Preamble

Our Retail Team provides a broad range of policies to meet the needs of individuals across different income levels and need requirements. Whether in need of an education plan, investment plan, whole life scheme, etc. our experts will listen to you, understand your needs and structure the best plan to suite your income and lifestyle.

1. Introduction.

This Data Privacy and Protection Policy (the “Privacy Policy” or “Privacy Notice”) describes your privacy rights regarding Scib Nigeria and Company Limited (“Scib” “we”, “us” or “our”) collection, use, storage, sharing and protection of your personal identifiers, electronic network activity information, professional information, location informa tion and other types of information. It applies to our platform, website and all related sites, applications, services, and tools (“Services”) regardless of how you access or use them.
This Privacy Policy applies to all forms of systems, operations and processes within our environment that involve the collection, storage, use, transmission, and disposal of Personal Information (described below). It is provided to help you understand what information we collect from you, how the information collected is used, how we protect it, and your rights to it, amongst others.
This Privacy Policy is strictly restricted to only our Services and therefore does not apply to services that are not owned or controlled by us, including third-party platforms/websites. We are committed to handling all personal data provided to us in compliance with applicable data privacy and protection laws.

2. Consent.

By accessing or using our Services in any manner, you indicate to us that you have read and accepted this Privacy Policy and consent to the data practices described in this Privacy Policy.
You agree that upon granting us your consent, you have the legal capacity to give consent and you are aware of your privacy rights and your option to withdraw your consent at any given time.

3. The Information We Collect - Personal Information.

As part of our operations, we collect and process certain types of information (such as name, telephone numbers, address etc.) of individuals that makes them easily identifiable. These individuals include current, past, and prospective employees, suppliers/vendors, clients or former clients, and other individuals whom we communicate or deal with, jointly and/or severally (“Data Subject(s)”)
To use our Services, you will voluntarily provide us with certain Personal Information. Personal Information refers to information relating to an identified person or information that can be used to identify you. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our Services or under applicable legislations or regulations.
The following are the information that we collect, and process may include:

1. Individual personal information (e.g., name, previous names, date of birth, etc.);
2. Individual personal contact details (e.g., address, email address, mobile numbers);
3. Identify information (e.g., photo ID, nationality, utility bill, national ID card and/or number);
4. Information about the ways you interact with Scib (e.g., channels used, email information, software used and information);
5. Any information received from external authoritative registers required for compliance purposes.
6. Information captured in customer documentation or data exchange such as application forms or advice documents or via telephone.
7. Marketing and promotional information (e.g., details of the services we offer and your preferences);
8. Cookies and similar technologies used to remember your preferences and tailor content;
9. Data or records of correspondence related to relevant exchanges of information (e.g., emails);
10. Information to fulfill regulatory obligations (e.g., transaction details, user activity);
11. Information from other entities (e.g., relevant transaction information)
12. Information from third parties providing information to identify and manage fraud;
13. Closed circuit television (CCTV) in and around Scib facilities (these may collect photos or videos of you); and
14. Other information about you that is voluntarily provided by filling in online forms or by communicating with us, whether face-to-face or via other available channels (e.g., by phone, email, or online. Other information about you that is voluntarily provided by filling in online forms or by communicating with us, whether face-to-face or via other available channels (e.g., by phone, email, or online.

In providing you with our Products or Services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and your personally identifiable information is treated in a safe and secure manner.

4. We use your Personal Information to:

1. provide you with the required insurance products and insurance broking and risk advisory services;
2. respond to your questions or requests;
3. improve features, platform and website content and analyse data to develop products and services;
4. address inappropriate use of our Products and services;
5. prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools;
6. send you newsletters and service updates curated by us, however, we will provide you with an option to unsubscribe if you do not want to hear from us;
7. verify your identity and the information you provide in line with our statutory obligations using internal and third party tools;
8. maintain up-to-date records;
9. resolve disputes that may arise, including investigations by law enforcement or regulatory bodies; and
10. any other purpose that we disclose to you while providing our services to you.

