Privacy Policy

INTRODUCTION

At Loyalty Solutions Limited (“LSL”, us, we, the Company), we are committed to maintaining the confidentiality of the Personal non-public Data (“Personal Data ”) entrusted to us by our clients, employees and other individuals.

Our privacy policy describes our practices and policy for the collection of Personal Data, usage, processing, storage and disclosure of data. This deals with Personal Data in all forms – written, spoken, electronic or printed – which is protected from unauthorized usage on all occasions.

LSL’s approach is to work closely with Data Subjects so that we can support compliance with privacy laws and Data Subjects’ confidentiality requirements as part of the provision of our services.

1.      CONSENT

 

You accept this Privacy Policy and hereby give us consent to save, process and use your Personal Data to the extent as allowed by law when you provide us with details of your Personal Data or by clicking on the “accept” button.

 

You may withdraw your consent at any time before, during and after we process your Personal Data.

2.      LEGAL & REGULATORY OBLIGATIONS

LSL abides by the Nigeria Data Protection Regulation (“NDPR”) regulations for the purpose of handling and protecting our own data and Data Subjects’ Personal Data.

LSL uses the regulator’s policy to improve privacy requirements as it relates to how we collect, use, process, store and disclose Personal Data. Personal Data means any information relating to an identified or identifiable natural person (Data Subject). For example, this may include name, 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. 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.

3.      INFORMATION WE COLLECT

We may collect the following types of Personal Data:

·       name;

·       address;

·       email address;

·       telephone number and other contact details;

·       gender;

·       any other personal or additional information that may be required in order to facilitate your dealings with us.

We may also collect your Personal Data when you:

•      communicate with us through correspondence, chats, emails, or when you share information with us from other social applications;

•      interact with our sites, services, contents and surveys.
4.      WHY WE COLLECT, USE AND PROCESS PERSONAL DATA

We collect and process your Personal Data only as necessary or appropriate for business purposes.

There are certain lawful bases for which we are allowed to use your Personal Data. Most commonly, we will rely on one or more of the following lawful bases for processing your Personal Data.

The legal basis for processing is based on any of the following:

I.         Consent: This will apply where you have provided your consent to the processing of your Personal Data for one or more specific purposes;

II.         Performance of contract: This will apply where processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract with you;

III.         Vital interests: This is where processing is required for the protection of your vital interests.

IV.         Compliance with legal obligation: Where we are subject to a legal obligation and need to use your Personal Data in order to comply with that obligation.

V.         Public interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public.

VI.         Legitimate Interest – means the interest of our business in conducting and managing our business to enable us to give you the best services and most secure experience.

We may also use your Personal Data:

·       to enable your use of the services available on our website or clients’ websites managed by us;

·       to send you items redeemed through websites managed by LSL;

·       to send statements, invoices and payment reminders to you, and collect payments from you;

·       to send you non-marketing commercial communications;

·       to send you email notifications that you have specifically requested;

·       to send you our email newsletter, to which you can unsubscribe if you no longer want to receive;

·       to deal with enquiries and complaints made by or about you relating to our website; and

·       to keep our website secure and prevent fraud.
We will not, without your express consent, supply your Personal Data to any third party for the purpose of their or any other third party’s direct marketing.

5.      DISCLOSING PERSONAL DATA

We may disclose Person Data for the purposes set out in this Privacy Policy to:

·       our employees;

·       third party suppliers and service providers;

·       professional advisers;

·       our existing or potential partners;

·       specific third parties authorized by you to receive information held by us;

·       fraud management agencies and law enforcement bodies;

·       regulatory or government body.