1. Who We Are
Pade HCM Technology Limited (“PaidHR” or “Us” or “We” or “Our”)is a retail technology company based in Lagos, Nigeria, with Our registered address at 13 Ore Close, Surulere, Lagos. Our business involves providing human resource and payroll services to businesses (Our “Services”). Our Privacy Policy has been prepared to meet the requirements of the Nigeria Data Protection Act (the “NDPA”). We are committed to protecting the confidentiality and privacy of personally identifiable information (“Personal Data”) entrusted to Us through this website and/or Our mobile application (“Website”). Our Privacy Policy, together with our Terms of Use, explains when and why We collect Personal Data, how We use the Personal Data, conditions under which We may disclose Personal Data to others and the efforts We take to keep Personal Data secure. The terms ‘you’ and ‘your’ means you as an individual accessing this Website, and applying for or utilising Our Services. Where We make decisions on how Personal Data is used in connection with Our Services, We are acting as a Data Controller and will be responsible for the obligations of a Data Controller under the NDPA in connection with the processing of Personal Data. For example, We use this Privacy Policy and other notices to provide you with information about Our use of Personal Data, as required by the NDPA. Where We only use Personal Data requested by other Data Controllers, We would be acting as Data Processors and those other Data Controllers are similarly responsible for the obligations of a Data Controller under the NDPA in connection with the processing of those categories of Personal Data. If you are using Our Services through those other Data Controllers, you should contact them if you have questions or concerns about the processing of your Personal Data or compliance with the NDPA and other applicable laws.
We may update and modify this Privacy Policy from time to time, so please do return to the Website and review this Privacy Policy regularly. Unless otherwise stated, any updates to this Privacy Policy become effective when We post the updates on the Website. Your continued use of the Website for Our Services following an update to the Privacy Policy means that you are aware of the updated Privacy Policy and have no objections to any such updated Privacy Policy. Please read the following carefully to understand Our views and practices regarding the processing of your Personal Data.
2. Personal Data We Collect
We may collect the following information from you as part of the process of providing the Services. The categories of Personal Data We may collect from you includes:
● Basic Personal Data which may include your name, date of birth, and gender;
● Information that you provide by filling in forms on theWebsite;
● Your contact details such as postal address, home address,delivery address, email address, and phone number;
● Bank details - such asaccount name, account number and bankname, and Bank Verification Number (BVN).;
● Means of identification – either your Voter’sCard, driver’s licence, utility bill or tenancy agreement.
● Identifiers assigned to your computer or other devices,including your Internet Protocol (IP) address and other information about your visits to the Website;
● Work details – such as job title,department, company name, company address, personal information of employeeswho may act as your agents, work email address, and office phone number;
● Log in details – such as username andpassword;
● Usage Information and BrowsingHistory - such as usage metrics (including usage rates, occurrences oftechnical errors, diagnostic reports, settings preferences, content, andadvertising interactions);
● We may also collect additionalinformation involving your opinion of Our Services and your preferencesregarding other services such as newsletter subscription;
● Any other Personal Data that youchoose to provide on the Website or in your communications with Us. Pleasenote, call recordings of conversations may be retained for monitoring andtraining purpose.
Information that we may obtain from third parties
In some circumstances, We may collect Personal Data about youfrom Our partners or from publicly available websites to help Us betterunderstand Our audience and enhance the relevance of Our content. We maycollect Personal Data about you from third parties, such as:
● Some organisations and others withwhom you have a relationship that provide or publish Personal Data related toyou, such as from Our customers when they arrange access to Our Services foryou or from others when they create, post, or submit user content on OurServices that may include your Personal Data.
● Professional or industryorganisations and certification / licensure agencies that provide or publishPersonal Data related to you.
● Third parties and affiliates whoresell or integrate with Our Services.
● Service providers and businesspartners who work with Us in relation to Our Services and that We may utiliseto deliver certain content, products, or services or to enhance yourexperience.
● Marketing, sales generation, andrecruiting business partners.
● Government agencies and others whorelease or publish public records.
● Other publicly or generally availablesources, such as social media sites, public and online websites, opendatabases, the corporate affairs commission, and data in the public domain.
● We may obtain information aboutcomplaints from a regulator, if you make a complaint.
Information that may be generatedduring the course of your relationship with us, for example:
● We may collect information about yourinteractions with the Website using cookies and similar technologies. Cookiesare small files placed on your computer’s hard drive that enable the Website toidentify your computer as you view different pages. Cookies allow websites andapplications to store your preferences in order to present contents, options orfunctions that are specific to you. Like most interactive websites, Our Websitemay use cookies to enable the tracking of your activity for the duration of asession. We may also use cookies (and similar technologies) and analytics toolsto collect information about you. This information can be used to improve theperformance of the site, make advertising more relevant and enhance your userexperience, such as Your location – We use cookies to display information thatis most relevant to your location. Your usage – We use cookies to understandhow Our customers use Our Website and interact with Our communications. Forexample, We use technology on Our Website, which record user movements,including page scrolling, clicks and text entered. (It does not record paymentdetails.) This helps Us identify usability issues and improve the assistance Wecan provide to users and is also used for aggregated and statistical reportingpurposes. Your device – We use cookies to understand what type of device youare using to show you the best version of the site. For instance, if you visitOur Website on a mobile device, Our technology will ensure that you see aversion that is optimised for mobile viewing and interaction. Your engagementwith advertisements – We use cookies to understand what advertisements you havebeen shown, or clicked on, to bill Our advertising partners, and to present youwith advertisements that are more relevant to you.
