Coure Tech

Introduction/Scope

This document is prepared in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Nigerian Data Protection Regulation (NDPR). It sets out how COURE applies and complies with the principles of the regulations in processing the personal data of individuals, clients, vendors, and even third parties that interact with COURE. This privacy policy describe how we collect and process your personal information through your use of our data collection forms/website (“the site”) and the account you open with us (“Account”), to create account profile, to ensure security of the website and to enable you use our products. The primary purpose of this policy is to provide you with better understanding of:

Information we collect
How we use the data we collect
Who we share your data with
Lawful grounds of processing
Retention period
Your data right
How to contact us
How to contact the regulatory body (NDPC)
Security of the personal data we hold

Roles and Responsibilities

Roles	Responsibilities
Data Protection Officer	To ensure that this notice is correct and up-to-date, and bring this notice to the awareness of data subjects prior to the collection and processing of personal data by COURE, including on COURE’s website.
All Employees/Staff who interact with personal data	To follow the provisions of this policy document. To seek the consent of data subject(s) for the secure processing of their personal data. To ensure that this notice is brought to the attention of the data subject(s).
I.T Team	To maintain the hardware and software systems within the organisation that contains personal data of data subjects. To ensure that the website works perfectly and free from glitches.

2. Policy Statement

2.1 Who We Are

COURE Software & Systems Limited (“COURE”) is a platform services provider. Since its formation, COURE has been focused on the accurate, secure and timely provision of relevant data and the proper implementation of technology to improve its clients’ business processes and operations. COURE provides platforms that centralize data access, management and delivery in a standardized manner. Through these platforms, COURE is able to aggregate various forms and types of data, analyse the data and create services that provide value.

2.2 What Personal Data Do We Need?

The personal data we would collect and process, depending on the particular processing requirement, are under the following categories:

Personal Data Type	Sources
Bio-data: Names, Email address, mobile number	Directly from Data Subjects, website
Account Information	Directly from Data Subjects, website
Financial Information	Directly from Data Subjects, website
General Location Information	Directly from Data Subjects, website
Device name and other technical information	Website

In certain instances, the personal data we need to collect may fall under a special category of personal data, which includes: race, political opinion, ethnic origin, religion, philosophical believes, genetic/biometric data, health record, sex life/sex orientation, criminal records, or alleged criminal activity. In such instances, our lawful basis of processing will be the explicit consent of the data subject, compliance with a legal obligation, or for legal proceedings/advice.

2.3 Why Do We Need the Data?

COURE ensures that the personal data collected and processed is necessary for the purpose of collection, and COURE shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:

Purpose of Processing	Lawful Basis of Processing
To register you as a new user on the site or Apps	We need to process this information with your consent as well as to meet our contractual obligations.
To allow you to use our products	We need to process this information to meet our contractual obligations and to comply with our legal and regulatory obligations.
To communicate with you about any new update on our site, products and any changes to our terms and conditions or Privacy Policy	We need to process this data to meet our contractual obligations; to comply with our legal obligations. We also require your consent to process your data.
To receive feedback from you about our products	We need to process this data to meet our contractual obligations as well as your consent as this request helps us understand how we can improve our products and services.
To provide customer support services	We need to process this information to meet our contractual obligations to you so that you enjoy our services and your consent is also required to process your data.
For promos and giveaways to grow social media presence	This information is processed explicitly on data subjects’ consent who have participated in the competition.
Payment of staff salaries and other employee related benefits like HMO, Pension and Taxes.	We need to process this information to meet contractual obligation we both agreed on.
To train our staff (For employees that works with COURE)	It is in our legitimate interest business interest to provide you with helpful service.

Where in any situation, legitimate Interest is considered the legal basis for processing personal data, be assured that COURE shall follow the steps below in carrying out a Legitimate Interest Assessment.

i. Determine the Purpose for Processing

In carrying out the purpose test, COURE must establish the exact reason for the processing and how it benefits the organisation. Answers to the following shall be provided to determine the exact purpose for processing:

Description of the processing objective
The likelihood of meeting the objective and how to determine if the objective was met
The benefit of the processing and the significance to the organisation
Description of the possible impact of not processing and any other issues that might be relevantn

ii. Determine the Necessity of the Processing

COURE must establish why the processing must take place, how the processing relates to the expected benefits, and any other alternatives and why there were not considered.

iii. Balance the identified interest with the Privacy Interest of the Data Subjects

The following questions will be addressed under the balance test:

Who are the data subjects (category)?
What is the relationship between COURE and the data subject
What personal data is to be processed
How will the processing impact the data subject
How will the data subject react to the processing

COURE records this information in line with this policy, data protection impact assessment, and data inventory.

3. Consent

COURE requires your explicit consent to process collected personal data. And by consenting to this privacy policy, you are giving us the permission to use/process your personal data specifically for the purpose identified before collection.
If, for any reason, COURE is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.
You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the COURE Withdrawal of Consent Procedure. You can contact the company DPO via mail at [email protected].

