Privacy Policy

Last updated April 2024

Table of Content

1. Information & information about ALN NIGERIA | ALUKO & OYEBODE

ALN NIGERIA | ALUKO & OYEBODE is a law firm registered as a partnership under the laws of the Federal Republic of Nigeria. ALN NIGERIA| ALUKO & OYEBODE is committed to safeguarding your privacy by protecting your Personal Data in accordance with the Applicable Data Protection Law. This Privacy Policy sets out how ALN NIGERIA| ALUKO & OYEBODE uses and protects your Personal Data.

References in this policy to “we”, “us”, “Firm” or “A & O” are references to ALN Nigeria | Aluko & Oyebode. References to “you” in this policy refers to any natural person who are our Data Subjects (Partners, Prospective Employees, Employees, Prospective Clients, Clients, Vendors, Visitors or Alumni) who visit our website or any of our physical offices or interact with any of our controlled information collection links or forms or such other information collection or exchange points, now known or to be developed in the future.

Category of Data Subject	Explanation
Employee	Any person who is employed by the Firm to support its operation in the delivery of legal services to its clients including interns, secondees, business support, part-time, and any other temporary or contract staff.
Prospective Employee	Any person who is actively undergoing the Firm’s recruitment process such as job applicants, test takers, and interviewees.
Vendor	Any person who has been engaged by the Firm to provide goods and services to support its operations and meet its business needs. This includes any prospective vendors.
Client	This may include: – any person who has engaged the Firm for the purpose of obtaining any of Our Services; – a prospective employee or an employee of an organisation that has engaged the Firm for the purpose of obtaining any of Our Services; – a prospective vendor or vendor of an organisation that has engaged the Firm for the purpose of obtaining any of Our Services; and a prospective client or client of an organisation that has engaged the Firm for the purpose of obtaining any of Our Services.
Prospective Client	Any person actively seeking to engage the Firm for the purpose of obtaining legal advice, legal representation, or such other services which fall within the scope of Our Services.
Visitor	Any person (including Clients & Vendors) who physically visit the Firm’s buildings (at any of our office locations and website) or attends any event hosted by the Firm.
Partners	Any person admitted to the Firm’s partnership.

This Privacy Policy gives you information about how we collect and use your Personal Data, the other parties with whom we may share it and the measures we take to ensure the security of your Personal Data. It also tells you about your rights and choices with respect to your Personal Data and how you can contact us about our privacy practices.

Please note that we also act on behalf of and under the instructions of Clients or Prospective Clients with whom we owe strict professional and statutory obligation of confidentiality. These Clients may act as Data Controllers or Data Processors or in such other capacity for the purpose of giving us legal instructions. When we act on their behalf, we only collect, use and share Personal Data as authorised by our letter of engagement, the law or as may be required for the purpose of establishing, exercising, or defending legal claims, whether in court proceeding, or in an administrative or out-of-court procedure. When we collect your Personal Data indirectly from other sources, for our own purposes, the provisions of this Privacy Policy and the Applicable Data Protection Law will apply.

This Privacy Policy is applicable to all ALN NIGERIA | ALUKO & OYEBODE Services (Our Services) accessed by you.

2. Our Data Processing Principle

We process your Personal Data in line with the following recognised principles. At ALN NIGERIA| ALUKO & OYEBODE Personal Data is:

processed and collected for specific, explicit, and legitimate purposes, and only further processed in a way that is compatible with such purposes;
processed in a fair, lawful and transparent manner;
adequate, relevant, and limited to the minimum necessary for the purpose for which the Personal Data is collected or further processed;
secured against hazards and breaches, including unauthorised or unlawful processing, access, loss, destruction, damages, cyber-attack, manipulations;
accurate, complete, not misleading and kept up to date having regard to the purpose for which the Personal Data is collected; and
retained for such period for which it is reasonably needed.

3. The Legal Bases for the Use of Your Personal Data

The legal bases we rely on for processing your Personal Data are:

Your Consent

The legal bases set out below form the bases of our processing of your personal data. We may in certain instances rely on your consent to process some of the Personal Data we obtain from you to provide Our Services. Consent is your confirmation or agreement to our data collection and processing request.

Where we require your consent, your consent may be obtained through the use of “check boxes”, “accept button”, “toggle button”, “submit button”, “continue button”, “oral confirmation”, “written confirmation” or such other similar method, including your continuous use of Our Services and/or provision of your Personal Data to us where consent is required, to indicate your agreement/consent to the use of your Personal Data. [See the section on Why and How We May Use Your Personal Data.

Where you have taken any action which may indicate consent by accident or mistake, you have the right to withdraw your consent using our AO Data Subject Tool. [See the section on Your Right as a Data Subject]

Where we need your consent and this is not provided to us, we may be unable to provide you with (a) Our Services; and/or (b) process your Personal Data to provide you with Our Services, except where we have other legal bases [TO4] to do so.

