Last updated: 16th August 2023

Nimbus Media Limited, (“Nimbus”) takes its responsibilities with regard to the management of personal data very seriously and we do not take lightly the trust you have reposed in us, in providing us with your personal information. This Policy describes how Nimbus processes your Personal Data, but it may not address all possible data processing scenarios. This Privacy Policy is a guide to help you understand:

The Information We Collect

We collect the following information: First Name, Last Name, Gender, Phone Number, Organization Name, Organization Type, Social Media Handles, and other related relevant information which constitute Personal Data or sensitive data.

How We Collect and Use Your Data

Nimbus collects the above-mentioned information using forms, email, physical requests, cookies, web tokens and pi-sync.

When you send email or other communications to Nimbus, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. When you access Nimbus’ services, our servers automatically record information that your browser sends whenever you visit a website.

We use the above-mentioned information for processing your application for the NIMBUS Aid Project, research, regulatory compliance, marketing, business development, listing on industry directories, publicity, human resources management, recruitment, events planning and hosting, in-house security and analysis, key business operation, processing or carrying out tasks to fulfill business goals or objectives and purposes that are agreed with you.

Consent and Access Rights

We require your consent for the processing of your data.

If we intend to use your data for a purpose which is different from the purpose for which your data was obtained, we will seek your consent prior to the use of your data for that other purpose.

In the event of any merger, acquisition or other arrangement whereby Nimbus sells or transfers all, or a portion of its business or assets (including in the event of a reorganization, dissolution or liquidation) to third parties, you hereby consent that your personal data held with Nimbus can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by Nimbus prior to such merger, acquisition or other arrangement. Nimbus shall at all times ensure that you are notified when your personal data is intended to be transferred to third parties in the circumstances outlined in this clause.

No consent shall be sought, given or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.

You may withdraw your consent, in writing, at any time and may request access to your personal information in our possession by sending a request to admin@nimbus.com.ng. We can, however, deny you access to the information where we determine that your request is unreasonable.

You reserve the right to request the modification or amendment of your personal data in our possession.

In all cases of access or modification / amendment of personal information, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed or modified / amended.

Your Rights

You have rights in relation to the way we handle your personal data. These include the following rights:

a) where the legal basis of our processing is consent, to withdraw that consent at any time;

b) to ask for access to the personal data that we hold;

c) to prevent our use of the personal data for direct marketing purposes;

d) to object to our processing of personal data in limited circumstances;

e) and to ask us to erase personal data without delay:

• if it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• How We Collect and Use Your Data
• if the only legal basis of the processing is consent and that consent has been withdrawn and there is no other legal basis on which we can process that personal data;
• if you object to our processing where the legal basis is the pursuit of a legitimate interest or the public interest and we can show no overriding legitimate grounds or interest;
• and if the processing is unlawful.

f) and to ask us to erase personal data without delay:

g) to restrict processing in specific circumstances e.g. where there is a complaint about accuracy;

h) to ask us for a copy of the safeguards under which personal data is transferred outside of Nigeria;

i) the right not to be subject to decisions based solely on automated processing, including profiling, except where necessary for entering into, or performing, a contract, with Nimbus;

j) it is based on your explicit consent and is subject to safeguards; or is authorized by law and is also subject to safeguards;

k) to prevent processing that is likely to cause damage or distress to you or anyone else; to data portability;

l) to be notified of a personal data breach which is likely to result in high risk to their rights and freedoms;

m) to make a complaint to the Nigerian Data Protection Commission (“NDPC”) or any other regulatory body;

n) and in limited circumstances, receive or ask for their personal data to be transferred to a Third Party in a structured, commonly used and machine-readable format.

Personal Data Protection Principles

When we process your personal data, we are guided by the following principles, which require personal data to be:

a) processed lawfully, fairly, in a transparent manner and with respect for the dignity of the human person.

b) collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

d) accurate and where necessary kept up to date.

e) removed or not kept in a form which permits identification of data subject for longer than is necessary for the purposes for which the personal data is processed.

f) processed in a manner that ensures its security, using appropriate technical and organizational measures to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage.

User Responsibility

You are required to familiarize yourself with this policy and to ensure that the information you provide to us is complete, accurate and up to date.

Data Security

Nimbus implements and maintains appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorized or unlawful processing or accidental loss, destruction of, or damage to their personal data.

Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting confidentiality (i.e. that only those who need to know and are authorized to use personal data have access to it), integrity and availability of the personal data. We regularly evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal data.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot guarantee absolute security. Nimbus, therefore, accepts no liability for any damage or loss, however caused, in connection with transmission over the internet or electronic storage.

Links to third party sites

The Nimbus website may contain links to other websites owned and operated by third parties. These links are provided for your information and convenience only and are not an endorsement by Nimbus of the content of such linked websites or third parties. The information that we collect from you will become available to these websites if you click the link to the websites. These linked websites are neither under our control nor our responsibility. Nimbus, therefore, makes no warranties or representations, express or implied about the safety of such linked websites, the third parties they are owned and operated by and the suitability or quality of information contained on them. This Privacy Policy does not apply to these websites, thus, if you decide to access these linked third-party websites and/or make use of the information contained on them, you do so entirely at your own risk. Nimbus accepts no liability for any damage or loss, however caused, in connection with accessing, the use of or reliance on any information, material, products or services contained on or accessed through any such linked websites. We advise that you contact those websites directly for information on their privacy policy, security, data collection and distribution policies.

Third Party Access

Nimbus will only share personal information with other companies, entities or individuals in the following limited circumstances:

a) We have your consent.

b) We provide such information to other professional advisers or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

c) We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce applicable terms of service, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to the rights, property or safety of Nimbus, its users or the public as required or permitted by law.

d) To fulfill the condition of any share acquisition or investment transaction involving Nimbus and a third party.

Nimbus is at all times responsible for the security and appropriate use of that data as long as it remains with Nimbus.

Violation of Privacy

We have put in place procedures to deal with any suspected personal data breach and will notify you of any personal data breach and let you know the steps we have taken to remedy the breach and the security measures we have applied to render your personal data unintelligible.

All suspected breach of personal data will be remedied within 1 (one) month from the date of the report of the breach.

If you know or suspect that a personal data breach has occurred, you should immediately contact the Nimbus team at admin@nimbus.com.ng.

Nimbus will not be responsible for any personal data breach which occurs as a result of:

a) an event which is beyond the control of Nimbus;

a) an event which is beyond the control of Nimbus;

b) an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises Nimbus’s data protection measures;

c) war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilization, requisition, or embargo;

d) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises Nimbus’s data protection measures;

e) the transfer of your personal data to a third party on your instructions; and

g) the use of your personal data by a third party designated by you.

Data Retention

Nimbus shall retain and use your Personal Data only as long as is necessary to implement, administer and manage your request and contract with Nimbus and a maximum of 5 years after the expiration or termination of the contract or as required to comply with legal or regulatory obligations, including under tax and security laws. At your request, at any time, your Personal Data which is in the custody of Nimbus may be deleted unless we are required by law to retain such information for a certain period of time so as to comply with our obligations under the law.