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Our Policy
Infonage Marketing Hub

Website Privacy Policy

Version 1.0

Public


Infonage Marketing Hub
NO.2 GBODU POWERLINE, IKORODU +234, NG
Public · Website Privacy Policy


Website Privacy Policy

1. Purpose

Infonage Marketing Hub (“The Company”) is committed to protecting your Personal Information
when you use our website, products, and services. We recognize that when you choose to provide
us with information about yourself, you trust us to treat it in a responsible manner.

The purpose of this Website Privacy Policy is to inform you about how the Company may use your
Personal Information.

In order to optimize the provision of our services to you and to facilitate some of our marketing
efforts, we collect certain specific information about you.

This Website Privacy Policy explains the following:

- what information we may collect about you;
- how we will use the information we collect about you;
- whether the Company will disclose your details to anyone else;
- where we might send your information;
- the use of cookies on the Company’s websites; and
- how you can reject cookies.

The Company uses all Personal Information that you provide to us or that we collect from you in
accordance with all applicable laws, including those concerning the protection of Personal
Information such as the EU General Data Protection Regulation.

2. Definitions

In this privacy policy, the following definitions are used:

GDPR: the General Data Protection Regulation (“GDPR”) is a regulation in EU law on data
protection and privacy in the European Union (EU) and the European Economic Area (EEA). It also
addresses the transfer of personal data outside the EU and EEA areas. The primary aim of the
“GDPR” is to give control to individuals over their personal data and to simplify the regulatory
environment for international business by unifying the regulation within the EU.

Data Protection Law: all legislation and regulations in force from time to time regulating the use of
personal data and the privacy of electronic communications including, but not limited to, EU
Regulation 2016/679 (the“GDPR”), the Data Protection Act 2018, and any successor legislation or
other directly applicable EU regulation relating to data protection and privacy for as long as, and to
the extent that, EU law has legal effect in the UK).

Encryption or encrypted data: The most effective way to achieve data security. To read an encrypted
file, you must have access to a secret key or password that enables you to decrypt it. Unencrypted
data is called plain text.

ICO: Information Commissioner’s Office. The supervisory authority for data protection in the UK.
Personal Data: any information relating to an identifiable person who can be directly or indirectly
identified from that information, for example, a person’s name, identification number, location, or online
identifier. It can also include pseudonymized data. The terms Personal Data and Personal
Information is used interchangeably within this policy.

Personal Data Breach: a breach of security leading to the accidental or unlawful destruction, loss,
the alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise
processed.

Special Categories of Personal Data: This data needs more protection because it is sensitive. It
includes data that relates to an individual’s health, sexual orientation, race, ethnic origin, political
opinion, religion, and trade union membership. It also includes genetic and biometric data (where
used for ID purposes).

3. Website Privacy Policy Scope

This Website Privacy Policy applies only to the actions of the Company and use of the Company’s
website.

The website may contain hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies and are also likely to use cookies. We recommend that you review these policies which will govern the use of Personal Information that you submit when visiting these websites and which may also be collected by cookies. We do not accept any liability for such third-party websites and your use of such websites is at your own risk.

4. The Collection and Use of Data

4.1. How do we collect information

This Policy relates to the Company’s use of any Personal Information collected from you via the
following services:

- Infonage Marketing Hub’s website;
- social media;
- messaging services; and
- any official email address or SMS number

4.2. What information do we collect

When you participate in, access or sign up for any of the Company’s services, activities, or online
content (including on social media and messaging applications), such as newsletters, promotions,
live chats, message boards, web, and mobile notifications or votes, we may receive Personal
Information about you.

This may include:

- your name

- email address

- postal address

- telephone or mobile number

The Company may also collect Special Categories of Personal Data. Special Category data needs
more protection because it is sensitive. In accordance with the “GDPR”, the Company will only
collect Special Category data where we have enhanced legal justification. The Company collects
the following types of special category personal data:

4.3. How will we use the information?

Depending on your use of our site, we will use your personal information for a number of purposes
including:

- To provide our services, activities, or online content, or communicate information about
them (e.g. relating to upcoming promotions or new product launches) or dealing with your
requests and inquiries.

