regarding your complaints and keep records of your requests and resolutions.
