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Privacy Policy

 

Who We Are

The Compliance Institute for Banks and Other Financial Institutions in Nigeria Ltd/GTE, also known as “Compliance Institute, Nigeria” (CIN) was registered on Thursday, 22nd January, 2015.

The Institute was established to encourage, promote and revive the consciousness for regulatory compliance within and outside the financial industry in the country.

The Institute seeks to create and build a body of professionals and corporate organisations from a range of industries established and recognized for integrity, professionalism and strict adherence to regulatory and non-regulatory standards in and outside the business environment.

It is the recognized body for compliance professionals within the financial industry in Nigeria. It shall draw its primary constituency from employees and directors within the financial industry while equally open to interested members of the Nigerian public. Membership of the Institute shall be considered a prerequisite for working in the compliance department of any financial institution in Nigeria.

Our website address is: https://www.complianceinstitute.org.ng

About Our Privacy Notice

Compliance Institute, Nigeria respects your privacy and is committed to protecting your personal data. This privacy notice will inform you on how we handle your personal data with utmost care and attention when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

When we refer to ‘we’ (or ‘our’ or ‘us’), that means Compliance Institute, Nigeria. This notice applies to our website. When we say ‘personal data’ we mean identifiable information about you, like your name, email, address, telephone number, payment information, support queries and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply.

For European Union data protection purposes, we promise to meet internationally recognised standards of personal privacy protection by complying with the Data Protection Law 2018. Please refer to https://ec.europa.eu/info/law/law-topic/data-protection_en  for further details.

Purpose of This Privacy Notice 

This privacy notice aims to give you further information about how Compliance Institute, Nigeria collects and processes your personal data through your use of this website, including any data you may provide through this website when you make payments, use our website, or request information about our products and services.   You should read this notice in addition to the individual data collection statements provided at the point of data collection.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or data collection statement 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.

Changes to The Privacy Notice and Your Duty to Inform Us of Changes

This version was last updated on 25 July 2018. We may need to update this notice from time to time. Where a change is significant, we’ll make sure we let you know – usually by sending you an email.

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.

Third-Party Links

Our website 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, we encourage you to read the privacy notice of every website you visit.

What Personal Data We Collect and Why We Collect It

When you visit our website or use our services, we collect personal data.  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 together as follows:

Usage Data: This includes information about how you use our website, products and services. That is, you add up to our usage data statistics e.g. page views.

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.

Forms Data includes registration, login, profile and contact form.

Registration / profile / login form includes personal information, contact information, employment/business details, membership eligibility criteria and profile information containing the following required or optional fields (Username, Title, First Name, Middle Name, Last Name, Gender, Email Address, Date of Birth, Country, Criminal Offense, Mobile Phone Number, Residential Address, Official Address, Alternative Mobile Number, Alternative E-mail Address, Preferred method of contact, Company Name, Job Title, Job Description, Company Address, Company Email, Company Telephone, Education, Experience, Organisation and passport photograph)

When users register on our website, we store the personal information they provide in their user profile. All users can see and edit their personal information at any time (except they cannot change their username) after paying membership fee. Our website administrators can also see and edit that information.

Login form request for your username or email and your profile displays all information keyed in during registration or profile update.

Contact form captures your name and email. Please note that we do not use this information submitted for marketing purposes.

Comments: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture may be made visible to the public in the context of your comment.

Media

When you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Our products include: Memberships, Certifications and Subscriptions.

When you purchase from us, we’ll ask you to provide information including your name, billing address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:

Send you information about your account and order

Respond to your requests, including refunds and complaints

Process payments and prevent fraud

Set up your account

Comply with any legal obligations

Improve our product offerings

Send you marketing messages, if you choose to receive them

If you create an account, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.

We generally store information about you for as long as we need the information for the purposes for which we collect and use it.

We use cookies to keep track of cart contents while you’re browsing our site.

We share information with third parties who help us provide our orders and product services to you; for example —

Payments

We accept payments through Flutterwave. When processing payments, some of your data will be passed to Flutterwave, including information required to process or support the payment, such as the purchase total and billing information.

