1. Introduction
This Privacy Policy (Policy) and any other document referred to sets out the basis on which any Personal Data Dinamico Consulting (“Dinamico”, “we”, “us”, “our”) collects from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. By clicking on the “accept” button, you are accepting and consenting to the practices described in this Policy. If you have any comments on this Policy, please email them to: info@dinamicoconsulting.com.ng or dinamicoconsulting@gmail.com.
2. Who We Are
Our business model operates on two main dimensions: Capacity Building & Development Services (CBDS) and Brand Support and Representation Services(BSRS). Through these interventions, we aim to provide comprehensive solutions that enhance our clients capabilities and support their brand development.
Our business addresses are:
1 st Floor, Benin Owena River Basin Development Authority House, Alagbaka, Akure, Ondo State, Nigeria.
11 th Floor, 17 Ligali Ayorinde Street, Victoria Island, Lagos State, Nigeria.
Our corporate website address is: www.dinamicoconsulting.com.ng
3. Collection of Your Personal Data
We will collect and process the following Personal Data about you:
3.1. Personal Data and content you provide.
We collect the content, communication and other Personal Data you provide when you use our services, including when you fill forms or surveys or sign up for an account, or by corresponding with us via phone, e-mail or otherwise. The Personal Data you give us may include your name, address, e-mail address, phone number, personal description and photograph.
3.2. Personal Data we collect about you.
With regard to each of your visits to our website or the use of our products, we will automatically collect the following information:
3.2.1. Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type, time zone setting, browser plug-in types and versions, operating system and platform;
3.2.2. information about your use of our website and mobile application (including date and time), details of transactions you carry out, interaction information, record of any correspondence between us and any phone number used to call our customer/client service number.
3.2.3. information about your visit(s) from your IP address, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse
overs), and methods used to browse away from the page.
3.3.3. Personal Data we receive from other sources. This information can be when you use any of the other websites we operate or the other services we provide. In this case we will inform you at the point of data collection, if we intend to share your data internally and combine it with data collected on www.dinamicoconsulting.com.ng or any of our
products’ websites.
3.4. We may collect your Personal Data when you send your CV or apply for a job application and employment.
3.5. We will also tell you for what purpose we will share and combine your Personal Data.
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive any Personal Data about you from them and the purposes for which we intend to use that Personal Data.
4. How We Use Your Personal Data
4.1. Personal data collected helps us to personalize our products according to each Data Subject’s wish and preference.
4.2. We use your Personal Data held about you in the following ways, that is,to:
4.2.1. tailor the content we display to you;
4.2.2. carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
4.2.3. provide you with information about other goods and services we provide that are similar to those that you have already purchased or enquired about;
4.2.4. notify you about changes to our service;
4.2.5. ensure that content from our product is presented in the most effective manner for you and for your computer;
4.2.6. administer our product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
4.2.7. improve our product to ensure that content is presented in the most effective manner for you and for your device;
4.2.8. allow you to participate in interactive features of our service, when you choose to do so.
4.2.9. measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
4.2.10. make suggestions and recommendations to you and other users of our product about goods or services that may interest you or them.
4.3. We will use Personal Data provided by you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer/client, we will only contact you by electronic means (call, e-mail or SMS) with information about goods and services similar to those, which were the subject of a previous sale or negotiation of a sale to you. If you are a new customer/client, and where we permit selected third parties to use your Personal Data, we (or they) will contact you by electronic means only if
you have consented to this. If you do not want us to use your Personal Data in this way, or to pass your details on to third parties for marketing purposes, you may unsubscribe from promotional emails via a link provided in each email.
