PRIVACY POLICY

INTRODUCTION

Balogun Harold respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

TABLE OF CONTENTS

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

1(a)  WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?

Balogun Harold is an investment and finance law firm structured along select industry sector expertise. Balogun Harold undertakes debt finance, private funds & private equity/strategic investment deals on behalf of foreign investors and lenders doing business in Nigeria

This privacy policy aims to give you information on how Balogun Harold collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletters, send us an inquiry, take part in our events or communicate with us otherwise.

This website is not intended for children and we do not knowingly or intentionally collect data relating to children.

It is important that you read this privacy policy together with any legal notices and our cookie policy and any other fair processing policy we may provide when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

1(b)  WHO IS THE CONTROLLER?

Balogun Harold is the controller of the personal data you submit to us and responsible for your personal data under applicable data protection law (collectively referred to as “Balogun Harold”, “we”, “us” or “our” in this privacy policy).

You have the right to make a complaint at any time to your jurisdiction’s supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach your jurisdiction’s supervising authority so please contact us in the first instance at Balogun Harold

1(c)  CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. 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.

1(d)  DOES THIS WEBSITE CONTAIN 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.

  1. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

Personal data or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Dataincludes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Dataincludes billing address, delivery address, email address and telephone numbers.
  • Transaction Dataincludes details about payments to and from you and other details of services you have received from us.
  • Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes any username and password, your interests, preferences, feedback and survey responses.
  • Usage Dataincludes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for the purpose of analyzing web traffic and functionality of our website. Aggregated Data could be derived from 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 with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.

WHAT HAPPENS IF YOU FAIL TO PROVIDE PERSONAL DATA?

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions.You may give us your personal data when filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • make an inquiry or engage our services;
  • subscribe to our newsletters or publications;
  • request marketing materials be sent to you;
  • register to attend our events and provide your contact information; or
  • give us feedback or contact us.
  • Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy below for further details.
  • Third parties or publicly available sources.We will receive personal data about you from various third parties and public sources as set out below
  • Technical Data from analytics and search information providers, such as Google;
  • Contact and Transaction Data from providers of technical, payment and delivery services such as based inside or outside the EU.
  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have given consent for our use in a specific purpose
  • Where we need to perform a contract we are about to enter into or have entered into with you. [See below meaning of Performance of Contract].
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. [See below meaning of Legitimate Interest].
  • Where we need to comply with a legal obligation. [See below meaning of Legal Obligation].

Consent means freely given, specific, informed and unambiguous indication that you wish to allow us process your data.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data where the law allows us. However, we will get your consent before sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at support@balogunharold.com

4(a) WHAT ARE THE PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA?

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new client

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To enable you to partake in or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests (to study how customers use our content and services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

 

Necessary for our legitimate interests (to develop our services and grow our business)

 

 

4(b)  HOW DO WE USE YOUR PERSONAL DATA FOR MARKETING?

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and information may be relevant to send you (we call this marketing).

You will receive marketing communications from us if you have subscribed to our mailing list and expressly consented to receive information such as our newsletters, events, news and updates.

4(c)  CAN YOU WITHDRAW YOUR CONSENT FROM RECEIVING MARKETING MATERIALS? 

If you receive marketing materials relating to our services by email, you may withdraw your consent for us to send these to you at any time, by clicking the “unsubscribe” option included in the marketing email. Alternatively, you can let us know your preferences by sending an email to support@balogunharold.com

4(d)  DO WE SHARE YOUR PERSONAL DATA FOR THIRD-PARTY MARKETING?

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4(e)  HOW CAN YOU OPT OUT OF RECEIVING MARKETING MESSAGES?

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links and instructions on any marketing emails sent to you or by contacting us at any time at support@balogunharold.com

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of engaging our services or other transactions.

4(f)  HOW CAN YOU DISABLE OR REFUSE COOKIES?

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click to read our cookie policy below

4(g)  WHAT IF THERE IS A CHANGE OF PURPOSE FOR OUR USE OF YOUR PERSONAL DATA?

