PERSONAL DATA

This Privacy Policy describes how and why we might collect, store, use, and/or share ('process') your personal information when you:

• Visit our physical offices
• Reach out to us through any electronic means including phone calls, emails, social media platforms
• Visit our website at flyvaluejet.com
• Engage with us in other related way

1. WHAT INFORMATION DO WE COLLECT

We collect this information to provide you with the services you require. Hence, we may not collect the underlisted information in all circumstances, we may also collect more than the underlisted information where it is necessary to provide you with the services you require. We will always inform you of why we need to collect the information.

1.1. If you are a customer or prospective customer, we may collect:

• a. Your name and contact information
• b. Information about your enquiries
• c. Data from contract which may include details of the contract, third party providers, counterparty names and email addresses, comments, activity on contracts, signatures.

1.2. If you are an employee or prospective employee, we may collect:

• a. Your name and contact information
• b. Your address and location
• c. Your means of identification
• d. The name and contact details of your guarantor/referees
• e. Your banking details

1.3. If you are just visiting our website:

We keep log files generated from our servers; this include the IP addressed assigned to you.

1.4. Additionally, If you are an organization, we may collect:

• a. Personal Information of key personnel: Full name, age, email address, phone numbers, residential address, photo, location, means of identification.
• b. Information about your organization: name of organization, registration number, organization’s website, description of business of the organization, names of key personnel, control structure of the organization, length of operation of the organization, audited financial statement.
• c. Regulatory licenses and approvals (where applicable), status report of the Organization.

We may collect sensitive Information such as your health information, trade union membership, religious or political affiliations etc. if it becomes necessary to process such sensitive information to provide you the services you require. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

• a. Personal Information of key personnel: Full name, age, email address, phone numbers, residential address, photo, location, means of identification.
• b. Information about your organization: name of organization, registration number, organization’s website, description of business of the organization, names of key personnel, control structure of the organization, length of operation of the organization, audited financial statement.
• c. Regulatory licenses and approvals (where applicable), status report of the Organization.

1.5. Information automatically collected Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our website. Like many businesses, we also collect information through cookies and similar tracking technologies. For more information on how we use cookies please refer to our cookie policy

1.6. Information collected from other sources We may collect information about you and your organization from public databases or social media platforms. When you request our services, we may receive information about you and your organization from public databases which may be hosted by government organizations with whom you have dealings, or we may collect information from social media platforms.

2. HOW WE PROCESS YOUR INFORMATION, LAWFUL BASIS FOR PROCESSING THE INFORMATION AND YOUR RIGHTS

We process your information to provide you with the requested service, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. In this section we have provided you with the purpose for processing your information, our lawful basis for processing

We process your personal information for a variety of reasons, depending on how you interact with us, including:

2.1. Personal data and data about you collected from you will be used for the provision of our services to you

• Our lawful basis for this is Consent, Contractual obligation
• You have the right to withdraw consent, object to processing, lodge a complaint with a supervisory authority, right to access, erasure and rectification, right to restriction of processing, right to data portability

2.2. Personal data may be collected and processed to respond to your inquiries and offer support services to you, we may also process your information to communicate changes in our policies

• Our lawful basis for this is Legitimate interest
• You have the right to object, right to lodge a complaint with a supervisory authority

2.3. Your data may be collected through third parties including public databases. We collect this information only if it is necessary to provide our services to you.

• Our lawful basis for this is: Consent, Contractual obligation
• You have the right to withdraw consent, object to processing, lodge a complaint with a supervisory authority, right to access, erasure and rectification, right to restriction of processing, right to data portability

2.4. If you are a current or prospective employee, your personal data is collected by us to fulfill our employment obligations to you.

• Our lawful basis for this is: Contractual obligation, Legitimate interest
• You have the right to object to processing, lodge a complaint with a supervisory authority, right to access and rectification, right to restriction of processing, right to data portability

2.5. If you connect with via our website, your data may be collected through cookies or similar tracking technologies to personalize your website experience and to deliver content and product and service offerings relevant to your interests

• Our lawful basis for this is Consent
• You have the right to withdraw consent, right to object, right to lodge a complaint with a supervisory authority, right to erasure

2.6. We may process your data if we are legally obligated to process such data.

• Our lawful basis for this is Legal Obligation
• You have the right to access and rectification, right to lodge a complaint with a supervisory authority.