4. Disclosure

COURE will not pass on your personal data to third parties without first obtaining your consent. Where there is a need for a third party to process the personal data of data subjects, COURE will enter into a Data Processing Agreement with the third party and be satisfied that the third party has adequate technical and organisation measures in place to protect the data against accidental or unauthorised access, use, disclosure, loss, or destruction.
In a case where the disclosure is to third parties outside the jurisdiction of the GDPR and NDPR, COURE will ensure that the third party meets the core regulatory standards prior to the transfer. This may include transferring the personal data to the third party where COURE has satisfied that:

The country of the recipient has adequate data protection controls established by legal or self-regulatory regime.
COURE has a contract in place that uses existing or approved data protection clauses to ensure adequate protection.
COURE is making the transfer under approved binding corporate rules.
COURE is relying on approved codes of conduct or certification mechanisms, together with binding and enforceable commitments in the foreign country or international organisation to apply the appropriate safeguards in relation to data subject rights.
Provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority

5. Retention of Records

In compliance with the GDPR/NDPR data retention policy, COURE will process your personal data for the minimum period necessary and as required by applicable laws, until a time it is no longer required or has no use.
This retention period has been established to enable us to use the personal data for the necessary legitimate purposes identified, in full compliance with the legal and regulatory requirements. When we no longer need to use your personal information, we will delete it from our systems/computer/data storage facilities or take steps to encrypt it to protect your identity as the case may be.

6. Data Subject Rights

Data subjects, according to the provision of the GDPR/NDPR, have certain rights. At any point while COURE is in possession of or processing your personal data, you, the data subject, have the right to:

Request a copy of the information that we hold about you.
Correct the data that we hold about you if it is inaccurate or incomplete.
Ask for the data we hold about you to be erased from our systems/record.
Restrict processing of your personal data where certain conditions apply.
Have the data we hold about you transferred to another organisation.
Object to certain types of processing like direct marketing.
Object to automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling.

In the event that COURE refuses/reject your request under rights of access, we will provide you with a reason as to why and you have the right to complain as outlined in section 7 below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Why Does COURE Need to Collect and Store Personal Data?

We need to collect your personal data in order for us to provide you with our services as mentioned in sub-section 2.3 above. In any event, we are committed to ensuring that the information we collect and use is appropriate for these purpose(s) only, and will in no way invade your privacy. If there is a need to use your personal data for marketing purpose, COURE will ensure to seek additional consent from you.

Will COURE Share My Personal Data with Anyone Else?

COURE may pass your personal data to third-party service providers contracted by us. Any third parties that we may share your personal data with is under an obligation to secure your details, and use them only to fulfil the service for which they were contracted. When they no longer need your details to fulfil this service, the data will be disposed in line with COURE’s 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 required to do otherwise, legally.

How Will COURE Use the Personal Data It Collects About Me?

We will process (collect, use and store) the information you provide in a manner that complies with the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation (NDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. COURE is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. The retention period for certain kinds of personal data may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will COURE contact me?

We do not intend to be intrusive, and we will not ask irrelevant or unnecessary questions. Moreover, we will subject the information you provide to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I Find Out the Personal Data That COURE Holds About Me?

COURE, at your request, can confirm what information we hold about you and how it is processed. If we do hold your personal data, you have the right to request the following information:

Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
Information about interests, if the processing is based on the legitimate interests of COURE or a third party.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
Information about how we intend to securely transfer the personal data to a third party or international organisation. The Attorney General of the Federation will approve 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 information.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information 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 you didn’t provide it directly.
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.

Forms of Identification documents you will need to Provide in Order to access your personal data with us?

COURE accepts the following forms of ID when information on your personal data is requested: International Passport, driver’s license, national identity card, permanent voters’ card.

7. Complaints

If for any reason you wish to make a complaint about how COURE (or any of our third parties) processes your personal data, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and the Data Protection Officer of COURE.
Below are the details for each of these contacts:

	Supervisory Authority	Data Protection Officer (DPO)
Contact Name:	Nigeria Data Protection Commission	Onome Omenai
Address:	No. 12 Clement Isong Street, Asokoro, Abuja, Nigeria	The Waterside, 5 Admiralty Road, Off Admiralty Way, Lekki Phase 1, Lagos.
Email:	[email protected]	[email protected]
Telephone:	09160615551

8. Privacy statement

Due to constant changes in technology and regulatory requirements, COURE may need to change its privacy policies or update this notice from time to time. The data subject will always be able to find the most recent version of our updated privacy policy on the website.

9. Privacy statement

For more information on how we use your personal data and why, please visit www.COURE.com/legal/data-policy.html. In addition, to read our cookie policy visit www.COURE.com/legal/cookies.html

LEGAL