Mirene Global Consults’ Privacy Policy
We review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall contact you to inform you.
Our Name & Contact Details.
Our contact details are:
Mirene Global Consults
11A Aliu Animashaun street,
Off Babatunde Kuboye Street,
Lekki Phase 1, Lagos
For what purposes do we process personal data, and what are the lawful basis’ by which we process data?
| For What Purposes Do We Process Personal Data? “Mirene Global Consults processes your data to…” | Lawful Basis |
| Communicate with clients to fulfil, administer or enforce contractual obligations via email, telephone, SMS text, postal mail and push notifications; | Contract |
| Communicate with customers where we have your consent to do so via email, telephone, SMS text, postal mail and push notifications; | Consent |
| Communicate with clients on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail and push notifications; | Legal Obligation |
| Communicate with clients on matters where we have a Legitimate Interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail and push notifications; | Legitimate Interest |
| Inform existing clients about Mirene Global Consults’s new products and services; Legitimate Interest Request specific consent to share information about specific aligned/similar products/services with specific fulfilment partners; | Legitimate Interest |
| Broker commercial relationships between database owners with aligned/similar product providers or vice-versa; | Consent |
| Verify the identity of individuals where necessary including for Subject Access Requests (SAR); | Legitimate Interest |
| Fulfil our SAR as a Service (SARaaS) service Legitimate Interest Update clients about significant changes to our Privacy Notice via email, telephone, SMS text, postal mail; | Legal Obligation |
| Update clients about changes to how we process their personal data and/or new processing activities via email, telephone, SMS text, postal mail; | Legal Obligation |
| Gather feedback for service and product improvement via email, telephone, SMS text, postal mail; | Legitimate Interest |
| Share testimonials, case studies and feedback on Mirene Global Consults on website and future marketing; | Consent |
| Resolve complaints and/or disputes; Legitimate Interest Request continuation of Consent prior to consent expiry; | Consent |
| Collect payments or arrears should we have the need to do so; | Legitimate Interest |
| Protect our organisation, staff, associates, suppliers, partners and clients; | Legitimate Interest |
| Prevent, detect and investigate fraud; | Legal Obligation |
| Prevent, detect and investigate crime; | Legal Obligation |
| Comply with the law; | Legal obligation |
| Fulfil our statutory or regulatory obligations; | Legal obligation |
| Maintain our own accounts and records; | Legal obligation |
| For reporting, analytics and product/service improvement (including training); | Legitimate Interest |
| Improve and maintain data accuracy or completeness; | Legitimate Interest |
| Track your email engagement; | Legitimate Interest |
| Personalise your online experience; | Legitimate Interest |
| Conduct market research. | Legitimate Interest |
Mirene Global Consults processes your Personal Data for the following purposes:
What are our legitimate interests for processing data?
Where we have used legitimate interest as the lawful basis for processing your personal data, we may use your personal data to:
- Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current products and services;
- Maintain our own accounts and records, including recording any contact we have with you via post, emails, telephone, SMS text and push notifications;
- Prevent, detect and investigate fraud;
- Prevent, detect and investigate crime;
- Fulfil our statutory or regulatory obligations;
- Reporting, analytics and product/service improvement, (including internal training);
- Resolve complaints and/or disputes;
- Improve data accuracy or completeness;
- Track your email engagement;
- Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
- Conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service. This research may be carried out internally by our employees or we may ask another company to do this work for us.
Sharing your personal data
Mirene Global Consults may choose to share your personal data internally and/or share your personal data externally to the business and as directed by clients’ need. Where we choose to share your information, we shall do so for the following reasons:
- Where we have your “Consent” to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent.
- Where necessary to fulfil the services and/or products we are “Contracted” to provide to you;
- Where we have a “Legal Obligation” and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;
- Where we have “Legitimate Interest” to do so, including:
- For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
- For reporting, analytics and service improvement purposes across our trading styles and/or within any future group construct should Mirene Global Consults establish or become part of a group.
- Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with our organisation’s aim to help clients maximise the potential of their data in a fair, lawful and transparent manner that we do not currently provide ourselves.
- Where an external 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we reasonably believe would be of benefit to you and you would reasonably expect to receive and is similar/aligned to our organisation. In this case, we would contact you using Legitimate Interest to request specific Consent to share your personal.
- Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
- Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
- Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:
Where we choose and/or have your permission to share/sell your personal data with 3rd Parties we will, where appropriate, ensure that they have signed a contract that requires them to:
- Abide by the requirements of all relevant data protection and privacy legislation;
- Treat your information as carefully as we would;
- Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
- Allow us to carry out checks to ensure they are doing all these things.
International Personal Data Transfer – Countries & Organisations:
Mirene Global Consults does not transfer personal data to any countries outside of Nigeria.
Personal Data Retention Period
Mirene Global Consults has the following data retention policies:
- Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
- Where you have purchased, or enquired about purchasing, a Mirene Global Consults product or services, we shall retain any personal details applicable to the contract delivery for a period of 7 years (name, email, telephone, postal address). During this time, we may contact you using legitimate interest to market additional products or services.
- Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number, company, job title) for a period of 7 years. During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you
- Where you have signed up to receive information emails from Mirene Global Consults, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 7 years, or until you withdraw your consent.
When we no longer need this information, we will erase or anonymise your data and/or dispose of it securely.
Your Right to Lodge a Complaint with NITDA
You have the right to lodge a complaint with the Supervising Authority: Nigerian Information Technology Development Agency. Prior to lodging a complaint, Mirene Global Consults would like the opportunity to address any complaint you may have.
Should you have a complaint please in the first instance contact our Data Protection Officer by emailing dpo@mireneglobalconsults.com.ng, or writing to:
Data Protection Officer
Mirene Global Consults
11A Aliu Animashaun street,
Off Babatunde Kuboye Street,
Lekki Phase 1,
Lagos
If your complaint has not been resolved, you can lodge a complaint with NITDA via email info@nitda.gov.ng or by writing to:
The Director General
National Information Technology Development Agency
No. 28, Port Harcourt Crescent, Off Gimbiya Street,
P.M.B 564, Area 11
Garki, Abuja, Nigeria.