3. WHAT LAWFUL BASIS DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we have a lawful basis for doing so. The Nigeria Data Protection Regulation (NDPR) and Nigerian Data Protection Act require us to explain the valid lawful basis we rely on in order to process your personal information.

As such, we may rely on the following lawful basis to process your personal information:

3.1. Consent: We may process your information if you have given us permission (i.e., consent) to use your personal data for a specific purpose. You can withdraw your consent at any time.

3.2. Contractual Obligation: We may process your personal information when we believe it is necessary to perform a contract which you are or will be subject to, including providing our services, or fulfilling our employment obligation to you or at your request prior to entering into a contract with you.

3.3. Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms

3.4. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to comply with a law, cooperate with a law enforcement body or regulatory agency

4. CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for any other purpose, we will seek your consent to do so, we will not process your information for any other purpose if you refuse to consent. Where we have a legal basis for using your information for any other purpose, we will notify you and explain the legal basis which allows us to do so.

5. YOUR RIGHTS

Depending on our purpose for processing and the legal basis we rely on, you are guaranteed the following rights:

5.1. Right to Rectification: you can at any time modify, change, update or rectify the personal information we have of you. If you wish to rectify your personal information please contact [support email]

5.2. Right of Access, Right to Erasure, Right to Restrict Processing: you can request access to the information we have of you including our source(s) of the information. You also have the right to restriction on further processing or erasure of your personal information by contacting us [here] (this should be a direct link to the data subject access request form that will be attached below). The request will be processed within 30 days

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

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

5.3. Right to Withdraw Consent: You can withdraw your consent to our use or processing of your data if you no longer wish for us to process your personal information. We will no longer process your data where you have withdrawn consent unless we have another lawful basis for doing so.

5.4. Right to lodge a complaint with a supervisory authority: you have a right to lodge a complaint against us to a supervisory authority whenever you feel that we may not have honored any of the rights granted to you under this Privacy Policy or under any law.

5.5. Right to object: where our lawful basis for processing your data is our legitimate interest, you may object to such processing, and we will no longer process the data unless we have a compelling, legitimate ground for processing which we will communicate to you at the soonest time possible.

5.6. Right to Erasure: you may request for an erasure of the data we have of you where such data is no longer needed for the purpose we have collected it for, or where you withdraw the consent you have given us or object to the processing and we have no other lawful basis for processing the data.

5.7. Right to data portability: you have a right to receive your data or have us transfer your data to another data controller in a structured, commonly used, and machine-readable format.

If you have questions or comments about your privacy rights, you may email us at contactcenter@flyvaluejet.com

6. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information in specific situations described in this section and/or with the following third parties.

We may share information about your organization and/or personal information to government agencies and parastatals. We may also share with third parties when we have received clear instructions from you to do so. We disclaim any liability arising from the use or misuse of the data provided to such government agencies and parastatals or third parties

7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security measures.

We only use technological platforms that incorporate privacy by design and default. We ensure that all technological platforms we use respect the privacy of its users and employs the acceptable industry standard of cyber security. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat the security and improperly collect, access, steal, or modify your information.

We also ensure that our employees are trained on the best data handling procedures that ensures the safety of your information. For sensitive information or delicate financial information, we ensure that the information is only accessible to key members of the Company, this helps us manage any employee related risks to your privacy.

10. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect data from children under 18 years of age. By connecting with us and requesting our services, you represent that you are at least 18. If you are less than 18 years, we would require the consent of your parent to process your personal information.

11. INTERNATIONAL DATA TRANSFER

You may be interested in services that can only be provided to you only if we transfer your personal information to locations outside your country. Where we transfer your personal information outside your country, we will ensure that it is protected and transferred in a manner consistent with legal requirements.

12. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contactcenter@flyvaluejet.com or call us at +234 912 595 0403 or by post to: #31 Ladoke Akintola Road, Ikeja GRA, Lagos