Other Legal Bases:

As a law firm, we may process your information where we have other legal bases to do so. Some of the other legal bases that we may rely on include:

Contract (We have a contractual obligation): To fulfil the terms of the contract to which you are a party, or to take steps, upon your request, prior to entering the contract.
Compliance with Legal Obligation: To comply with the laws and regulations that are applicable to us in Nigeria and globally and ensure that we are fully compliant with the laws applicable to Our Services on how we must process your Personal Data.
Legitimate Interest: For the purposes of our own legitimate interests or for the legitimate interests of others to whom we may lawfully disclose your Personal Data.
Vital interest: To protect your interests where you are incapable of providing your consent.
Public Interest: For the performance of a task carried out in the public interest or in the exercise of official authority.

4. The Types and Categories of Personal Data We Collect about You

We may collect, use, store and transfer different types of Personal Data about you which we have categorised as follows:

Category	Types
Alumni Data	This includes all forms and types of Personal Data about our past Employees retained by the Firm for relationship, storage, and archiving purposes.
Audio/visual Data	This includes all forms and types of data contained in audio and visual recordings captured through cameras or other recording devices including images or videos with identifiable voices, identifiable faces, voice recordings, and geotagging information (such as location, date, and time of image) pertaining to an identified/identifiable person.
Compliance Data	This includes records maintained to demonstrate compliance with applicable laws; records related to consumer preferences, such as your opt-ins and opt-outs of marketing programmes; records relating to data subjects’ rights requests and any other types or forms of Personal Data which we process in relation satisfying and demonstrating the fulfilment of our compliance obligations.
Contact Information	This includes telephone number, email address, physical address, social media handles and any other type or form of information which provide a means by which to contact an identified/identifiable person.
Credential Information	This includes academic certificates, transcripts and records, and any other type or form of professional certification used for the purpose of demonstrating the qualification of an identified/identifiable person in an academic or professional context.
Financial Information	This includes tax identification details, partnership equity contributions, bank account information, income and salary details, loan and debt information, insurance policies and any other type or form of information relating to any financial transactions between an identified/identifiable person and the Firm.
Identity Information	This includes name, date of birth, gender, state of origin, National Identification Number (NIN), IT equipment’s inventory tag numbers, employee ID number, place of birth, nationality information, passport number, driver’s license number and any other type or form of information which is used to uniquely identify an identified/identifiable person.
Identity Documentation	This refers to any type or form of government or Firm issued identification documents and includes passports, National Identification Number (NIN) card or slip, driver’s licence, birth certificate, employee identity cards and any other type of document used to validate an identified/identifiable person’s identity.
Performance Data	This includes performance review assessment, compensation and benefit history, employee training and development, disciplinary records, key performance indicators, performance feedback, evaluation, performance rating and any other type or form of information used to monitor, assess and review the performance of an identified/identifiable employee.
Referential Data	This includes names, address and contact details of next of kin, emergency contact, spouse, children, or other dependants. It may also include the data of identified/identifiable client employees or vendors and any other type or form of Personal Data belonging to an individual which is supplied to the Firm by a Data Subject.
Professional Information	This refers to data relevant to an identified/identifiable person’s professional life or activities such as employment history, department, professional designation, professional skills and expertise, professional achievements and awards, publications, professional memberships, and affiliations.
Recruitment Data	This includes information about an identified/identifiable person’s education, profession, employment, ethnic background, state of health and any other types or forms of Personal Data processed for the purpose of completing the recruitment process see Credential Information.
Sensitive Personal Data	This is all types and forms of data on religion, ethnicity, health (including vaccination details and medical history), race, trade union membership, genetic data, and biometric data of an identified/identifiable person.
Technical Data	This refers to all types and forms of data used in the course of an identified/identifiable person’s interactions with technology and includes data such as IP address, session ID, Cookie and tracking data, user account information, web browsing history, and communication metadata.
Travel Information	This refers to travel preferences, travel history, travel itinerary, accommodation information and any other types or forms of data relating to an identified/identifiable person’s travel.
Vehicle information	This includes vehicle information, Close Circuit Television (CCTV) footage of vehicle and any other types or forms of data which relate to the vehicle but may be used to identify an identifiable/identified person.