5. Information that we collect from Platform Visitors.

We do not collect any unauthorized Personal Information when you request our services or visit our website except for the purpose for which you have consented that we do so. For the avoidance of doubt, any Personal Information collected for the purpose of carrying out the services or providing you with the required products will be done further to your consent and shall be used only for the purpose communicated.
We may collect non-personally identifiable information to monitor and improve our services. We will not share or disclose this information with third parties except as a necessary part of providing our Services to you or In compliance with legal and regulatory obligations.

6. Purpose Limitation.

We collect Personal Information only for identified purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose or is in compliance with legal and regulatory obligations.

7. Data Processing Principles.

Your personal data will be:

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

8. Data Minimization.

We limit Personal Information collection and usage to data that is relevant, adequate, and necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

9. Cookies.

Cookies allow our servers to remember IP addresses, date, and time of visits, and monitor web traffic. Our cookies never store personal or sensitive information.

10. How We Protect Your Information.

We shall establish adequate controls to protect the integrity and confidentiality of your Personal Information, both in digital and physical format and to prevent your Personal Information from being accidentally or deliberately compromised.
We are committed to managing your Personal Information in line with industry best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration, we also use security protocols to safeguard your Personal Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to your Personal Information to only employees who require it to fulfil their job responsibilities. No Personal Information processing will be undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties.
Employees may have access to your Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use your Personal Information for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.

11. How We Use the Information You Provide.

We use the information we collect for business and commercial purposes such as:
to operate, improve, and develop our services and to verify your identity and the identities of other members of your company, We use your information to comply with law, such as for tax reporting purposes and to send you technical notices, updates, security alerts, and administrative messages; to respond to your comments, questions, inquiries, and customer service requests.
We use your data to help personalize the service experience for you to communicate with you about products, services, offers, and events offered or sponsored by Scib, and to provide news and other information we think may be of interest to you. Information that we collect is also used to monitor and analyse trends, usage, and activities in connection with our Services, to detect and prevent fraud, malicious activity, and other illegal activities. We use your data to protect the rights, privacy, safety, or property of Scib and others; and for any other purpose described to you when the information was collected.

12. How We Share the Personal Information You Provide.

We do not sell, trade, or rent personal information to anyone. However, to enable us to render our services to you, we may share your information with trusted third parties, such third parties include insurance institutions, financial institutions, sanctions screening and identity verification services as well as any third parties that you have directly authorised to receive your Personal Information. Your Personal Information may be stored in locations outside our direct control, for instance, on servers or databases co-located with hosting providers. We may disclose your Personal Information in compliance with applicable law or a legal obligation to which we are bound.

13. Transfer of Personal Information -

We may share your information with regulatory agencies, law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

1. comply with a legal obligation, process, or request (including tax and related reporting requirements);
2. enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
3. detect, prevent, or otherwise address security, fraud, or technical issues; or
4. protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection , money laundering, terrorist financing and proliferation financing).

14. Transfer of Personal Information to Foreign Country.

Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act ("NDPA”). We will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

1. the consent of the Data Subject has been obtained;
2. the transfer is necessary for the performance of a contract between us, and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request;
3. the transfer is necessary to conclude a contract between us and a third party in the interest of the Data Subject;
4. the transfer is necessary for reason of public interest;
5. the transfer is for the establishment, exercise, or defence of legal claims;
6. the transfer is necessary to protect the vital interests of the Data Subjects or other persons.

We will take all necessary steps to ensure that your Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request

15. Ground for Processing of Personal Information - Our Lawful Basis for Processing Personal Information.

We will only use and process your personal data as permitted by the Nigerian Data Protection Act 2023. We have set out below a description of all the legal bases we may rely on to process your personal data:

1. where you or your data controller have given, us consent to the processing of your personal data for one or more specific purposes;
2. where processing is necessary for the performance of a contract to which you or your data controller area party or to take steps at youror data controller’s request prior to entering into a contract;
3. where processing is necessary for compliance with a legal obligation to which we are subject;
4. where processing is necessary to protect your vital interests or the vital interests of another natural person, and
5. where processing is necessary for the performance of a task carried out in the public interest or in exercise of an official public mandate vested in us.