3. How We Use Personal Data
Wemay store and use your Personal Data for the following purposes:
a. Search for and subscribe to OurServices.
b. Use Our Services or otherwiseinteract with Us.
c. Create or maintain a profile oraccount with Us.
d. Purchase, use, or otherwiseinteract with content, products, or services from third-party providers whohave a relationship with Us.
e. Create, post, or submit usercontent on Our Services.
f. Register for or attend one of Ourevents or locations.
g. Improve features and websitecontent, and analyse data to develop products and services.
h. Request or sign up forinformation.
i. Communicate with Us by phone,email, chat, in person, or otherwise.
j. Complete a questionnaire, survey,support ticket, or other information request form.
k. When you express an interest inworking with Us or apply for a job or position with Us.
l. Address any inappropriate use ofOur Website. (as is necessary for compliance with Our legal obligations and/oras is necessary for Our legitimate interests).
m. Prevent, detect and manage risk against fraud andillegal activities using internal and third-party screening tools. (as isnecessary for compliance with Our legal obligations and/or as is necessary forOur legitimate interests).
n. Verify your identity. (as is necessary forcompliance with Our legal obligations and/or as is necessary for Our legitimateinterests).
o. Carrying out anti-fraud andanti-money laundering checks and verifying your identity (as is necessary forcompliance with Our legal obligations and/or as is necessary for Our legitimateinterests).
p. Assessing financial risks,including by carrying out credit reference checks (as is necessary for theperformance of a contract between you and Us and/or as is necessary for Ourlegitimate interests).
q. Undertaking statisticalanalysis, including analysing your use of Our Website. This allows Us todevelop new, or improve existing products and services (as is necessary for Ourlegitimate interests); and
r. fulfilling Our obligationsowed to a relevant regulator, tax authority or revenue service (as is necessaryfor compliance with Our legal obligations and/or as is necessary for Ourlegitimate interests).
Our “legitimateinterests” as referred to above, include Our legitimate business purposes andcommercial interests in operating Our business in a customer-focused,efficient, and sustainable manner, in accordance with all applicable legal andregulatory requirements. Your Personal Data is not used for the purposes of solelyautomated decision making or profiling.
4. How We Share Personal Data
Wemay share your Personal Data with Our associated companies and with certainthird parties including:
● Third parties that assist Us inpreparing or sending any communications to you, or to assist Us in connectionwith any of Our administrative or business functions, or in the provision ofany of Our services to you, or to third parties acting as Our agents.
● If We are unable to make contact withyou, We may employ third party companies to trace your whereabouts andre-engage with Us. We may also employ third parties to enforce Our rights underany agreement with you.
● If We or Our assets are potentiallyto be acquired by a third party, or if We consider restructuring, Personal Dataheld by Us about Our customers (including borrowers and investors) will be oneof the transferred assets and may be shared during the potential transaction orrestructuring process or as part of a mergers & acquisition transaction.
● Anyone to whom We transfer or maytransfer Our rights and duties under any agreement with you.
● Legal and regulatory bodies,including fraud prevention agencies or when We have a legal obligation to doso.
● Our auditors, solicitors,professional advisors, sub-contractors who have agreed to treat your PersonalData as confidential.
5. How We Protect yourPersonal Data
We employ all reasonable efforts to keep your Personal Datasecure by taking appropriate technical and organisational measures against anyunauthorised or unlawful processing of Personal Data and against its accidentalloss, destruction or damage. We are committed to managing your Personal Data inline with the NDPA and best practices. We protect your Personal Data usingphysical, technical, and organisational measures to reduce the risks of loss,misuse, unauthorised access, disclosure and alteration. We also useindustry-recommended security protocols to safeguard your Personal Data. Othersecurity safeguards include, but are not limited to, data encryption,firewalls, and physical access controls to Our buildings and files.
6. Grounds for Processingyour Personal Data
We may process your Personal Data for anyone of the lawfulbasis specified below in accordance with the NDPA. If you are unsure as to thelawful basis for processing any category of your Personal Data which Weprocess, please reach out to Us via hello@paidhr.com.
o theData Subject has given consent to the processing of his/her Personal Data forone or more specific purposes;
o theprocessing is necessary for the performance of a contract to which the DataSubject is party or to take steps at the request of the Data Subject prior toentering into a contract;
o processingis necessary for compliance with a legal obligation to which We are subject;
o processingis necessary for legitimate interests pursued by Us or by a third party, exceptwhere such interests are overridden by the interests or fundamental rights andfreedoms of the data subject, which require the protection of Personal Data;and
o processingis necessary for the performance of a task carried out in the public interestor in exercise of an official public mandate vested in Us.
