How We Use Personal Data

• Provide you with the required services


• Respond to your questions or requests


• Improve features, website content and analyze data to develop services


• Address inappropriate use of our website


• Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools


• Send you marketing content, newsletters, and service updates carefully chosen and thoughtfully organized or presented by Swift Complaint Hub. However, we will provide you with an option to unsubscribe if you do not want to hear from us


• Verify your identity and the information you provide in line with Swift Complaint Hub’s statutory obligations using internal and third-party tools


• Maintain up-to-date records of clients


• Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies


• Any other purpose that we disclose to you in the course of providing Swift Complaint Hub services to you

How We Share The Personal Data You Provide

Swift Complaint Hub does not sell, trade or rent personal data to anyone. Further, we will not share or disclose your personal data with a third party without your consent except as necessary to provide the Services or as described in this Privacy Policy.

• Legal and Law Enforcement. We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.


• Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:
  • Protect our clients and others, for example to prevent fraud, or to help prevent the loss of life or serious injury of anyone;
  
  
  • Operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
  
  
  • Protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

Third party analytics and advertising companies also collect personal data through our website and apps including, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at How Google uses information from sites or apps that use our services – Privacy & Terms – Google

Please note that some of our services include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

Finally, we may share de-identified information in accordance with applicable laws.

How We Protect Your Information

Swift Complaint Hub has established adequate technical and organisational controls to protect the integrity and confidentiality of your Personal Information, both in digital and physical format, whilst preventing Personal Information from being accidentally or deliberately compromised.

Swift Complaint Hub is committed to managing your Personal Information in line with best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration, we also use industry recommended 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 Personal Information to only employees who require it to fulfil their job responsibilities.

In addition, Swift Complaint Hub maintains a data breach procedure in order to deal with incidents concerning Personal Information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information transmitted, stored or otherwise processed. You may contact our DPO upon becoming aware of any breach of Personal Information or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your Personal Information or account. We will report any breaches that will compromise your rights and freedoms to the Relevant Authority within 72 hours of discovery.

It is vital to make mention that our payment terminal is powered by Paystack who are in compliance with the Payment Card Industry Data Security Standard (PCI DSS Requirements”), they implement access control measures, security protocols and standards including the use of encryption and firewall technologies to ensure your card information is safe and secure in their servers, additionally, they implement periodical security updates to ensure that their security infrastructures follow reasonable industry standards.

Storage Limitation

• As long as reasonably necessary for the purpose of providing our services to you


• For the duration your account is active and we have your consent


• For the period needed to comply with our legal and statutory obligations


• As needed to verify your information with the industry you have made a complaint about

• The contract terms agreed between Swift Complaint Hub and the Client or as long as it is needed for the purpose for which it was obtained;


• Whether the business relationship has statutory implication or a required retention period;


• Whether there is an express request for removal of Personal Data by the client, provided that such request will only be treated where the Data Subject is not under any investigation which may require Swift Complaint Hub to retain such Personal Data or there is no existing contractual arrangement with the Data Subject that would require the processing of the Personal Data;


• Whether Swift Complaint Hub has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

Transfer of Personal Data

As part of our service provision, we may rely on third-party servers, databases co-located with hosting providers, resident in foreign jurisdictions, which constitutes the transfer of your personal data to computers or servers in foreign countries. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law wherever the data is located.

Where personal data is to be transferred to a country outside Nigeria, Swift Complaint Hub shall put adequate measures in place to ensure the security of such Personal Information. Any transfer of Personal Information out of Nigeria will be in accordance with the provisions of relevant data protection regulations. In particular, Swift Complaint Hub shall, among other things, use contractual terms to ensure protection of the data or ensure the country has adequate data protection laws (i.e. listed in the National Information Technology Development Agency’s [“NITDA”] White List of Countries, or the General Data Protection Regulation’s [“GDPR”] Adequacy List).

Should you wish to transfer personal data to a country deemed to have inadequate data protection laws, Swift Complaint Hub will take all necessary steps to ensure that informed consent is obtained from you, and you are aware of the risks entailed with such transfer. In any instance, Swift Complaint Hub will ensure Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred abroad, and details of the basis of such transfers shall be provided to you upon request.

Grounds for Processing of Personal Information

• The Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;


• The processing is necessary for the performance of a contract to which the Data Subject is a party or in order to take steps at the request of the Data Subject prior to entering into a contract;


• Processing is necessary for compliance with a legal obligation to which Swift Complaint Hub is subject;


• Processing is necessary to protect the vital interests of the Data Subject or of another natural person;


• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in Swift Complaint Hub

Choices and Rights

• Right to request for and access any Personal Information collected and stored by Swift Complaint Hub;


• Right to be informed regarding their Personal Information;


• Right to object to automated decision-making and processing;


• Right to request rectification and modification of Personal Information which Swift Complaint Hub keeps;


• Right to request the removal of their data;


• Right to request the movement of data from Swift Complaint Hub to a third party - this is the right to the portability of data;


• Right to revoke consent;


• Right to object to direct marketing, and to request that Swift Complaint Hub restricts the processing of their information;


• Right to submit a complaint to the relevant authorities, including the Public Complaints Commission (PCC) https://pcc.org.ng/

Policy Violations

Any violation of this Privacy Policy should be brought to the attention of the Data Protection Officer (details below) for appropriate sanctioning and treatment.

You certify that the information provided to register as a client is correct to the best of your knowledge. Furthermore, when providing the personal data of any other person, you confirm that you are only providing accurate and up-to-date data in accordance with their instructions, and are able to provide evidence of their consent to the data processing described in this Policy as and when required by Swift Complaint Hub. Please note that any attempt to mislead may result in prosecution and the deliberate provision of inaccurate data results in a privacy violation.

Changes to This Privacy Policy

We may need to update, modify or amend our Privacy Policy as our technology evolves and as required by law. If we materially change the ways in which we use or share personal data previously collected from you through our Services, we will provide notice or obtain consent regarding such changes as may be required by law. The Privacy Policy will apply from the effective date provided on our website.

Contact Swift Complaint Hub’s Data Protection Officer (DPO)

If you have any questions relating to this Privacy Policy, complaints or would like to find out more about exercising your data privacy rights, please reach out to our DPO via email at admin@swifthub.ng .