5. Security
We adopt robust technologies and policies to ensure the Personal Data we hold about you is suitably protected. We take steps to protect your Personal Data from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Where you have chosen a password that allows you to access certain parts of the website and mobile application,
you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
6. Disclosure of your Personal Data
6.1. We will usually not share your Personal Data with other third parties without your consent. You agree that we have the right to share your Personal Data with:
6.1.1. any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined under the Nigerian Companies and Allied Matters Act Cap C20 LFN 2004;
6.1.2. our authorized employees only for the purpose of resolving issues associated with the use of our services;
6.1.3. selected third parties including:
6.1.3.1. business partners, suppliers or sub-contractors for the performance of any contract we enter into with them;
6.1.3.2. advertisers and advertising networks that require the Personal Data to select and serve relevant adverts to you and others. Please note that:
a. we do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users, for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day;
b. we may also use such aggregate information to help advertisers reach the kind of audience they want to target;
6.1.3.3. analytics and search engine providers that assist us in the improvement and optimisation of our corporate and products websites.
6.2. We may share your Personal Data without your consent in any of the following situations:
6.2.1. if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our, our clients and others’ rights, property, or safety;
6.2.2. where we are requested to provide your Personal Data by authorized third parties or regulatory/governmental agencies investigating illegal activities;
6.2.3. in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller
or buyer of such business or assets;
6.2.4. if we or substantially all of our assets are acquired by a third party, in which case Personal Data we hold about our clients will
be one of the transferred assets;
6.2.5. we may hold events including seminars and conferences which are sponsored by third parties or have third party speakers. Where you register for one of these events, we may share your Personal Data with those third parties;
6.2.6. we use third party payment processing services when you make payment through our website. We do not have access to any credit card or financial data processed by the third party.
7. Where we Store your Data
7.1. The Personal Data that we collect from you may be transferred to, and stored at, a destination outside 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 data is treated securely and in accordance with this Policy and the Nigeria Data Protection Act
(NDPA).
7.2. Furthermore, all Personal Data you provide to us is stored on our secure servers. Any payment transactions will be encrypted using secure sockets layer (SSL) technology. Where we have given you (or where you have chosen) a password, which enables you to access the services on our website and mobile applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8. Retention of Information
8.1. Your Personal Data will not be retained for longer than is necessary for the purposes for which it was processed.
8.2. Your Personal Data will be stored as long as you have an active client account. If your account is closed, information will be deleted from the databases in line with our retention period, unless such Personal Data is required to be retained for accounting, dispute resolution or fraud prevention purposes.
8.3. Please note that the deletion of any of our apps from your device does not cause the deletion of your Personal Data.
8.4. If any of our applications has not been used for 2 years, we will notify you and ask you to confirm whether your account is still active. If no reply is received, the account will be closed and your Personal Data will be deleted unless such Personal Data is required to be stored for accounting, dispute resolution or fraud prevention purposes.
9. Your Rights as a Data Subject
9.1. The law gives you certain rights in respect of the Personal Data we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your Personal Data.
9.1.1. You have a right to consent to this Privacy Policy and to withdraw your consent at any time.
9.1.2. You have a right to a copy of the Personal Data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.
9.1.3. You have a right to freely transfer your Personal Data received from us to any other person.
9.1.4. You have the right to have the Personal Data we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose.
9.1.5. In some circumstances, you have the right to the deletion of the Personal Data that we hold about you.
9.1.6. You have a right to lodge a complaint about the handling of your Personal Data with the Nigeria Data Protection Commission (NDPC).
9.1.7. You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes.
9.2. The NDPC website has a wealth of useful information in respect of you rights over your personal data.
9.3. If you wish to exercise your rights, you may contact the office of our data protection and compliance officer at info@dinamicoconsulting.com.ng .
10. Breach/Privacy Violation
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NDPC. Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.
11. Changes to this Policy
Any future changes we make to this Policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.
12. Note
Please note that our products or services may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to such websites.
13. Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:
info@dinamicoconsulting.com.ng or our physical offices at:
1 st Floor, Benin Owena River Basin Development Authority House, Alagbaka,
Akure, Ondo State, Nigeria.
11 th Floor, 17 Ligali Ayorinde Street, Victoria Island, Lagos State, Nigeria.