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. WHAT THIRD PARTIES MAY WE DISCLOSE YOUR PERSONAL DATA?

We may share your personal data with the parties set out below for the purposes set out in the table above on “Purposes for which We Will Use Your Personal Data” above.

  • Internal Third Parties,which are other entities within Balogun Harold acting as joint controllers and who provide IT and system administration services and undertake leadership reporting.
  • External Third Partieswhich are:
  • Service providers, acting as processors, who provide IT and system administration services.
  • Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. HOW DO WE HANDLEINTERNATIONAL TRANSFERS OF YOUR DATA?

Whenever we transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented.

Where we use certain service providers, we will only use providers which give personal data the same degree of protection required under the Nigerian laws whilst adopting global standards in data privacy regulation

  1. DO WE HAVE DATA SECURITY IN PLACE?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to 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 unauthorised 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.

In some circumstances you can ask us to delete your data: see section on “YOUR LEGAL RIGHTS” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. WHAT ARE YOUR LEGAL RIGHTS?

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at support@balogunharold.com

9(a) WHAT MAY WE NEED FROM YOU?

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9(b) WHAT IS THE TIME LIMIT IN WHICH WE ARE TO RESPOND?

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Cookies and similar technologies

Balogun Harold and our third-party providers set and use cookies and similar technologies to store and manage user preferences, deliver targeted advertising, enable content, and gather analytic and usage data, for example. The use of cookies and other tracking technologies is standard across websites and apps through which information is collected about your online activities across applications, websites, or other services. More information about how we use cookies and similar technologies and how you can control and manage them is below.

What is a cookie?

A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.

Types of cookies and why we use them

Absolutely necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, you may not be able to access some of our services

Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies only collect information in an aggregated format. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.

Functionality cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide our services you have asked for, such as watching a video or commenting on a blog. These cookies cannot track your browsing activity on other websites.

Targeting and advertising cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.

Managing cookies

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on our website. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.

We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org  or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:

We use certain other tracking technologies in addition to cookies:

  • Local shared objects/Flash cookies: Flash cookies, also known as local shared objects, are designed to support browser content supported by Adobe® Flash. They are usually used to enable ads and video content on websites. Like other cookies, they will store information on your device, some of which will be specific to the Flash-enabled content. Flash cookies can only be deleted within Adobe Flash rather than via your browser. Please refer to the following help page for information on how to manage your privacy settings and deletion of Flash cookies: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
  • Web beacons: Our web pages may contain electronic images known as web beacons (also called single-pixel gifs and transparent graphic images) that we use to help deliver cookies on our sites, count users who have visited those sites, deliver Services, and analyze the effectiveness of our promotional campaigns, for example. We may also include web beacons in our marketing email messages or newsletters to determine whether an email is opened or if links are clicked. Web beacons are also used to deliver you interest-based advertising.
  • Web server & application logs: Our servers automatically collect certain information to help us administer and protect our services, analyze usage, and improve users’ experience. The information collected includes:
    • IP address and browser type
    • Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
    • Device operating system and other technical facts
    • The city, state, and country from which you access our website
    • Pages visited and content viewed, stored, and purchased
    • Information or text entered
    • Links and buttons clicked
    • URLs visited before and after you use our Services

“Do Not Track” Signals

Some browsers transmit Do Not Track (DNT) signals to websites. Due to the lack of a common interpretation of DNT signals throughout the industry, we do not currently alter, change, or respond to DNT requests or signals from these browsers. We continue to monitor industry activity in this area and reassess our DNT practices as necessary.

Connecting via social networks

Some of our services may include social networking features, such as the Facebook® “Like” button and widgets, “Share” buttons, and interactive mini-programs. Additionally, you may choose to use your own social networking logins from, for example, Facebook or LinkedIn®, to log into some of our services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with our Services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for our services and do not participate in social sharing of any content form our website

CONTACT US

If you have any questions about this Privacy Policy, please contact us at: support@balogunharold.com

 

 

error: Content is protected !!