SESA DATA PRIVACY POLICY
This Privacy Notice (“Notice”) guides your use of our website: www.trysesa.com (“the Website”) and your rights regarding our collection, use, storage and protection of your personal data when you visit, access, browse through and/or use our website or services. Your privacy is important to us.
Your personal data that we process
Personal data means any information about an individual from which that person can be directly or indirectly identified. We do not consider personal data to include information that has been made anonymous such that it does not identify a specific user.
In connection with the services we provide, we collect personal and financial information from you while you use our products, services and websites. We may ask you to provide us with certain personal data directly to contact or identify you, and some automatically for our website to function effectively.
The personal data we obtain include:
Service usersAll Visitors- Full name of registrant
- The domain name of the Internet service provider (ISP)
- Personal email address & phone number
- Data and time of your visits
- Physical address
- The Internet protocol address used to connect your device to the Internet for identification purposes
- Estate name
- Web pages visited, duration and frequency of visit
- Service requested
- Login email addresses and passwords
- Date and time of your visits
- Login email addresses and passwords
Cookies
Cookies are tools used to collect information automatically from you when you visit a Website. The only cookies we use are chocolate chip cookies.
Lawful Bases for processing data
We are required to process your data under at least one of these lawful bases:
Legitimate interest:
Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided your rights and interests do not outweigh those interests.Consent:
You have given explicit consent for us to process your data for a specific purpose.Contract:
If your data processing is necessary for a contract you have with us or because we have asked you to take specific steps before entering into that contract.Legal obligation:
If the processing of your data is necessary where there is a statutory obligation on us.
Purpose of ProcessingLawful Bases- Enhance data security.
- Identify your device when you access your account.
- Allow you subscribe for and pay for services provided on our platform
- Legitimate interest, Contract
- Process statistical data to improve our business.
- To inform you whenever there are changes to our terms of business or services
- Legitimate interest
- Enable us to send targeted advertisements to you (if you are a new customer).
- Access your device.
- Subscribe to our newsletter.
- Consent
- To enable you to carry out transactions.
- Communicate with you.
- Notify you of any changes to our service, solving issues via live chat support, phone or email, including any bug fixing.
- Enable registered users to log in to our mobile app.
- Contract
- Fulfil our Know Your Customer (KYC) obligation.
- Fulfil legal requirements where needed.
- Legal obligation
Your rights as a data subject
The law vests you with certain rights as a data subject. They include the right to
- access personal data we hold about you by requesting a copy of the personal data we hold about you;
- rectify such information where you believe it to be inaccurate;
- restrict the processing of your data in certain circumstances;
- object to the processing of your data where we intend to process such data for marketing purposes;
- where feasible, receive all personal data you have provided to us in a structured, commonly used, and machine-readable format and transmit the information to another data controller;
- request the erasure of your data (also known as the right to be forgotten);
- withdraw your consent to the processing of your personal data; and
- lodge a complaint with a relevant authority, where you have reason to believe that we have violated the term(s) of this Privacy Notice. (You may complain or seek redress from us within 30 days from the time you first detected the alleged violation.).
You may seek to exercise any of the above rights at any time by sending an email to us via support@trysesa.com
The supervisory authority is the Nigerian Data Protection Bureau (NDPB), and you can send your complaint via email toinfo@ndpb.gov.ng
Who we share your data with
We may share your data with the following third parties:
Service usersAll Visitors- Estate Management
- We may offer your information to your estate management in order to ensure a seamless use of our estate management service and other related services which serves the needs of your estate.
- Law enforcement, government officials
- We may disclose your data pursuant to a subpoena, or court order, when we need to do so to comply with law or credit/debit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
- Legal/ Regulatory Authority
- We may disclose your data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, audit, or to protect the safety of any person, to address fraud, security or technical issues.
Note that if you wish to prevent your device’s operating system from sharing your Personal Data with SESA or with the third parties mentioned for profiling purposes, you can do so by setting up your device appropriately – namely, by changing the privacy settings on your device to disable/restrict any advertising tracking features. For more information on this, please see the following links:
iOS Devices:
https://support.apple.com/en-us/HT202074Android Devices:
https://support.google.com/ads/answer/2662922?hl=en
Retention of your data
Your personal data or any other information collected will be stored for as long as necessary to fulfil the purposes described in this Notice. However, we will also retain personal data based on relevant provisions of applicable laws, to resolve disputes, and enforce our legal agreements and policies. In addition, we delete your data for targeted marketing purposes once you unsubscribe from our marketing communications.
Please note that your data may be retained for a more extended period, notwithstanding your request to remove your data, where there is a legal requirement to do so.
How your data is stored
We store and process your data. We protect your data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls, and information access authorisation controls.
Where there is an actual or suspected data breach capable of causing harm to your rights and freedoms, we will notify you without undue delay and use our best effort to remedy the violation within one (1) month from the date we notify you.
International transfer of data
To achieve the purposes described in this Notice, we may transfer your data to countries that may not offer an adequate protection level or are not considered to have sufficient law by the National Information Technology Development Agency (NITDA). Where personal data is to be transferred to a country outside Nigeria, we shall put adequate measures to ensure data security.
Our data transfers to the countries that do not offer an adequate protection level are subject to the conditions under the Nigeria Data Protection Regulation (NDPR). We will therefore only transfer Personal Data out of Nigeria on one of the following conditions:
- Your consent has been obtained;
- The transfer is necessary for the performance of a contract between Us and you or implementation of pre-contractual measures taken at your request;
- The transfer is necessary to conclude a contract between Us and the third party in your interest;
- The transfer is necessary for reason of public interest;
- The transfer is for the establishment, exercise or defence of legal claims;
- The transfer is essential to protect your vital interests or other persons, where the Data Subject is physically or legally incapable of giving consent.
Marketing and communications
We only send marketing communications to you with your consent. You may choose to opt out of our marketing emails by clicking on the ‘unsubscribe' button at the bottom of the page.
Security of your data
We are very particular about preserving your privacy and protecting your data. We deploy all reasonable and appropriate technical and organisational measures to keep your data safe. However, we cannot completely guarantee the security of any information you transmit via our website, as the internet is not an entirely secure place. Nevertheless, we are committed to doing our best to protect you.
Complaints
If you are concerned about an alleged breach of data protection law or any other regulation by us, you can contact the Data Protection Officer (DPO) via support@trysesa.com. The DPO will investigate your complaint and provide information about how your complaint is handled.
Please be informed that you may complain to the relevant data protection authority if your complaints are not satisfactorily addressed.
Changes to this notice
We update our privacy notice from time to time. We will notify our users when we change it, and visitors will know this by checking the last date of update on this page whenever you visit.
Contact Us
If you have any questions relating to this Notice, your rights under this Notice, or are not satisfied with how we manage your personal data, kindly reach out to our Data Protection Officer at support@trysesa.com
To obtain any relevant information regarding any transfers of your Personal Data to third countries (including the appropriate transfer mechanisms), please contact us.
Last updated on August 10, 2024