- To provide you with better ways of accessing information from this website.

- For service administration, which means that we may contact you for reasons related to the
service, activity, or online content you have signed up for.

We collect and use your Personal Information about you for the purposes described above because
we have a legitimate business interest to do so that is not overridden by your right to have your
Personal Information is adequately protected. You do not have to provide us with any of the Personal Information described above, but if you chose not to do so, you may not be able to receive certain Company services, access certain parts of our website, or receive information from us that you have requested.

4.4. Where do we send your information

The Company may be required to transfer personal data to a country/countries around the world
including (Europe, U.S., Asia, and Africa). We will, where the country to which your data is transferred
has not been found to provide an adequate level of protection, put in place appropriate safeguards
to ensure your Personal Information is protected.

5. Cookies

6. Keeping Data Secure

6.1. Third-Party Websites

Our website links to third-party sites which we do not operate or endorse. These websites may use
cookies and collect your personal information in accordance with their own privacy policies. This
privacy policy does not apply to third-party websites and we are not responsible for third-party websites.

6.2. How do we protect your information?

We take appropriate measures to ensure that any personal information which you disclose to us is
kept secure, accurate, and up to date and kept only for so long as is necessary for the purposes for
which it is used. The security measures taken may include but are not limited to, data encryption.

7. What are your rights?

Under the “GDPR”, you have the following rights, which the Company will always work to uphold:

- Right to access - for a copy of the Personal Information we hold about you, and details about
how we are processing your Personal Information. If we provide you with access to the
information we hold about you, we will not charge you for this, unless your request is
“manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse
your request. If we refuse your request, we will tell you the reasons why.

- Right to correct - to have any inaccuracies in your Personal Information corrected.

- Right to erase - to have your Personal Information erased, or for our use of it to be restricted
(for example, if your preferences change, or if you don’t want us to send you the information
you have requested).

- Right to restrict use - the right to “block” Infonage Marketing Hub from using your data or limit
the way in which we can use it;

- Right to data portability - if we are processing your Personal Information by automated means
and on the basis of your consent (see “How do we use it?”, above), for us to provide your
personal information to you in a structured, commonly used, and machine-readable format.
You can also ask us to provide your personal information directly to the third party in this
format, and, if technically feasible, we will do so;

- Right to object - the right to object to our use of your data including where we use it for our
legitimate interests.

7.1. Right to opt-out

You can request that we stop sending you marketing materials at any time.
Electronic communications typically include an unsubscribe link that allows you to manage your
communication preferences including the ability to unsubscribe from all future marketing. If for any
reason that has not been successful please contact us using the details provided below.

7.2. How to contact us

This Website Privacy Policy should tell you everything you need to know, but you can always
contact us to ask any questions or if you wish to exercise any of your rights in relation to your
Personal Information, using the contact information below:

- Email address: support@infonagemarketinghub.net
- Postal address: P.O. Box 104101

You have the right to make a complaint to the supervisory authority if you are unhappy with how
we’ve handled your Personal Information. In the UK, the supervisory authority is the Information
Commissioner’s Office (http://www.ico.org.uk).

8. Policy Governance

Responsibility for the Website Privacy Policy rests with Uko Anselem Inyang. Duties include, but are not limited to:

- Ensuring that all staff in scope and appropriate external parties have read and confirmed their
acceptance of the latest version of this policy

- Monitoring for legal, regulatory, or industry best practice developments in relation to this
policy

- Coordinate with senior management, IT, and legal counsel to communicate and review issues
related to this policy

- Review and update this policy at least every 12 months, in order that it remains fit for purpose

Exceptions to this policy shall be allowed only if previously approved by Uko Anselem Inyang.

This policy has been approved by senior management and is effective from 17-Oct-2022.