VDT Communications Ltd (VDT) including its associated companies values the confidentiality of personal data. This document details how the VDT uses and protects personal data for the purpose of obtaining the consent of data subjects, in accordance with the Nigeria Data Protection Regulation (NDPR) and other relevant privacy and data protection laws in Nigeria. This Privacy Notice also details how we collect and process your personal data when you interact with us, typically through the use of our website and social media pages (our “Online Channels“); or when you visit, interact with or use any of our offices and other offline activities (our “Offline Channels“). We have also detailed here what rights you have as a data subject under applicable laws. Note that this Privacy Notice does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal data is subject to different privacy notices which are provided to such individuals in the context of their employment or working relationship with us. Please read this document carefully to ensure informed consent. We take your privacy seriously and we will not abuse your trust by disclosing, exporting, or dealing with your personal data in a manner that is contrary to this Privacy Notice.
VDT collects, uses, processes, stores and retains Personal Data when reasonable and necessary to perform its business processes effectively, safely and efficiently and in accordance with corporate policies. In particular, VDT will collect your data in order to provide you with access to our Internet Access Service. Personal information will at all times only be used for specific purposes, and the individual is aware of the information collected and what it will be used for. Personal information may also be used for secondary purposes (processing beyond initial collection purposes), provided this further processing is disclosed to the individual or juristic entity. Consent will be gained for marketing purposes.
VDT collects, uses, processes, stores and retains Personal Data when reasonable and necessary to perform its business processes effectively, safely and efficiently and in accordance with corporate policies. In particular, VDT will collect your data in order to provide you with access to our Internet Access Service. Personal information will at all times only be used for specific purposes, and the individual is aware of the information collected and what it will be used for. Personal information may also be used for secondary purposes (processing beyond initial collection purposes), provided this further processing is disclosed to the individual or juristic entity. Consent will be gained for marketing purposes.
Data subjects are primarily responsible for ensuring that all personal data submitted are accurate, complete and up-to-date. From time to time, VDT may request updated data; it is important that data subjects cooperate and provide the same. VDT will take reasonable measures to ensure that all personal information under its control is complete, accurate, and will offer individuals various platforms and opportunities to update their personal information and exercise any other rights that they may have under applicable information privacy laws. Note that if you submit any Personal Data that is not your own, you represent that you have the authority to do so and to permit us to use that Data in accordance with this Privacy Notice.
Where we need to process your Personal Data for additional purposes that we have not identified at the time of collection, we will make sure to obtain your consent for these additional uses to the extent required by applicable law.
Here, we have set out the relevant bases upon which we process your Personal Data. For ease of reference we have colour-coded the processing bases as follows: “Green” means most likely to be a relevant processing basis; “Orange” means may be a relevant basis and “Red” means unlikely to be a relevant processing basis.
The primary basis for processing your Personal Data is consent. When you visit our website, you will see a clear and unambiguous display of this Privacy Notice with a link to access and review the same. Before you can use our website, you will have to click a “Yes” or an “I Agree” button. By clicking the “Yes” or “I Agree” button, you consent to the collection and use of your Personal Data in accordance with this Privacy Notice. Note that once you provide consent, you may change your mind and withdraw the consent at any time by contacting us at info@vdtcomms.com However, please note that consent withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent.
We may also process your information on the basis that we need to perform and fulfill a contract with you for the provision of insurance and other services or to take steps at your request prior to entering a contract. So, for instance, where you need to obtain insurance policy (of whatever type), we may provide your Personal Data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign, as necessary for the proper execution of processes related to the provision of the insurance policy; and where the use or disclosure is reasonably necessary, required or authorized by or under relevant laws or contracts.
We may process your Personal Data where it is necessary to respond to a lawful request from a law enforcement or regulatory authority, body or agency; in the defense of legal claims or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of any of our website’s terms.
