This document is prepared in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Nigerian Data Protection Regulation (NDPR). It sets out how COURE Software and Systems Limited applies and complies with the principles of the regulations in processing the personal data of individuals, clients, vendors, and even third parties that interact with COURE Software and Systems Limited. For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed in compliance with the GDPR/NDPR.
| Roles | Responsibilities |
|---|---|
| Data Protection Officer | • To ensure that this notice is correct and up-to-date, and bring this notice to the awareness of data subjects prior to the collection and processing of personal data by the COURE Software and Systems Limited. |
| All Employees/Staff who interact with personal data |
• To follow the provisions of this privacy
notice document. • To seek the consent of data subject(s) for the secure processing of their personal data. • To ensure that this notice is brought to the attention of the data subject(s). |
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COURE Software & Systems Limited (“COURE”) is a Platform Services Provider. Since its formation, COURE has been focused on the accurate, secure and timely provision of relevant Data and the proper implementation of technology to improve its clients’ business processes and operations. COURE provides platforms that centralize Data access, management and delivery in a standardized manner. Through these platforms, COURE is able to aggregate various forms and types of data, analyze the data and create services that provide value.
The personal data we would collect and process, depending on the particular processing requirement, are under the following categories:
| Personal Data Type | Sources |
|---|---|
| Names | Website |
| Email Addresses | Website |
| Phone Numbers | Website |
In certain instances, the personal data we need to collect may fall under a special category of personal data, which includes: race, political opinion, ethnic origin, religion, philosophical beliefs, genetic/biometric data, health records, criminal records, or alleged criminal activity. In such instances, our lawful basis of processing will be the explicit consent of the data subject, compliance with a legal obligation, or for legal proceedings/advice.
COURE Software and Systems Limited ensures that the personal data collected and processed is necessary for the purpose of collection, and COURE Software and Systems Limited shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects.
COURE Software and Systems Limited requires your explicit consent to process collected personal data. And by consenting to this privacy notice, you are giving us the permission to use/process your personal data specifically for the purpose identified before collection. If, for any reason, COURE Software and Systems Limited is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used. You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the COURE Software and Systems Limited Withdrawal of Consent Procedure.
COURE Software and Systems Limited will not pass on your personal data to third parties without first
obtaining your consent.
Where there is a need for a third party to process the personal data of data subjects, COURE Software
and Systems Limited will enter into a Data Processing Agreement with the third party and be satisfied
that the third party has adequate measures in place to protect the data against accidental or
unauthorised access, use, disclosure, loss, or destruction.
In a case where the disclosure is to third parties outside the jurisdiction of the GDPR and NDPR, COURE
Software and Systems Limited will ensure that the third party meets the core regulatory standards
prior to the transfer. This may include transferring the personal data to the third party where COURE
Software and Systems Limited has satisfied that:
• The country of the recipient has adequate data protection controls established by legal or
self-regulatory regime.
• COURE Software and Systems Limited has a contract in place that uses existing or approved
data protection clauses to ensure adequate protection.
•COURE Software and Systems Limited is making the transfer under approved binding
corporate rules.
• COURE Software and Systems Limited is relying on approved codes of conduct or
certification mechanisms, together with binding and enforceable commitments in the
foreign country or international organisation to apply the appropriate safeguards in relation
to data subject rights.
• Provisions inserted into administrative arrangements between public authorities or bodies
authorised by the competent supervisory authority.
In compliance with the GDPR/NDPR data retention policy, COURE Software and Systems Limited when processing your personal data in addition to ensuring it is secure will retain the personal data for the minimum period necessary and/ or as required by applicable laws, until a time it is no longer required or has no use. This retention period enables us use the personal data for the necessary legitimate purposes identified, in full compliance with the legal and regulatory requirements. When we no longer need to use your personal information, we will delete it from our systems and records, and/or take steps to encrypt/anonymise it to protect your identity as the case may be.
Data subjects, according to the provision of the GDPR/NDPR, have certain rights. At any point while
COURE Software and Systems Limited are in possession of or processing your personal data, you, the
data subject, have the right to:
• Request a copy of the information that we hold about you.
• Correct the data that we hold about you that is inaccurate or incomplete.
• Ask for the data we hold about you to be erased from our systems/record.
• Restrict processing of your personal data where certain conditions apply.
• Have the data we hold about you transferred to another organisation.
• Object to certain types of processing like direct marketing.
• Object to automated processing like profiling, as well as the right to be subject to the legal
effects of automated processing or profiling.
•In the event that COURE Software and Systems Limited refuses your request.
under rights of access, we will provide you with a reason as to why and you have the right to
complain as outlined in clause 8 below.
All of the above requests will be forwarded on should there be a third party involved in the processing
of your personal data.
If for any reason you wish to make a complaint about how COURE Software and Systems Limited (or any of our third parties described in 3.4 above) processes your personal data, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and the Data Protection Officer of COURE Software and Systems Limited who can be reached at [email protected]
For more information on how we use your personal data and why, please visit
Personal Data
Under the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation
personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable
natural person is one who can be identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.”
Due to constant changes in technology and regulatory requirements, COURE Software and Systems
Limited may need to change its privacy policies or update this Notice from time to time. The data
Subject will always be able to find the most recent version of our updated privacy policy on the
website.
Why Does COURE Software and Systems Limited Need to Collect and Store Personal Data?
We need to collect your personal data in order for us to provide you with our services as mentioned
in clause 3.3 above. In any event, we are committed to ensuring that the information we collect and
use is appropriate for this purpose(s) only, and will in no way invade your privacy. If there is a need to
use your personal data for marketing purpose, COURE Software and Systems Limited will ensure to
seek additional consent from you.
Will COURE Software and Systems Limited Share My Personal Data with Anyone Else?
COURE Software and Systems Limited may pass your personal data to third-party service providers
contracted by us. Any third parties that we may share your personal data with is under an obligation
to secure your details, and use them only to fulfil the service for which they were contracted. When
they no longer need your details to fulfil this service, the data will be disposed in line with the COURE
Software and Systems Limited procedures. If we wish to pass your sensitive personal data onto a third
party we will only do so once we have obtained your consent, unless we are required to do otherwise,
legally.
How Will COURE Software and Systems Limited Use the Personal Data It Collects About Me?
We will process (collect, use and store) the information you provide in a manner that complies with
the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation. We
will endeavour to keep your information accurate and up to date, and not keep it for longer than is
necessary. COURE Software and Systems Limited is required to retain information in accordance with
the law, such as information needed for income tax and audit purposes. The retention period for
certain kinds of personal data may also be governed by specific business-sector requirements and
agreed practices. Personal data may be held in addition to these periods depending on individual
business needs.
Under what circumstances will the COURE Software and Systems Limited contact me?
We do not intend to be intrusive, and we will not ask irrelevant or unnecessary questions. Moreover,
we will subject the information you provide to rigorous measures and procedures to minimise the risk
of unauthorised access or disclosure.