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 personal data.

16. The Data that We Retain.

We will retain your Personal Information for as long as is needed to provide our services to you, comply with our legal and statutory obligations or verify your information with the required verification authorities.
We are statutorily obligated to retain the Personal Information and data you provide us with to process transactions, ensure settlements, make refunds, identify fraud, holistically carry out our services and in compliance with laws and regulatory guidelines applicable to us and our service partners. Therefore, even after discontinuance of our services, we will retain certain Personal Information and transaction data to comply with these obligations.
For all Personal Information and records obtained, used, and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity, and requirement to retain.
The length of storage of your Personal Information shall, amongst other things, be determined by:

1. the contract terms agreed between us and the Data Subject or as long as it is needed for the purpose for which it was obtained, subject regulatory requirement on data retention; or
2. whether the transaction or relationship has statutory implication or a required retention period; or
3. whether we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

17. Choices and Rights

Once your Personal Information is held by us, you are entitled to reach out to us to exercise the following rights:

1. Request access to your personal data (commonly known as a “data subject access request”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). Alternatively, we may notify you of our refusal to comply with your request in these circumstances. Where we have reasonable doubts concerning the identity of the natural person making the request for information, we may request the provision of additional information necessary to confirm the identity of the Data Subject. Where data is held electronically in a structured form, such as in a Database, as the Data Subject, you have a right to receive that data in a common electronic format;
2. Right to request correction of the personal data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Right to request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Right to object to the processing of your personal data: Where we are relying on a legitimate interest (or those of a third party) there maybe something about your situation which could justify an objection to processing on this ground. we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Right to request restriction of processing of your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
   1. If you want us to establish the data’s accuracy;
   2. Where you need us to hold the data even if we no longer require it; or
   3. You have objected to our use of your data but we need to verify whether we have overridingright/obligation to continue to hold the data.
6. Request the transfer of your personal data to you or to a third party: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data: However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations.

18. Age Restriction.

If you access our Services or Platform and you are below 18 years, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s). If you have inadvertently provided personal data of a child to us, please notify us at dpo@scibng.com. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

19. Compliance with Local and International Regulatory Best Practices.

We confirm that we comply with the NDPA on data collection, transmission, usage, and protection. We also, for best practices, adopt pertinent best practices to the extent that they do not conflict with Nigerian data protection regulations and laws.

20. Updates, Modifications and Amendments.

We reserve the right to update, modify, change, or revise this Privacy Policy from time to time. The changes will not be retroactive, and the most current version of this Privacy Policy which will always be on this page and will continue to govern our relationship with you. We advise that you check this page often, referring to the date of the last modification on the page. By continuing to use our Services after the changes become effective, you agree to be bound by the revised Privacy Policy.

21. Complaints and Remedies.

You may file a complaint in accordance with this privacy policy if you believe that any provision of this privacy policy or your privacy rights have been violated in respect of your personal information to enable us to take the necessary steps towards ensuring the security of your Personal Information.
All complaint must be addressed to the company by sending an email to our Data Protection Officer using the following contact details:
Address:
66, Adeniran Ogunsanya Street,
Surulere,
Lagos State Nigeria.

Email: dpo@scibng.com
Please note that, the complaint and resolution procedure is not prejudicial to your right to complain to the data protection authorities, the Nigeria Data Protection Commission.
We also have a duty of self-reporting of Personal Information breaches to NDPC within 72 hours of being aware of such breach.
We would, however, appreciate the chance to deal with your concerns before you approach the data protection authorities. Kindly contact us in the first instance by sending an email to: scib@scibng.com or dpo@scibng.com

22. Questions and Inquiries.

You may also contact us if you have any questions relating to this Privacy Policy or would like to find out more about exercising your data protection rights. All questions, comments and requests regarding this policy should be addressed to scib@scibng.com or dpo@scibng.com, we can be reached at:
66, Adeniran Ogunsanya Street,
Surulere, Lagos, Nigeria.