Data Privacy Policy
1. Scope
All data subjects whose
Personal
Data
is collected, in line with the requirements of the
Nigeria Data Protection Regulation
(“NDPR”).
This Privacy Policy (“Policy”) describes what personal information
the
Fast Moving Consumer Goods Distributions Ltd
(“FMCG”) collects,
what
the FMCG
does with it, how
the FMCG
protects it and how
the FMCG
maintains information collected from Users.
We are
a
Data
Controller
-
meaning
that we
determine the purposes for and manner in which Personal Data is processed or is
to be processed.
2. Responsibilities
2.1. The assigned Data Protection Officer is responsible for ensuring that this
notice is made available to data subjects prior to the Fast Moving Consumer
Goods Distributions Ltd
(“FMCG”)
collecting/processing their
Personal
Data.
2.2. All Employees/Staff of
FMCG
who interact with data subjects are responsible for ensuring that this notice is
drawn to the data subject’s attention and their consent to the processing of
their data is secured.
3. Privacy notice
3.1. Brief description of Fast Moving Consumer Goods Distributions Ltd
FMCG is a Nigerian wide distribution company, dealing with Tobacco, Alcohol and
Beverages.
Our assigned Data Protection Officer can be contacted directly via:
• Website: www.fmcgdistribution.org/dpo
• Email: dpo@fmcgdistribution.org
• Tel/WhatsApp
:
+234 (0) 9062968750
• Address:
1 Cocoa Industries Road, Ikeja, Lagos.
3.2. Consent
By consenting to this privacy notice you are giving us permission to process
your
Personal
Data
specifically for the purposes identified.
Consent
is required for
FMCG
to process both types of
Personal
Data,
but it must be explicitly given. Where we are asking you for sensitive
Personal
Data
we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting us at the details provided or
in line with Withdrawal of Consent Procedure.
3.3. Disclosure
FMCG
will not pass on your
Personal
Data
to third parties without first obtaining your consent. We do not share your
Personal
Data
without first obtaining your consent.
3.4.
Storage of your Personal Data
The
Personal
Data
that we collect from you will be transferred to and stored at destinations
within Nigeria. By submitting your
Personal
Data,
you agree to this transfer, storing or processing. We will take all steps
reasonably necessary to ensure that your
Personal
Data
is treated securely and in accordance with this Policy.
3.5.
Retention period
FMCG will process
Personal
Data
for the purposes of your
business dealings and or employment with us
and store information in line with statutory obligations.
Wherever possible
Personal
Data
will be
minimized and securely destroyed. Storage of
Personal
Data
will follow statutory retention
requirements.
3.6.
Your rights as a data subject
At any point while we are in possession of or processing your
Personal
Data,
you, the data subject, have the following rights:
·
Right of access – you have the right to request a copy of the information that
we hold about you.
·
Right of rectification – you have a right to correct data that we hold about you
that is inaccurate or incomplete.
·
Right to be forgotten – in certain circumstances you can ask for the data we
hold about you to be erased from our records.
·
Right to restriction of processing – where certain conditions apply to have a
right to restrict the processing.
·
Right of portability – you have the right to have the data we hold about you
transferred to
yourself or
another organisation.
·
Right to object – you have the right to object to certain types of processing
such as direct marketing.
·
Right to object to automated processing, including profiling – you also have the
right to be subject to the legal effects of automated processing or profiling.
·
Right to judicial review: in the event that
FMCG
refuses your request under rights of access, we will provide you with a reason
as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party
involved in the processing of your
Personal
Data.
3.7.
Complaints
In the event that you wish to make a complaint about how your
Personal
Data
is being processed by FMCG
(or third parties as described in 3.3
above), or how your complaint has been handled, you have the right to lodge a
complaint directly with the supervisory authority and FMCG data protection
representative the assigned Data Protection Officer / NDPR Owner, details as in
3.1.
We will investigate and attempt to resolve complaints and disputes regarding use
and disclosure of personal information within thirty (30) days in accordance
with this Privacy Policy and in accordance with applicable law and regulation.
3.8.
