INTRODUCTION
Welcome to the Covenant Community Group (“CCG)’s privacy policy.
CCG respects your privacy and is committed to protecting your personal data. This privacy policy contains information about your privacy rights, how the law protects you and how we look after your personal data when you visit our Website, regardless of where you visit it from.
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to provide information on how CCG collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you register as a participant of any of our community groups.
This Website is not intended for children and we do not knowingly collect data relating to children under the age of 18.
It is important that you read this privacy policy 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.
CONTROLLER
CCG is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your rights as a Data Subject, please contact the Secretariat via [tcncommunitygroups@gmail.com or call on +2348186000025].
You have the right to lodge a complaint with a relevant authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the relevant authority. Please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. Where this privacy policy is updated, we will include the link to the previous privacy policies for you to access. 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
This 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 data use and privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
THE DATA WE COLLECT ABOUT YOU
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:
Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender and religion.
Contact Data includes home address, work address, email address and telephone numbers.
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 this Website.
Usage Data includes information about how you use our Website, platform and services.
Communication Data includes your preferences in receiving communication from us.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
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). Nor do we collect any information about criminal convictions and offences.
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 register you with a Community Group of your choice).
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us through phone, email or other media. This includes personal data you provide when you register for a Community Group or give us feedback or contact us.
Automated technologies or interactions. As you interact with our Website, we may collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
analytics providers [such as Google];
search information providers [such as Google, Yahoo or Bing].
HOW WE USE 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 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 obligation.
OPTING OUT
You can ask us to stop sending you communication at any time by contacting us
Where you opt out of receiving these communications, this will not apply to personal data provided to us as a result of a registration.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when Websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.
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 our DPO.
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above, and Internal Third Parties as set out in the Glossary.
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 on our behalf for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Nigeria
We share your personal data within the CCG and Internal Third Parties. This may involve transferring your data outside Nigeria. Some of our Internal Third Parties are based outside Nigeria so their processing of your personal data will involve a transfer of data outside Nigeria.
Whenever we transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Nigeria.
Diaspora
We share your personal data within the CCG and Internal Third Parties. This may involve transferring your data outside your domiciled country. Some of our Internal Third Parties are based outside your domiciled country so their processing of your personal data will involve a transfer of data outside your location.
Whenever we transfer your personal data out of your domiciled country, we ensure a similar degree of protection is afforded to it by ensuring we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
In compliance with GDPR and other international privacy regulations, the personal data of community group participants registering in the Diaspora are stored in our server located in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of your domiciled country.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to the Board, Governors, Leaders and third parties who have a legitimate need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality and integrity.
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 my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including the purposes of satisfying any legal, regulatory or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
For CCG registration purposes, we will retain your personal data for a maximum of two years after your last registration.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise 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.
NO FEE USUALLY REQUIRED
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 clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
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 for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our organisation in conducting and managing our organisation objectives to enable us to give you 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Website includes our website, online platforms, e-mail correspondence or any other platform from which personal data is submitted.
YOUR LEGAL RIGHTS
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:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
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.