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IMPORTANT PRIVACY NOTICE



HIB is an Insurance broking institution that processes data in furtherance to
the legitimate interest of the data-subject. We process various categories of
your data based on the type of engagement we have with you. Embedded
applications or codes (which are in some cases called “cookies”) on our website
may process your pattern of engagement with our website and thereby create
automated responses and notifications that seem most likely to suit your
interest. We accept your continued engagement with our website as your CONSENT
to the processing of your personal data. Click the following words TO READ OUR
DATA PRIVACY POLICY. This notice applies to HIB. Make sure you read privacy
notices on every website that you visit.

 

PREAMBLE:

Heirs Insurance Brokers Ltd (HIB) provide risk management solutions to help
protect and preserve what our customers value most.

This privacy policy is in consonance with the Nigeria Data Protection Regulation
(NDPR) requirement, Section 37 of the Constitution of the Federal Republic of
Nigeria (CFRN) 1999 (as amended) and all other legal instruments designed to
protect the privacy rights of natural persons.

 

As a company and the Data Controller, we are cognizant of the privacy rights of
all natural persons who are part of HIB or interact with us on all our data
processing mediums or platforms. These people are our “Data Subjects”. Hence, as
a responsible organization, we are committed to safeguarding the privacy rights
of our data subjects through this strict privacy policy.

 

SECTION 1:- OUR GUIDING PRINCIPLES ON DATA PROCESSING

We adhere strictly to the principles as set out in Article 2.1 of the NDPR in
the processing of data subjects ‘personal data. Therefore, we ensure that
personal data shall only be:

 1. a) collected and processed in accordance with specific, legitimate and
    lawful purpose consented to by the Data Subject;
 2. b) adequate, accurate and without prejudice to the dignity of human person;
 3. c) stored only for the period within which it is reasonably needed; and
 4. d) secured against all foreseeable hazards and breaches such as theft,
    cyber-attack, viral attack, dissemination, manipulations of any kind, damage
    by rain, fire or exposure to other natural elements.

 

 

SECTION 2:- CONSENT OF DATA SUBJECT

Except it is required by operation of law or principles of law, your consent as
the Data Subject is the entry point for data processing. You have the right to
give, withhold or otherwise withdraw your consent to data processing. For
further understanding of the operation of the principle of consent under data
processing see Articles 2.1(a), 2.2, 2.3 and 2.4 of the NDPR. Those who seek
information on our website or other platforms shall be deemed to have given
constructive consent to receiving information of specific or of general nature
through us from time to time.

 

SECTION 3:- OUR SCOPE OF DATA PROCESSING

In varying degrees vis-à-vis the insurance broking services, we render or your
level of engagement with us, we do process your personal data legitimately and
lawfully.

 

SECTION 4:- RIGHTS OF DATA SUBJECTS

As the Data Controller, we hold your privacy rights very dear to our operations.
Apart from the right to give, withhold or withdraw consent, you have rights to
all relevant information that may guide you in making informed decisions about
your personal data. For example, you have the right to be notified of anyone or
any place to which we may transfer your personal data. The totality your rights
include but are not limited to the following:

 

 * a) right to data portability,
 * b) right to erasure,
 * c) right to limit processing and
 * d) right to obtain your data.

SECTION 5:- WITHOLDING RELEVANT DATA

There are types of personal data that are mandatory for us to process in order
carry out your instruction for your benefit. If you withhold such information,
it may be impracticable for us to carry out our mandate in relation to you. If
you seek more clarification on our data processing, please contact our
designated Data Protection Officer as provided under SECTION 12 below.

 

 

SECTION 6:- TECHNICAL INFORMATION

Usually, websites are designed to collect certain information from the visitor.
Our website is also designed to collect your IP address and other information
that your web browser typically shares with the websites that you visit. The
purpose of this is to know you better and to automatically and dynamically
engage with you through your actions and preferences on our website.