Online privacy statement
3.8.1.
Personal
Data
Under the NDPR,
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”.
3.8.2.
How we use your information
This privacy notice tells you how we,
FMCG,
will collect and use your
Personal
Data.
We acquire and use information relating to commercial organisations and
individuals for a variety of reasons:
1. Delivery of our
goods and or
services
2. Communications
3. Legal obligations
4. Marketing purposes
5. Human resources ( Employment )
If you are requested to provide us with
Personal
Data
you can of course refuse. If you choose not to provide the
Personal Data
that we require to provide our
goods and or
services then we may not be able to deliver that service for you.
If you choose not to provide the
Personal Data
that we require to provide
employment
then we may not be able to
employ
you.
FMCG
will not share with other parties, information which you may provide when using
the Site, except to the extent necessary to provide
services
to you, further, to obtaining your consent.
3.8.3.
The
Personal
Data
collected from you
are as follows:
Contact data:
We will request your full name, address, phone number and e-mail address.
Special category data:
We may request on occasion such
Personal Data
about you that may be necessary to facilitate the execution of our services
or in suppling us services or goods or in the course of employment with us,.
This maybe
Personal Data
such as your
NIN, Criminal records,
current health for a vulnerability assessment.
Payment data:
Where it is necessary to process your payment, if you are
making payment
for
goods or
services supplied to you, then sensitive information, such as your
bank account
number,
TIN,
maybe
stored.
Business and relationships:
We may collect such
Personal
Data
that you provide to us relating to your contacts and business relationships.
Content:
We may collect the content of any data files and communications that you may
send us for the purposes of carrying out
our dealings with you,
together with any relevant physical documents that you may give us as well, when
these are necessary to provide you with the offered service
and or employment.
Data we collect may include but not limited to:
·
address, subject line and body of an email
·
video and/or audio recording of a video message
·
written content of a text, similar app or other content of an instant message
·
relevant social media messages
We may also collect
Personal Data
that you provide us with regards to client feedback for services provided. This
Personal Data
will be retained in line with our retention policy.
The
Personal
Data
we collect will be used for the following purposes but not limited to:
·
To carry out our business activities
·
To enforce using the appropriate legal process
·
Update existing
Personal Data
·
Manage our products and services
·
Monitor and keep records of communications
·
To improve the operations of our business where possible
·
To comply with legal and regulatory obligations and requirements
Our legal basis for processing
Personal
Data:
·
To provide products and services
·
To receive products and services
·
Legitimate interests
·
Vulnerability assessments
·
Public interest matters
·
To comply with legal and regulatory obligations and requirements
·
To offer employment
Any legitimate interests pursued by us, or third parties we use, are as follows:
·
Develop business partnerships
·
To comply with legal and regulatory obligations and requirements
3.8.4.
Need to collect and store
Personal
Data
In order for us to provide you with the
goods and
services we offer we need to collect
Personal
Data
for:
·
General
Personal Data
processing: though we do not undertake automated decision making or profiling of
Personal
Data.
·
Legitimate Business requirements
·
Perform contractual and payment obligations
·
Meet legal obligations and requirements
In order for us to provide you with
employment
we need to collect
Personal
Data
for:
·
Human resources requirements.
·
Background checks
In any event, we are committed to ensuring that the
Personal Data
we collect and use is appropriate for this purpose, and does not constitute an
invasion of your privacy.
3.8.5.
Sharing
Personal
Data
Any third parties that we may share your data with are obliged to keep your
details securely, and to use them only to fulfil the service they provide you on
our behalf. When they no longer need your data to fulfil this service, they will
dispose of the details in line with FMCG 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 legally required to do otherwise.
We do not sell, trade, or rent Users
Personal
Data
to others.
3.8.6.
Use of
Personal
Data
FMCG will process (collect, store and use) the
Personal
Data
you provide in a manner compatible with the Nigeria Data Protection Regulation
(NDPR). We will endeavour to keep your
Personal
Data
accurate and up to date,
and not keep it for longer than is necessary. Personal
Data
may be held in addition to these periods depending on individual business needs.
