Acilect Ltd (12347194) is the controller and responsible for your personal data (“Acilect” “we”, “us” or “our”).

Acilect respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or app (regardless of where you visit it from) when you become a customer or supplier of Acilect or use our products and/or services and tell you about your privacy rights and how the law protects you.

You must read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions 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. This privacy notice supplements the other notices and is not intended to override them.

1.1 Data Protection Officer (DPO) and Compliance with Nigerian Data Protection Act 2023

Acilect has appointed a dedicated Data Protection Officer (DPO), in compliance with the Nigerian Data Protection Act 2023 ("the Act") as well as NDPR Implementation Framework. This appointment was made in response to the need for processing the personal data of over 10,000 data subjects annually and handling sensitive personal data regularly. The DPO at Acilect is not personally liable for the organization’s non-compliance with applicable data protection laws, regardless of any contractual, civil, or criminal liability.

The DPO at Acilect possesses professional expertise in Nigerian data protection laws and practices, an in-depth understanding of applicable data protection laws, and the knowledge to inform and advise the organization, management, employees, and third-party processors of their obligations under the NDPR. The DPO is capable of monitoring compliance with the NDPR and Acilect’s data protection objectives, assigning responsibilities, raising awareness, and training staff involved in processing operations. Additionally, the DPO is skilled in advising on data protection impact assessments and monitoring their performance, as well as liaising with NITDA and/or the Data Protection Compliance Organization (DPCO) on data protection matters.

Under the Act, Acilect is committed to protecting the privacy rights of individuals whose personal data is processed, including customers, suppliers, and website users. This commitment includes ensuring that personal data is collected lawfully, used only for specified purposes, and retained no longer than necessary for those purposes. Acilect adheres to data protection principles such as transparency, accountability, and data minimization in its data processing activities.

For inquiries regarding data protection practices at Acilect or to exercise your rights under the Act, including the right to access, correct, or delete your personal data, please contact our Data Protection Officer at:

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 as follows:

• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or through the platform.
• Technical Data includes 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 our website or app.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, app, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific 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 notice.

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, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 product or service you have with us but we will notify you if this is the case at the time.

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account;
  • subscribe to our service or publications;
  • request marketing to be sent to you; or
  • give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly availably sources.
• Automated technologies or interactions. As you interact with our website or app, we may 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.

Our website and app use cookies to distinguish you from other users of our website/ app. This helps us to provide you with a good experience when you browse our website, use our app and also allows us to improve our website and our online application (“app”).

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer’s or device’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website/ app. They include, for example, cookies that enable you to log into secure areas of our website/ app or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website/ app when they are using it. This helps us to improve the way our website/ app works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

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 we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Data can be used for scientific research, historical research, or statistical purposes in the public interest without requiring further consent.
• Data processing can be justified if it is necessary for the legitimate interests of the data controller or a third party, provided these interests are not overridden by the data subject's rights and interests.
• Data can be used if it is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis 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.

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.

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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

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

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

We may have to share your personal data with the parties set out below:

• Service providers who provide IT, payment processing, identity verification and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities 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 notice.

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.

In the event of a data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary. 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

On the closure of your account, we may keep your data for up to six months after you have cancelled your services with us. We may not be able to delete your data before this time due to our legal and/or accountancy obligations or as reasonably necessary to prevent fraud, abuse, enforce our terms and to protect our legitimate interests. We assure you that your personal data shall only be used for these purposes stated herein.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights have been granted to all users under UK-GDPR and Nigerian Data Protection Act (2023).

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

We are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us https://acilect.com/contact.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

This website and/or app 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 or app, we encourage you to read the privacy notice of every website you visit.