7. Transfers of Personal Dataoutside Nigeria
The Personal Data that We collect from you may be transferredto, and stored at, a destination outside Nigeria. Where your Personal Data istransferred outside Nigeria, We will take all steps reasonably necessary toensure that your Personal Data is transferred to a country on the AdequacyWhitelist published by the NDPC and, generally, in accordance with theprovisions of the NDPA. We will take reasonable steps to use contractual termswhich ensure that any such category of Personal Data is adequately protected orthat the country to which the data is being transferred has reasonably adequatedata protection laws in place.
8.Data Retention
We retain the Personal Data processed by Us for as long as isconsidered necessary for the purpose for which it was collected (including asrequired by applicable law or regulation). In accordance with Our retentionpolicy, We may retain your Personal Data for a minimum of 6 (six) years fromthe end of Our business relationship with you. That is, when your account isclosed..
9. Security of Information
We are aware of the importance of protecting the Personal Data We collect from you andtherefore We store data in encrypted form on computers and control access viasecure web pages. We employ firewalls and other security technologies toprotect Our servers from external attacks. We train Our employees in the properhandling of Personal Data and when We use other companies to provide servicesfor Us, We require them to protect the confidentiality of Personal Data theyreceive. Unfortunately, the transmission of information via the internet is notcompletely secure. Although We will do Our best to protect your Personal Data,We cannot guarantee the security of your data transmitted to Our Website; anytransmission is at your own risk. Once We have received your Personal Data, Wewill use strict procedures and security features to try to prevent unauthorisedaccess.
10.Your rights under the NDPA
Your Personal Data is protected under the NDPA and you have anumber of data protection rights (explained below) which you can seek toexercise. Please contact Us via: hello@paidhr.com, if you wish to do so, or if youhave any queries in relation to your rights. If you seek to exercise yourrights, We will explain to you whether or not the right applies to you; theserights do not apply in all circumstances. Please be aware that if your requestis manifestly unfounded or excessive, We may refuse to deal with your requestin accordance with the provisions of the NDPA. We may also charge a reasonablefee for dealing with any such requests as requested by the NDPA.
(a) Right to access of Personal Data
You have the right to access the Personal Data We hold aboutyou and to obtain certain prescribed information about how We process it, aswell as the source of the Personal Data We hold about you. This is morecommonly known as submitting a ‘Data Subject Access Request’. We may requestproof of your identity before sharing such information.
(b) Right to rectify or erase yourPersonal Data
If you discover that the Personal Data We hold about you isinaccurate or incomplete, you have the right to have this information rectified(i.e. corrected). You may ask Us to delete information We hold about you incertain circumstances. This right is not absolute and only applies inparticular circumstances. It may therefore not be possible for Us to delete the Personal Data We hold about you,for example, if We have an ongoing relationship or are required to retaininformation to comply with Our legal obligations or to exercise or defend legalclaims.
(c) Right to Withdraw Consent
WhereWe have relied on consent as the lawful basis to process your Personal Data,You may withdraw your consent by notifying Us immediately.
(d) Right to object to processing
You may not object to the processing of your Personal Datawhen it is based on Our legitimate interests. You may also object to theprocessing of your Personal Data for the purposes of direct marketing andprofiling, to the extent that such profiling is related to direct marketing.
(e) Right to restriction ofprocessing
In some cases, you may have the right to have the processingof your Personal Data restricted. For example, where you contest the accuracyof your Personal Data, it may be restricted until the accuracy is verified, orwhere the processing is unlawful but you object to it being deleted and requestthat it be restricted instead.
(f) Right to data portability
You have the right to receive, move, copy, or transfer yourPersonal Data to a controller which is also known as ‘data portability’.
(g) Right to Complain
Right to submit a complaint to the Nigeria Data ProtectionCommission (NDPC).
(h) Right to Object
You have the right to object to any automated decision makingmade in connection with your Personal Data. Automated decision making aredecisions based solely on automated processing by automated means, without anyhuman involvement. We may still process your Personal Data by automated means,where such is (a) necessary for entering into or the performance of a contractbetween the data subject and a data controller; (b) authorised by a writtenlaw, which establishes suitable measures to safeguard your fundamental rightsand freedoms; or where this is authorised by you. In that event, We would takereasonable steps to implement suitable measures to safeguard your fundamentalrights, freedoms and interests.
11. Complaints
If you have any complaints about Our use of Personal Data,please send an email with the details of your complaint to hello@paidhr.com or use the contact details above. We will investigate and respond to anycomplaints We receive. You also have the right to lodge a complaint with theNDPC. For further information on yourrights and how to complain to the NDPC, please refer to the NDPC Website.
12. Data Controller andContact Information
The Data Controller is Pade HCM Technology Limited, registered in Nigeria anddoing business at 13 Ore Close, Surulere, Lagos. If you have any questionsabout this Privacy Policy or how and why We process Personal Data, pleasecontact Us at hello@paidhr.com.
ThisPrivacy Policy was last updated on August 26, 2024