This privacy notice describes our policies and procedures on the collection, use and disclosure of your information and tells you about your privacy rights and how you can exercise them. By ‘your information’ we mean any information provided to us by you or a third party

Definitions

This privacy notice (the “Privacy Notice” or “this notice”) relates to all personal information processing activities carried out by The Pension Alliance Limited (PAL Pensions). PAL Pensions is a data controller of personal information collected and processed for our business (including the products and services that we provide). In this notice, references to:

You means the individual or business customer or partner (which includes suppliers or other organisations we do business with

Company (either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Pensions Alliance Limited or Pal Pensions

Account means a unique account created for you to access our service or parts of our service.

Personal Information is any information that relates to an identified or identifiable individual.

Consent

We will provide you with our privacy policy whenever we are collecting your personal information irrespective of the medium being used. Your consent will be obtained by asking you to click on a button to show acknowledgement of the policy if the medium being used to collect your personal information is in an electronic format. If your personal information is being collected through a paper document we will ask you to sign off on the document showing your understanding of our privacy policy.

Information Collected

While using our Service, We may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

 Information you give to us through our various touchpoints (i.e. website, paper forms, etc.)

• Information that we gather from publicly available sources, such as the press, company registers and online search engines
• Information that we receive from third parties – third parties who provide services to you or us, government agencies, and other
• Information that we learn about you when you use our services
• Information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition)

 Information Usage

When you provide your information to us, we may use the information we collect in the following ways:

To manage our relationship with you or your business

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage your Account: to manage your registration as a user of the service. The personal data you provide can give you access to different functionalities of the service that are available to you as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the service.
• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.

Information sharing

When you provide your information to us, we may use the information we will share your information on the following requirements: 

Business Transactions

If PAL Pensions is involved in a merger, acquisition or asset sale, Your Personal data may be transferred. We will provide notice before Your Personal data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the company may be required to disclose Your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other requirements

The Company may disclose Your Personal data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
• Consent is provided
• Required by court orders or legal process
• Violation of any part of our Privacy Notice
• Third parties conducting business on our behalf. These parties process such information for specific and limited purposes, in compliance with the privacy notice and any other appropriate confidentiality and security measures

Sensitive personal data (also known as special categories of personal data) make up information we collect from you. In particular, we may process, biometric data, for services that require it. We process such sensitive personal data when you have provided your consent or otherwise required by applicable law and these information will be collected and processed only for the particular purposes and activities for which the information is provided.

Transfer of Your Personal data

Your information, including Personal data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

Pal Pensions will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Information Retention

PAL Pensions will retain Your Personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will retain and use Your personal data to the extent necessary to comply with our contractual obligations with You and once our contract with you has come to an end (e.g. following retirement or closure of your account), we will only retain your personal data for a period of time that is, depending on the type of personal data, and the purposes for which we hold that information

 The Company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or We are legally obligated to retain this data for longer time periods.

 Your Rights
Subject to applicable laws, Nigeria data protection regulations and/or pension industry guidelines, you have the following rights:

• To request a copy of the personal data processed in relation to you
• To request that we correct your personal data
• To request us to delete your personal data, for example if we no longer have a valid reason to process it
• To object to how we process your personal data
• To restrict how your personal data is processed in certain cases, such as when the accuracy of your Personal data is contested
• To request a copy of the personal data you have given to us in a machine readable format

Cookies Policy

Cookies are small text files containing information which your computer or mobile device downloads when you visit a website, return to websites – or visit websites that use the same cookies – they recognize these cookies and therefore your browsing device .We do not store confidential or sensitive personal information in cookies.

To find out more about how we use cookies and what benefits they bring, please take a few moments to read this Cookie Policy.

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Why and How We Use Cookies on Our Website

We use cookies to improve your online activity session by making navigation easier and providing important security features.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

We use Cookies to track the activity on Our Service and store certain information

We use Google Analytics to collect the following types of information from users who have JavaScript enabled on their browser:

• Web browser used – software manufacturer, and version number
• Operating system
• Screen colours
• JavaScript support
• Flash version
• Screen resolution
• Network location and IP address
  • May include geographic
  • Hostname
  • Connection Bandwidth
• May include geographic data
• Hostname
• Connection bandwidth
• Time of visit
• Pages visited and dwell time on these pages
• Referring site
  • The referring website URL
  • Search engine query used

Google Analytics data is shared with Google. For more information on Google’s Privacy Policies, visit https://policies.google.com/privacy.

Cookie Category

Some cookies are needed to make our website work, but we need your consent to use others .The cookie categories are.

We do not use third party cookies on our website.

What are your choices regarding cookies?

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. This can be done in your browser settings. Since browsers differ, we recommend that you access the Help Menu to learn the correct way to modify your cookies.

If you turn your cookies off, some of the features that make your site experience more efficient may not function properly.

Where you can find more information about cookies

You can learn more about cookies at http://www.allaboutcookies.org/

Security

We will always hold your information securely. To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. This site uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.

Your information is regarded as confidential and will not be divulged to any third party except under legal and/or regulatory conditions. You have the right to request sight of, and copies of any and all information we keep on you, if such requests are made in compliance with the Freedom of Information Act and other relevant enactments. While Pensions Alliance Limited (PAL pensions) is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorized officers of the Agency.

Children’s Privacy

Our Service does not address children. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal data, please contact Us. If We become aware that We have collected Personal data from anyone that is considered a child without verification of parental consent, we take steps to remove that information from Our servers.

Changes to This Privacy Notice

Based on the changing nature of privacy laws, user needs and our business, this privacy notice may be updated from time to time. Any change to our Privacy Notice will be communicated on our website, and this will be effective as soon as published. Accordingly, we encourage periodic reviews of this Privacy Notice for awareness of any changes that may have occurred.

Governing Law

This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2019) or any other relevant Nigerian laws, regulations, or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation, or convention.

Contact us

Pensions Alliance Limited (PAL Pensions) strives to resolve your privacy complaints and concerns as quickly as possible. If you have a concern, complaint or questions regarding this Privacy Notice, you may contact us through the following means:

Head Office: Plot 289, Ajose Adeogun Street, Victoria Island, Lagos.

Phone: 0201-2776900,  080072573674667 (Toll free)

E-mail: dataprotection@palpensions.com or info@palpensions.com

Website: www.palpensions.com