 

SECTION 7:- PERSONAL DATA SECURITY AND INTEGRITY

HIB engage the use cutting-edge technologies and foolproof protocols to provide
you with comprehensive layers of security in the area of personal data. Thus, we
are constantly vigilant in preventing cyber-attacks, fraudulent intrusion,
unauthorized access, loss or corruption of personal data. We are equally
conscious of the obligations imposed on us by law in terms of data protection.

 

SECTION 8:- PURPOSE AND STORAGE LIMITATION

The Intention for data processing usually determines the length of time within
which your personal data is stored with us and the residue of data actually
stored for this purpose. We reasonably collect and store personal data that is
reasonably required by law or best practice to serve you or respond to
legitimate enquiry about our transaction with you. We take this responsibility
very seriously in the knowledge of the need for you to enjoy your privacy as
guaranteed under the 1999 Constitution of the Federal Republic of Nigeria and
international human rights law.

 

SECTION 9:- CAVEAT ON WEBSITE LINKS:

Our website may contain links to other websites. Save and except as otherwise
expressly stated by us, any link to another website is not covered by our
privacy policy. We strongly advise that you should satisfy yourself with the
details of any privacy policy provided on other websites or links.

 

SECTION 10:- TRANSFER TO THIRD PARTIES AND COUNTRIES

In helping to protect what our customers valued most, we may require the
services of third party vendors who may be within or outside the NDPR
jurisdiction (Nigeria). Examples of such services include but are not limited to
the following:

 

 * a) Internet connectivity,
 * b) cloud storage,
 * c) data analytics,
 * d) data security,
 * e) software development, and
 * f) Legitimate Public interest.

 

However, in transferring your data to third parties, we shall be guided by
extant public policy of the NDPR as regards the adequacy level of the foreign
jurisdictions. See PART 2 Article 2.11 and PART 3 under the NDPR for details of
your right under this section.

SECTION 11: – USE OF SPECIAL DATA PROCESSING CODES (COOKIES)

“Cookies”, are text files that are downloaded to your browsing devices such as
phones or computers when you visit our websites. They contain small amounts of
data and their essential function is to intelligently memorize your preferences
and therefore present them to you as choices when you are browsing – even at
different times. Note that various websites use cookies for different purposes
some of which may undermine your privacy rights. We have taken measures to
ensure that all methods adopted by us to engage automatically with you do not
violate your privacy rights under the NDPR. In the case of cookies, we ensure
that they have security protocols and are not vulnerable to abuses by anyone.

 

SECTION 12:- DATA PRIVACY SERVICE UNIT (DPSU).

A platform has been provided to respond promptly and satisfactorily to all your
requests, suggestions and complaints. This is called the DPSU. We have a Data
Protection Officer responsible for prompt action on your data privacy. Contact
the DPSU via this link: dpo@heirsinsurancebrokers.com

 

Our DPSU serves as the internal mechanism to carry out the following services
amongst others:

 * a) Data protection regulations compliance and breach services
 * b) Data protection and privacy advisory services
 * c) Data protection capacity building
 * d) Data Regulations Contracts drafting and advisory
 * e) Data protection and privacy breach remediation planning and support
   services
 * f) Information privacy audit
 * g) Data privacy breach impact assessment
 * h) Data Protection and Privacy Due Diligence Investigation
 * i) Data Protection Officer

 

SECTION 14:- REMEDIATION

Data subjects are encouraged to report any complaint or concern about their data
privacy through the DPSU. Our team at the DPSU shall take action to redress any
grievance within 7 working days.

 

SECTION 15:- ALTERATION OF PRIVACY POLICY

The Data Controller reserves the right to alter the foregoing policy for the
purpose of advancing data privacy rights, public interest or complying with
lawful directives of the Federal Government.




CONTACT DETAILS

+234 1 2774641-5
info@heirsinsurancebrokers.com

ADDRESS

Afriland Towers
97/105, Broad Street
Lagos Island, Lagos, Nigeria

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