3.8.7.
The
Personal
Data
that FMCG
holds about you
If FMCG
does hold
Personal
Data
about you, you can request the following
Personal
Data:
• Identity the contact details of the person or organisation that has determined
how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of FMCG
or a third party,
Personal
Data
about those interests.
• The categories of
Personal
Data
collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed
to.
• If we intend to transfer the
Personal
Data
to a third country or international organisation,
Personal
Data
about how we ensure this is done securely.
• The National Information Technology Development Agency (NITDA) has approved
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
Personal
Data.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such
processing.
•
Personal
Data
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 it wasn’t collected directly from you.
• 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.
3.8.8.
What forms of ID will I need to provide in order to access this?
FMCG
accepts:
Passport Photograph
National ID Card
Driver's License
Nigerian International passport
4. Cookie Policy
Our website does use cookies for the purposes of analytics. A detailed outline
of cookies is listed below:
4.1. About cookies
A cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a page
from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set
expiry date, unless deleted by the user before the expiry date; a session
cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.
4.2. Cookies that we do and do not use
We do and do not use cookies for the following purposes:
(a) authentication - we do not use cookies to identify you when you visit our
website and as you navigate our website
(b) status - we do not use cookies to help us to determine if you are logged
into our website
(c) personalisation – we do not use cookies to store Personal Data
about your preferences and to personalise the website for you
(d) security - we do not use cookies, as an element of the security measures
used to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally, as we do not
have these credentials located anywhere
(e) advertising - we do not use cookies to help us to display advertisements
that will be relevant to you
(f) analysis - we
may
use cookies to help us to analyse the use and performance of our website and
services. Cookies used for this purpose
would be
listed below
(g) cookie consent - we
may
use
cookies
to store your preferences in relation to the use of cookies more generally.
4.3. Cookies used by our service providers
Our service providers
may use
cookies and those cookies may be stored on your computer when you visit our
website.
We use Google Analytics to analyse the use of our website. Google Analytics
gathers i Personal Data about website use by means of cookies. The Personal Data
gathered relating to our website is used to create reports about the use of our
website. Google's privacy policy is available at:
https://www.google.com/policies/privacy/.
4.4. Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date Personal Data about blocking and deleting
cookies via these links
( for popular web browsers ):
• https://support.google.com/chrome/answer/95647?hl=en (Chrome);
•
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-websitepreferences
(Firefox);
• http://www.opera.com/help/tutorials/security/cookies/ (Opera);
•
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorerdelete-manage-cookies
(Internet Explorer);
• https://support.apple.com/kb/PH21411 (Safari); and
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
Blocking all cookies will have a negative impact upon the usability of many
websites. If you block cookies, you may not be able to use all of the features
on our website.
Our Privacy Policy may change from time to time. We will not reduce your rights
under this Policy without your explicit consent. We will post any privacy policy
changes on this page and, if the changes are significant, we will provide a more
prominent notice (including, for certain services, email notification of privacy
policy changes) or via a pop-up notice or statement of changes on our website)
You acknowledge and agree that it is Your responsibility to review this Policy
periodically and become aware of modifications. This Privacy Notice or Policy
was last updated on
March
22,
2021.
The most up-to-date version can be found on this website.
This Privacy
Policy is in line with the provisions of Nigeria Data Protection Regulation,
2019 (Regulation),
a regulation which
describes
how organisations including
the
FMCG
must collect, handle and store
Personal
Data
and applies regardless of whether data is stored electronically, on paper or on
other materials.
According to the Regulation, FMCG shall notify NITDA within 72 hours of
knowledge of a breach of security leading to accidental or unlawful destruction,
loss, alteration unauthorized disclosure of, or access to your Personal Data.
If you feel that your Personal Data has not been handled correctly or you are
unhappy with our response to any requests you have made to us regarding the use
of your Personal Data, you have a right to lodge a complaint with the NITDA. The
contact details are:
National Information Technology Development Agency
Tel: +234929220263, +2348168401851, +2347052420189
Email: info@nitda.gov.ng