Please see the Flutterwave Privacy Policy for more details.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

If you have subscribed to our newsletter or if you are a member of our website (you can log in) or if you have purchased on our website, there is a good chance you will receive emails from us.

We will only send you emails which you have signed up to receive, or which pertain to the services we provided to you.

To send you emails, we use the name and email address you provide us. Our site also logs the IP address you used when you signed up for the service to prevent abuse of the system.

Our website can send emails through sending services like, MailChimp and MailPoet. This service allows us to track opens and clicks on our emails. We use this information to improve the content of our newsletters.

No identifiable information is otherwise tracked outside this website except for the email address.

We also collect, use and share Aggregated Data such as statistical or demographic data for business analytical purposes. 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 website 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 and related data collection statements.

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, trade union membership, information about your health and genetic and biometric data).

 

If You Fail to Provide Personal Data 

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.

 

How Is Your Personal Data Collected? 

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

Directly

You may give us your Identity, Contact and Transaction Data by filling in forms, or by corresponding with us digitally (via our webpages or social media), by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing information to be sent to you;
• download some of our resources (e.g. curriculum, study materials, guides or promotional material such as our brochures); or
• attend one of our events.

If you don’t want to provide us with your personal data, you don’t have to but it might mean that you can’t use some parts of our websites or services.

Automatically

As you interact with our website, 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. We may also receive Technical Data about you if you visit other websites employing our cookies.

Cookies are pieces of data created when you visit a site, and contain a unique, anonymous number. They do not contain any personal information about you and cannot be used to identify an individual user. You can choose not to accept cookies by changing the settings in your Internet Browser – refer to your Browser’s help files for instructions. Please be aware that if you decline the use of cookies set by us you will be unable to access our sites. You can also delete any cookies from your computer – refer to your Internet Browser’s help files. Compliance Institute, Nigeria may use session cookies where necessary for the functionality of our websites.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

Session Cookies are temporary and are used only during a browsing session. When you close your browser the session cookie set by the web site is destroyed and no personal information is held which might identify you. Compliance Institute, Nigeria may also use tracking cookies, again these do not hold any personal information. Tracking cookies do not automatically delete when you close your browser window but you can remove them manually after each session. Cookies help us to understand how users progress through our site allowing us to deliver better services to you over time.

We also use Google Analytics, which is a web service provided by Google.  Google utilizes the data collected to track and examine the use of www.complianceinstitute.org.ng to prepare reports on their activities and share them with other Google services.  Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Embedded content from other websites

Articles on our site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

The Lawful Basis for Processing Your Personal Data

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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting Us.

• Where we need to comply with a legal or regulatory obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by Contacting Us.

 

Purposes for Which We Will Use Your Personal Data 

We primarily use your data to operate our websites and provide you with any services you’ve requested, and to manage our relationship with you.

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 bases 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new member and/or deal with queries from existing members which may include contact by telephone or email or both.	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver a service to you online including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy. (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communication (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our organisation and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our organisation and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you, including by telephone.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our organisation)

 

 

 

Promotional Offers from Us 

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 services from us or if you have requested to access or download a resource from us and, in each case, you have not opted out of receiving that marketing.

Third-Party Marketing 

We will not share your personal data for marketing purposes with any company outside the Compliance Institute, Nigeria Organization.

 

Opting Out 

You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by Contacting Us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.

Change of Purpose 

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, only where this is required or permitted by law.

Disclosures of Your Personal Data 

We may have to share your personal data with authorized third parties in accordance with our standard contractual terms where you have purchased a service.

We will only disclose your personal data to:

• third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you;
• regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;
• third parties to whom we may choose to sell, transfer, or merge parts of our organisation or our assets may lawfully be provided with controlled access to your data.

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.

 

Data Security 

We are committed to protecting your personal data and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to other third parties. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data Retention – How Long Will You Use and Hold My Personal Data For? 

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you may be able to ask us to delete your data: see below for further information on the “right to erasure”.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

Your Legal Rights 

You have rights under the Law in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy; (2) where our use of the data is unlawful but you do not want us to erase it; (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (4) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact Us by using this link: https://www.complianceinstitute.org.ng/contact-us/