POLICY STATEMENT

Who We Are?

Estuary Business Solutions (EBS) Limited is a Nigerian-based business consulting and technology services company with experience and comprehensive capabilities across diverse business functions. EBS collaborates with clients to support their strategic objectives of transformation into high-performance businesses. EBS delivers insights and puts them into action through the following service lines: Customer Relationship Management, Finance and Performance Management, Talent and Organisation Performance, Strategy, and Supply Chain Management.

Personal Data

Under the Nigeria Data Protection Regulation /Act (NDPR/NDPA) personal data is defined as:
“Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, 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.”

How We Use Your Information

This Privacy Policy tells you how we, Estuary Business Solution Limited, will collect and use your personal data for relationship management, profiling, business analytics/development, communication, registration, cookies, and all-round efficient service delivery.

How Will Estuary Business Solution Limited Use the Personal Data It Collects About Me?

We will process (collect, use and store) the information you provide in a manner that complies with the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation/Act (NDPR/NDPA). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Estuary Business Solution Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. The retention period for certain kinds of personal data may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

What Personal Data Do We Need?

The personal data we collect and process varies depending on your interaction with our services, products, and website. The categories of data, along with their typical sources, are outlined below.

Special Category / Sensitive Data: We do not intentionally collect sensitive personal data (e.g., race, ethnicity, religious beliefs, health data, biometric data) unless legally required and with your explicit consent. If such processing is necessary, we will provide clear information and obtain your affirmative consent.

Why Do We Need the Data?

We need to collect your personal data in order for us to provide you with our services. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose(s) only, and will in no way invade your privacy. If there is a need to use your personal data for marketing purpose, Estuary Business Solution Limited will ensure to seek additional consent from you. Estuary Business Solution Limited shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:

Consent

Estuary Business Solution Limited requires your explicit consent to process collected personal data. And by consenting to this privacy policy, you are giving us the permission to use/process your personal data specifically for the purpose identified before collection.
If, for any reason, Estuary Business Solution Limited is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.
You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the Estuary Business Solution Limited Withdrawal of Consent Procedure.

Disclosure: Will Estuary Business Solution Limited Share My Personal Data with Anyone Else?

Estuary Business Solution Limited may pass your personal data to third-party service providers contracted by us. Any third parties that we may share your personal data with is under an obligation to secure your details, and use them only to fulfil the service for which they were contracted. When they no longer need your details to fulfil this service, the data will be disposed in line with the Estuary Business Solution Limited’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are required to do otherwise, legally.
Where there is a need for a third party to process the personal data of data subjects, Estuary Business Solution Limited will enter into a Data Processing Agreement with the third party and be satisfied that the third party has adequate measures in place to protect the data against accidental or unauthorised access, use, disclosure, loss, or destruction.
In a case where the disclosure is to third parties outside the jurisdiction of the GDPR and NDPR/NDPA, Estuary Business Solution Limited will ensure that the third party meets the core regulatory standards prior to the transfer. This may include transferring the personal data to the third party where Estuary Business Solution Limited has satisfied that:

• the country of the recipient has adequate data protection controls established by legal or self-regulatory regime
• Estuary Business Solution Limited has a contract in place that uses existing or approved data protection clauses to ensure adequate protection
• Estuary Business Solution Limited is making the transfer under approved binding corporate rules
• Estuary Business Solution Limited is relying on approved codes of conduct or certification mechanisms, together with binding and enforceable commitments in the foreign country or international organisation to apply the appropriate safeguards in relation to data subject rights
• Provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority

Retention of Records

In compliance with the NDPR/NDPA data retention policy, Estuary Business Solutions Limited will process your personal data for the duration of the service contract" or as long as necessary to fulfil the purposes outlined in our privacy policy and will retain the personal data for a maximum of 5 years after the conclusion of the service relationship unless otherwise required by law.
This retention period has been established to enable us use the personal data for the necessary legitimate purposes identified, in full compliance with the legal and regulatory requirements. When we no longer need to use your personal information, we will delete it from our systems and records, and/or take steps to encrypt/anonymised it to protect your identity as the case may be.

Data Subject Rights

According to the provision of the GDPR/NDPR/NDPA, data subject has certain rights at any point while Estuary Business Solution Limited are in possession of or processing your personal data, you, the data subject, have the right to:

• Request a copy of the information that we hold about you
• Correct the data that we hold about you that is inaccurate or incomplete
• Right to rectify inaccurate data
• Ask for the data we hold about you to be erased from our systems/record
• Restrict processing of your personal data where certain conditions apply
• Have the data we hold about you transferred to another organisation
• Object to certain types of processing like direct marketing
• Object to automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling
• Right to Lodge Complaint to the Supervisory Authority (Nigeria Data Protection Commission) at Info@ndpc.gov.ng

Can I Find Out the Personal Data That Estuary Business Solution Limited Holds About Me?

Estuary Business Solution Limited, at your request, can confirm what information we hold about you and how it is processed. If we do hold your personal data, you have the right to request the following information:

• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• Information about interests, if the processing is based on the legitimate interests of Estuary Business Solution Limited or a third party.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• Information about how we intend to securely transfer the personal data to a third party or international organisation. The Attorney General of the Federation will approve sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if you didn’t provide it directly.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Data Security

All information you provide to us is stored on our secure Server.
We implement appropriate, generally accepted technical and organisational measures to protect your personal data such as (firewalls, password access and encryption methods) against unauthorised or unlawful Processing, accidental loss, destruction, or damage.
Unfortunately, the transmission of information via the Internet is not completely secure. We will do our best to protect your personal information, but we cannot guarantee 100% security of your data transmitted to our servers using the internet and any transmission is at your own risk.
Under what circumstances will the Estuary Business Solution Limited contact me? We do not intend to be intrusive, and we will not ask irrelevant or unnecessary questions. Moreover, we will subject the information you provide to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Complaints

If for any reason you wish to make a complaint about how Estuary Business Solution Limited (or any of our third parties) processes your personal data, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and the Data Protection Officer of Estuary Business Solution Limited.
Below are the details for each of these contacts: