Introduction

Advancly strongly believes in providing total privacy and protection to our customer’s personal data. The information our customers give us are gotten with full consent, are processed under legal basis and are not sold, rented, loaned or otherwise disclosed to third parties.

Our policies are created to provide protection of the confidentiality and security of our customer’s personal information. We only require the minimum amount of personal information needed to fulfill our service to our customers. Our privacy standards are in compliance with the National Data Protection Regulation (NDPR) and the General Data Protection Regulation (GDPR).

1. Policy Overview

This Privacy Policy describes the process involved in the acquisition, processing, porting, storage and disposing of your personal data in connection with our websites, portals, mobiles applications, tools and services. This Privacy Policy also governs your rights regarding the foregoing Advancly takes pride in securing and maintaining the privacy of the data we collect from you.

2. Scope and Consent

This policy is enforced after you consent to it when you sign-up, access our products, services, content, features, technologies or functions offered from our websites, related sites, portals, applications and services.

However, Advancly is not responsible for handling of information gotten by third party customer/sites through the use of our tools, portal, and services and will not be held liable for any breach or misuse of collected information.

3. Rights

You have the right of access to your personal data being processed by Advancly which includes requesting for an update, rectification, erasure, asking for a copy of your personal data, a withdrawal of consent at any time, complaining to a data protection authority, without affecting the lawfulness of processing based on consent given before the withdrawal.

You can request for a restriction or deletion of your personal data based on the following:

• Non-legitimate grounds for processing
• Unlawful processing
• Erasure is required for compliance with a legal obligation.
• Inaccuracy of personal data
• Change in initial purpose

All requests shall be made in writing to the Data Protection Officer via email at dpo@venturegardengroup.com

4. Use of personal information

The collection and use of personal data by Advancly is guided by certain principles. These principles state that personal data should:

• be processed fairly, lawfully and in a transparent manner.
• be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purposes.
• be adequate, relevant and limited to what is necessary to fulfil the purpose of processing.
• be accurate and, where necessary, up to date.
• Not be kept for longer than necessary for the purpose of processing.
• be processed in accordance with the data subject’s rights.
• be kept safe from unauthorised processing, and accidental loss, damage or destruction using adequate technical and organizational measures

5. Personal Data Collected and Used in Advancly

We collect the following personal information in order to provide personalized and improved experience. Personal Data may be given to us directly by you or by people or companies authorized by you to act on your behalf. We may also collect Personal Data about you from third parties in connection with our services. No Personal Data about you will be collected without your consent.

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 provide the services envisaged or requested.

Automatic Information: In general, website visitors do not need to provide personalized information to Advancly. We may collect “aggregate data,” i.e., group data with no personal identifiers such as IP address, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information used to help us understand how the Sites are being used and to improve usability. We also use it to enhance the quality and availability of our products and services.

Provided Information: Personal data that are provided and retained allows Advancly provide services to its users. Advancly solely holds the information and engages in no contact-sharing program with other organizations. The information collected are

Contact Information: first and last name, email address. phone number, town/city/state, Valid Identity Number (which could be BVN, National ID among others) country, and any other information required to process your information as a user of our platforms.

Mobile Devices: Some of our applications can be accessed through mobile applications or mobile-optimized websites from which we collect user data. This policy applies to access and use of data through mobile devices.

Surveys: In order to ensure that the services we offer meet your requirements, we may ask for your feedback in the form of surveys and polls. Any feedback received from you shall only be used for the purpose of improving our services and shall not be disclosed and used for research and publication purposes.

Inquiries: When an inquiry is sent to us through our contact form, we use the personal data that you have stated in the contact form to send a response to you. Any personal data received from you shall not be used for any other purpose without your prior consent and knowledge and shall not be disclosed.

6. Duration of Storage

We shall store your personal data until they are no longer necessary for the purpose which we had collected it. Your information is only retained in accordance with legal and regulatory requirements for the collected data.

7. Data Storage and Security

Advancly use a security-cleared data processor to store files and data on secure cloud-based servers hosted in the Republic of Ireland region of Amazon Web Services, and the North Europe Region of Microsoft Azure. The data processors are certified under the applicable frameworks and thereby guarantees and operates an appropriate standard of data protection and data security. Regardless of where your information is processed, we apply the same protections described in this policy and you have the right (upon your request) to be informed of the appropriate safeguards for data protection in the foreign country.

We protect your Personal Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. All data is accessed via secure connections and stored on encrypted servers and encrypted storage services. We also use firewalls and physical access controls for our data centres, and information access authorization controls.

Despite our efforts to establish a secure environment for the website, you should be aware that no information is completely secure on the internet. Therefore, you should always take the necessary safeguards and precautions on your own equipment. In the event of an actual or suspected breach of your Personal Data, we will use best effort to remedy the breach within one (1) month from the date we report the breach to you.

8. Children’s Privacy

We do not use our platforms to knowingly solicit data from children or individuals under the age of Sixteen (16). Where a parent or guardian discovers that a child or individual under the age of Sixteen (16) has provided us with his/her Personal Data without their consent, he or she should contact us at {dpo@venturegardengroup.com} and we shall immediately delete the user’s account from our servers.

9. Accuracy of Information

1. The Company shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
3. The Company shall ensure that updated personal data reflect across all boards to which it is being used.

10. Archiving / Removal

1. To ensure that personal data is kept for no longer than necessary, the Company puts in place a data retention policy for each area in which personal data is processed and review this process annually.
2. This retention policy considers what data should/must be retained, for how long, and why.

11. Transfer of Personal Data

We do not rent or sell your personally identifiable information to other individuals or organizations.

However, we may transfer your personal data to third parties when it is necessary to provide you with our service. Third parties could include:

• Undertakings within Advancly
• Business partners
• Professional advisors
• Legal or regulatory authority
• Application program interface (API) Users
• Security-cleared data processors/subcontractors, who are assisting us or the group with IT or other services.

When we transfer your personal data to business partners, you should be aware that they might have stored personal data concerning you collected through other means, e.g., if you have been in contact with them in another context.

We also transfer your personal data to the above or other third parties if we are obliged to do so according to legislation or in order to protect our or the group’s interests in legal disputes.

Transfer of Personal Data to Third Countries: Advancly partners with various technology vendors from time to time. This shall result in a transfer of personal data to a third country or international organization.

In order to ensure an equal level of security for such transfer in accordance with the NDPR, Advancly has chosen to work only with vendors that have entered Standard Contractual Clauses with Advancly.

12. Changes to this Policy

We may update this Policy from time to time without any prior notice to you or consent. Thus, you are advised to consult this Platform periodically for any changes. We will notify you of any changes by posting the revised Policy on this Platform. Please note that changes shall be effective immediately after they are updated on this Platform.

13. Contact

If you want to lodge a complaint over our processing of your personal data or have further requests, please contact the Data Protection Officer directly at dpo@venturegardengroup.com.

Advancly maintains an incidence response plan used in dealing with incidents relating to unlawful disclosure, loss, alteration, destruction, access to our customer’s personal data collected, transmitted, stored or processed in any way.

We will work with the National Information Technology Development Agency (NITDA) to resolve any issues that we cannot resolve with you directly.