HomePrivacy Policy

Privacy Policy

Reposebay respects your privacy and is committed to protecting your personal data.
This privacy policy will inform you as to how we look after your personal data when you
visit our website regardless of where you visit it from and tell you about your privacy
rights and how the law protects you.


Purpose of this privacy policy
This privacy policy aims to give you information on how Reposebay collects and
processes your personal data through your use of this website, including any data you
may provide through this website when you sign up for our newsletter, purchase a
product or service, provide feedback or in any other manner interact with us. This
website is not intended for children and we do not knowingly collect data relating to

You must read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why we are
using your data. This privacy policy supplements other notices and privacy policies and
is not intended to override them.
Reposebay HR Limited is the controller and responsible for your personal data
(collectively referred to as “Reposebay”, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise
your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please
contact us in the following ways: Full name of legal entity: Reposebay Human Resource
Limited Email address: info@reposebayhr.com Telephone number: +234 8022629576
You have the right to make a complaint at any time to the National Information
Technology Development Agency (NITDA), the Nigerian regulator for data protection
issues (www.nitda.gov.ng). We would, however, appreciate the chance to deal with
your concerns before you approach the NITDA so please contact us in the first instance.
Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking
on those links or enabling those connections may allow third parties to collect or share
data about you. We do not control these third-party websites and are not responsible
for their privacy statements. When you leave our website, we encourage you to read
the privacy policy of every website you visit.



Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the identity has
been removed. We may collect, use, store and transfer different kinds of personal data
about you which we have grouped as follows:
• Identity Data includes first name, maiden name, last name, username or similar
identifier, marital status, title, date of birth and gender.
• Contact Data includes billing, delivery, email, and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details
of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices you use to
access this website.
• Profile Data includes your username and password, purchases or orders made by you,
your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and
• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data could be derived from your data but is not
considered personal data in law as this data will not directly or indirectly reveal your
identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can directly or indirectly

identify you, we treat the combined data as personal data which will be used per this
privacy policy.
We do not collect any Special Categories of Personal Data about you this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your health,
and genetic and biometric data. Nor do we collect any information about criminal
convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we
have with you, and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for example, to
provide you with services). In this case, we may have to cancel a product or service
you have with us but we will notify you if this is the case at the time.


We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by
filling in forms or by corresponding with us by post, phone, email or otherwise. This
includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data about
your equipment, browsing actions and patterns. We collect this personal data by using
cookies, server logs and other similar technologies. We may also receive Technical Data
about you if you visit other websites employing our cookies. Please see our cookie
policy for further details.
Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources as
set out below.
Technical Data from the following parties:
(a) analytics providers
(b) advertising networks
(c) search information providers.
● Contact, Financial and Transaction Data from providers of technical, payment
and delivery services.
● Identity and Contact Data from data brokers or aggregators.
● Identity and Contact Data from publicly available sources.
We will only use your personal data when the law allows us to. Most commonly, we will
use your personal data in the following circumstances:
● Where we need to perform the contract we are about to enter into or we have
entered into with you.
● Where it is necessary for our legitimate interests or those of a third party and your
interests and fundamental rights do not override those interests.
● Where we need to comply with a legal obligation. Generally, we do not rely on
consent as a legal basis for processing your personal data although we will get
your consent before sending third-party direct marketing communications to you
via email or text message. You have the right to withdraw consent to marketing
at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data,
and which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate. Note that we may process your personal
data for more than one lawful ground depending on the specific purpose for which we
are using your data.
How do we use your data?
● We use your phone number to retrieve your registered Bank accounts
● We use your PIN to validate your transactions.
● We use your email to verify your registration.

