Introduction

This Privacy Notice ("Notice") governs your use of all our products and services, which includes our websites and Apps listed below (collectively referred to as "Our Products") and your rights regarding our collection, use, storage and protection of your data. Your privacy is important to us.
Websites

• https://smartcomply.com/
• https://intel.smartcomply.com/
• https://secure.smartcomply.com/
• https://adhere.smartcomply.com/

• https://intel.smartcomply.com/login
• https://app.smartcomply.com/
• https://adhere-app.smartcomply.com/

Privacy Notice Overview

Smartcomply Technology Solutions Limited is dedicated to protecting the privacy of its merchants and users. As such, we have implemented the necessary measures to comply with the Nigeria Data Protection Regulation (NDPR), Nigeria Data Protection Act (NDPA), which is designed to regulate the collection, processing, and use of personal data in Nigeria.

Who are we?

We are Smartcomply Technology Solutions Limited (hereinafter referred to as 'Our Products'). The Bunker Building 279 Herbert Macaulay Way Yaba, Lagos, Nigeria. You can contact us at the above address, by email at support@smartcomplyapp.com or by telephone on +234 813 326 2024.

Personal Information Collected

As a user or merchant using our products, we may collect your personal information including:

• full name
• email address
• phone number
• postal/company address
• billing and transaction details
• demographic information

Cookies

Cookies are tools used to automatically collect information from you when you use Our Products. When you use our website to browse our products and services and view the information we make available, a number of cookies are used by us and by third parties to allow the website to function, to collect useful information about visitors and to help to make your user experience better.
Some of the cookies we use are strictly necessary for our website to function, and we do not ask for your consent to place these on your computer and information about the usage is specified in ourCookie Notice.

Legal bases

We are required to process your data under at least one of these lawful bases:

1. Legitimate interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided your rights and interests do not outweigh those interests.

2. Consent: You have given explicit consent for us to process your data for a specific purpose.

3. Legal obligation: If the processing of your data is necessary where there is a statutory obligation on us.

Purpose of processing your data and the lawful bases

We collect your data to:

Protection of Personal Information

Smartcomply is committed to protecting your personal information from unauthorized access, misuse, loss, modification, or disclosure. We have implemented appropriate technical, physical, and administrative safeguards to ensure the confidentiality, integrity, and availability of personal information.

Disclosure of Personal Information

To protect your privacy is our priority, we limit the sharing of your Personal Information outside of Adhere. We will not share Personal Information about you except under the circumstances listed below.
Smartcomply may disclose personal information to its service providers and third-party vendors who work on our behalf. The service providers we use are obligated by contract to keep your personal information private and secure and only use it for its intended purposes in compliance with this Notice. It's important to note that the data protection laws of the service provider's country may not be as stringent as those in your country.
By agreeing to this Notice, you acknowledge and authorize these third-party service providers to use your personal information. We will take all reasonable precautions to ensure your information is treated with the utmost security and in compliance with the Privacy Notice, and we will not transfer your personal information without appropriate measures being taken. Your information is shared or disclosed with your permission or based on your direction, for instance, if you allow a third-party website client or app to access your account.
Smartcomply also reserves the right to disclose your personal information where required by law to regulatory, law enforcement, or other government authorities, including during routine regulatory inspections.

Your Rights

We will like to ensure that our users and merchants are aware of their rights.
As data subjects, you have the following data protection rights:

• By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.
• If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
• If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
• If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
• You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.
• You have the right to ask us to erase your personal data
• Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.

To exercise these rights or lodge a complaint, please contact Smartcomply's Data Protection Officer.

The contact details of our Data Protection Officer are:

Name: Opeyemi Ajakaye-Maku

Post Address: The Bunker Building 279 Herbert Macaulay Way, Yaba, Lagos, Nigeria.

Phone Number: +234 708 650 1941

Data retention period

Your data or any other information collected will be stored for as long as necessary to fulfil the purposes described in this Notice. However, we will also retain data subject to relevant provisions of applicable laws, resolve disputes, and enforce our legal agreements and policies.

Cookie Policy

Our website and web application currently do not use any cookies or similar tracking technologies to store personal information or track user activity. As we are committed to your privacy and compliance with the Nigeria Data Protection Regulation (NDPR) and Nigeria Data Protection Act (NDPA), we will notify you of any future updates to this policy, including the introduction of cookies. Should we implement cookies in the future, you will be provided with detailed information about the types of cookies, their purposes, and options to manage your cookie preferences. For now, you can browse with confidence that no data is being collected through cookies

International transfer of data

To achieve the purposes described in this Notice, we may transfer your data to countries that may not offer an adequate protection level or are not considered to have sufficient law by the Nigeria Data Protection Regulation (NDPR) and Nigeria Data Protection Act (NDPA).
Where personal data is to be transferred to a country outside Nigeria, we shall put adequate measures to ensure data security.
Our data transfers to countries that do not offer an adequate protection level are subject to the Nigeria Data Protection Regulation (NDPR) conditions. We will therefore only transfer Personal Data out of Nigeria on one of the following conditions:

• Your consent has been obtained;
• The transfer is necessary for the performance of a contract between us and you or implementation of pre-contractual measures taken at your request;
• The transfer is necessary to conclude a contract between us and the third party in your interest;
• The transfer is necessary for reason of public interest;
• The transfer is for the establishment, exercise or defense of legal claims; or
• The transfer is essential to protect your vital interests or other persons, where the data subject is physically or legally incapable of giving consent

Please get in touch with us to obtain relevant information regarding your data transfers to third countries (including the appropriate transfer mechanisms).

Complaints

If you are concerned about an alleged breach of data protection law or any other regulation by us, you can contact the Data Protection Officer (DPO). The DPO will investigate your complaint and provide information about how your complaint is handled.
Please be informed that you may complain to the relevant data protection authority where your complaints are not satisfactorily addressed.

Changes to Privacy Notice

The most current version of this Notice governs our processing of your personal data and we may revise this Notice from time to time as needed. Smartcomply reserves the right to change its Notice as needed for compliance with NDPA & NDPR. Any changes to this Notice will be posted on our website, and the effective date will be indicated.

Contact Us

If you have any questions, concerns, or suggestions regarding our Privacy Notice, please contact our Data Protection Officer.
You may further contact us via
Phone: +234 813 326 2024
Address: The Bunker Building 279 Herbert Macaulay Way Yaba, Lagos, Nigeria.