We may process your Personal Data where it is necessary to protect an interest which is essential for your life, health, and bodily safety. For clarity sake, please note that this basis is limited in scope and will come into play in matters of life and death, for instance where we have not obtained your consent (because you are physically or legally incapable of giving it) or have any other appropriate legal basis for processing your personal data and We have to manage a situation of emergency medical care involving you. We will not rely on this basis where you expressly refuse consent (unless you are not competent to do so).
We may process your information where it is necessary for the performance of a task carried out in the public interest or in order to fulfil a public mandate imposed on us.
As a general rule, VDT does not and will not share Personal Data with third parties except as necessary for the proper execution of processes related to the provision of Internet Access Service, or the use or disclosure is reasonably necessary, required or authorized by or under law. Also, for operational efficiency and record-keeping, we share your Personal Data with our industry association and/or industry regulator. We may also share your Personal Data with our potential and current financiers and financial investors, and in connection with, or during due diligence or and negotiations of, any proposed or actual financing, merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of VDT; or if we are duty bound to disclose or share your Personal Data in order to fulfil any legal requirements, or in order to administer or enforce customer agreements and applicable terms and policies. When we share your Personal Data with third parties, we require those third parties to enter into a Third-Party Data Processing Contract with us that requires them to use the Personal Data we transfer to them in a manner that is consistent with this Privacy Notice and applicable laws.
VDT strictly enforces its Privacy Notice. It has implemented technical, organisational and physical security measures to protect Personal Data from loss, misuse, unauthorized modification, unauthorized or accidental access or disclosure, alteration or destruction. VDT uses safeguards such as the following: *Use of secured servers and firewalls, *Encryption on computing devices; *Restricted access only for qualified and authorized personnel; and *Strict implementation of information security policies.
VDT stores Personal Data in both local and remote facilities, such as data centres (on premises and cloud) and physical document storage facilities. Records will only be kept for such time as the individual or juristic entity has a relationship with VDT or as required by law or to support a business need, following which they will be archived or securely disposed of. Related to this, 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.
Data subjects have the following rights: *Right to be informed; *Right to object; *Right to access; *Right to rectify or correct erroneous data; * Right to restrict, in certain circumstances, the processing of your Personal Data; *Right to have your Personal Data erased from our systems; *Right to indemnify for damages; *Right to file a complaint; *Right to make a complaint to the relevant authority; and *Right to withdraw your consent. You may exercise any of the above rights by emailing us at info@vdtcomms.com . Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can’t comply with your request, we will inform you of the reasons why.
Sometimes we will process your personal information in other countries, either to carry out your instructions or for ordinary business purposes. These countries may not have the same level of protection. We will only process your personal information with your consent. If necessary, we will ask the party to whom we transfer your personal information to agree to our privacy principles, associated policies and practices. We will specifically check and confirm if applicable countries are in the National Information Technology Development Agency (NITDA) WHITE LIST in line with the NDPR 2019 and its associated Implementation Framework.
We use cookies and other tracking technologies on some parts of our website. A cookie is small pieces of text that are saved on your Internet browser when you use our website. The cookie is sent back to our computer each time you visit our website. Cookies make it easier for us to give you a better experience online. You can stop your browser from accepting cookies, but if you do, some parts of our website or online services may not work appropriately. We recommend that you allow cookies. Please read our cookies policy.
You have a right to complain to the National Information Technology Development Agency (NITDA) at any time if you object to the way in which we use your personal information, but we ask that you please contact us first to see if we can provide you with an adequate remedy.
You can contact us at any time. Should you have any enquiries, feedback, and/or complaints, you may reach the Data Protection Officer (DPO) through the following contact details: Data Protection Officer, VDT Communications Ltd, 1 Alfred Rewane, Road, Falomo, Ikoyi, Lagos, Nigeria. Tel: 09062943032 E-mail: Internal_Audit@vdtcomms.com
This Privacy Notice is effective as of the date indicated above and will so remain except with respect to any changes in its provisions in the future, which will become effective immediately after being posted on this page. We reserve the right to update or change our Privacy Notice at any time and you should check this page periodically. If we make any material changes to this Privacy Notice, we may notify you either through the email address you have provided us, or by placing a prominent notice on our website or other Online Channels.