● We use your other personal details to present data to you on the channels we
reach you at.
We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to you. This is how
we decide which products, services and offers may be relevant for you. You will receive
marketing communications from us if you have requested information from us or
purchased goods or services from us and you have not opted out of receiving that
Third-party marketing
We will get your express opt-in consent before we share your personal data with any
third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by
following the opt-out links on any marketing message sent to you or by contacting us at
any time. Where you opt out of receiving these marketing messages, this will not apply
to personal data provided to us as a result of a product/service purchase, warranty
registration, product/service experience or other transactions.
You can set your browser to refuse all or some browser cookies or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that some
parts of this website may become inaccessible or not function properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please contact
us. If we need to use your personal data for an unrelated purpose, we will notify you
and we will explain the legal basis which allows us to do so. Please note that we may

process your personal data without your knowledge or consent, in compliance with the
above rules, where this is required or permitted by law.


We may share your personal data with the parties set out below for the purposes set out
in the table [Purposes for which we will use your personal data] above.
● Internal Third Parties as set out in the Glossary.
● External Third Parties as set out in the Glossary.
● Third parties to whom we may choose to sell, transfer or merge parts of our
business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same
way as set out in this privacy policy. We require all third parties to respect the security of
your personal data and to treat it per the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them to
process your personal data for specified purposes and in accordance with our


We may share your personal data with our affiliate companies or external third parties.
This may involve transferring your data outside Nigeria. We ensure your personal data is
protected by requiring all our affiliate companies to follow the same rules when
processing your personal data. Whenever we transfer your personal data out of Nigeria,
we ensure a similar degree of protection is afforded to it. We will only transfer your
personal data to countries that have been deemed to provide an adequate level of
protection for personal data. Please contact us if you want further information on the
specific mechanism used by us when transferring your personal data out of Nigeria.



We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need to know. They will
only process your personal data on our instructions and they are subject to a duty of
confidentiality. We have established procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we
are legally required to do so.

How long will you use my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the
purposes we collected it for, including the purposes of satisfying any legal, regulatory,
tax, accounting or reporting requirements. We may retain your personal data for a
longer period in the event of a complaint or if we reasonably believe there is a
prospect of litigation with respect to our relationship with you. To determine the
appropriate retention period for personal data, we consider the amount, nature and
sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data
and whether we can achieve those purposes through other means, and the applicable
legal, regulatory, tax, accounting or other requirements. In some circumstances, you
can ask us to delete your data.
In some circumstances, we will anonymise your personal data so that it can no longer
be associated with you for research or statistical purposes, in which case we may use
this information indefinitely without further notice to you.
How do we store your data?
● We store sensitive data encrypted in data security vaults.
● We store non-sensitive data in clear text in our databases.


Under certain circumstances, you have rights under data protection laws in relation to
your personal data and if you wish to exercise any of the rights, please contact us.
These rights are stated below:
● The right to access – You have the right to request Reposebay for copies of your
personal data.
● The right to rectification – You have the right to request that Reposebay correct
any information you believe is inaccurate. You also have the right to request
Reposebay to complete information you believe is incomplete.
● The right to erasure – You have the right to request that Reposebay erase your
personal data, under certain conditions.

● The right to restrict processing – You have the right to request that
Reposebay restrict the processing of your personal data under certain
● The right to object to processing – Under certain conditions, you have the right to
object to Reposebay processing of your personal data.
● The right to data portability – You have the right to request that
Reposebay transfer the data that we have collected to another organization, or
directly to you, under certain conditions.
No fee is usually required
You will not have to pay a fee to access your personal data or to exercise any of the
other rights. However, we may charge a reasonable fee if your request is unfounded,
repetitive or excessive. Alternatively, we could refuse to comply with your request in
these circumstances
What we may need from you
We may need to request specific information from you to help us confirm your identity
and ensure your right to access your personal data or to exercise any of your other
rights. This is a security measure to ensure that personal data is not disclosed to any
a person who has no right to receive it. We may also contact you to ask you for further
information about your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take
us longer than a month if your request is particularly complex or you have made several
requests. In this case, we will notify you and keep you updated.


We may change, amend or review our privacy policy from time to time if required by
the law and reflect our new services or changes. You will however be notified of this
change by placing notice online or via mail.

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