5. Source and How is Your Personal Data Collected

We use different methods and sources to collect Personal Data from and about you; and these may include:

You: When you interact with us, such as when you visit any of our office locations, send us an email, or interact with any of our other data collection or exchange medium.
Automated technologies or interactions: As you interact with our platforms or website or engage with our emails and online adverts, such as when we record calls made to/with us and use CCTV cameras in our facilities, we may collect information by automated means using technologies such as Cookies, browser analysis tools, and server logs. We may also collect Technical Data about your equipment, browsing actions and patterns.
Close Circuit Television (CCTV): We use CCTV to help provide a safe and secure environment for our Visitors and Employees; and you may be recorded when you visit any of our office locations.
Recruitment Exercise: If you apply for a job with us, you may need to provide information about your education, employment, ethnic background, and health status or submit to a health check. Your application will constitute your express consent to our use of this information in order to assess your application or suitability for the role applied for or any other role, carry out recruitment analytics and any monitoring activities which may be required of us under any laws applicable to us as an employer. We may also carry out screening checks (including reference, background, identity, eligibility to work, and vocational suitability checks) when considering you for employment. We may disclose your personal information (including diversity and equal opportunities data) to academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics and diversity research providers, referees, and your current and previous employers. We may also collect your Personal Data from these parties in some circumstances. Without your Personal Data we may not be able to progress with your applications for employment with us.
Third Parties sources (including publicly available sources): In certain circumstances, we may need to collect Personal Data such as Professional and Credential Information which may be collected from publicly available sources, your references, and Third Parties that help us conduct internal investigations and other background screenings. Also, your Personal Data may be collected from your employer, trade show and conference organisers, and professional services companies.
Other Sources of collections are further highlighted below in Purpose of Processing: Why and How We May Use Your Personal Data.

6. Purpose of Processing: Why and How We May Use Your Personal Data

We use your Personal Data across our business functions, to help us with specific business purposes as detailed below.

Business function	Specific Purpose of processing	Source of Data	Categories Of Data	Categories of Data Subjects	Legal basis
Administration	Mailroom management	Mailroom log, Email	Identity Information, Contact Information, Professional Information	Clients, prospective Clients, Employees, Vendors, Partners	Legitimate Interest
	Travel Arrangements Booking hotels, Visa processing, Flight reservations, car booking	Email, SMS, Telephone call	Contact Information, Identity Information, Financial Information, Travel Information, Sensitive Personal Data, Identity Documentation, Sensitive Personal Data	Employees, Partners	Contractual Legitimate Interest
	Event management Support (such as processing invitations, etc)	Email, Social Media, SMS, Telephone call	Identity Information, Contact Information, Professional Information, Audio/Visual Data	Employees, Clients, Visitors, Partners	Legitimate Interest Consent
	Front Desk management (Accreditation of guest coming into any Firm’s location)	Visitors’ log	Identity Information, Audio/Visual Data, Vehicle Information, Contact Information	Clients, Prospective Clients, Employees, Visitors, Prospective Employees, Vendors, Partners	Legitimate Interest Contract
	Facility management (This helps us manage the occupational safety and health facility, security risks and other business utility purposes)	Email, SMS, Telephone call, CCTV	Identity Information, Professional Information, Contact Information, Audio/Visual Data	Employees, Visitor, Client, Partners	Legitimate Interest, Contract, Vital Interest
	Provision of Phone services (CUG)	CUG log, Employee Records	Identity Documentation, Identity Information	Employees, Prospective Employees, Partners	Contractual, Legal Obligations, Legitimate Interest
	Catering/food vending services for our employees	Microsoft form	Identity Information	Employees, Partners	Contractual
	Vendor management	Email, SMS, Telephone call	Identity Information, Contact Information, Professional Information	Vendors	Contractual
	Provision of first aid & emergency services	Email, SMS, Employee Records	Identity Information, Professional Information, Contact Information, Sensitive Personal Data, Referential Data	Employees, Partners	Vital Interest Consent
People & Culture	Recruitment and selection	Google Form, LinkedIn Jobs, Emails, SMS, Telephone call, Third-party sources	Identity Information, Credential Documents, Professional Information, Contact Information	Prospective Employees, Employees, Partners	Contractual, Legitimate Interest,
	Compensation and benefit	Microsoft Forms, Email, SMS, Employee Records Telephone Call, Health Management Organisation	Identity Information, Identity Documentation, Contact Information, Performance Data, Alumni Data, Referential Data	Employees, Partners	Contractual Consent
	Performance management	Third Party Sources, Email	Identity Information, Performance Data	Employees, Partners	Legitimate Interest
	Learning and development	Microsoft Teams, Email	Identity Information, Contact Information, Audio/visual Data	Employees, Partners	Legitimate Interest
	Employee records and services	Microsoft Forms, Email, SMS, Telephone Call	Identity Information, Identity Documentation, Credential Information, Financial Information, Referential Data, Sensitive Personal Data	Employees, Partners	Vital interests, contractual, Legitimate Interest, Consent
Finance	Payables (payment purposes for fulling contractual arrangements)	Email, SMS, Telephone call	Identity Information, Financial Information, Contact Information	Vendor, Employees, Partners	Contractual, Legitimate Interest
	Revenue (payment collection from clients and other agreements)	Email, SMS, Telephone call	Identity Information, Contact Information,	Employees, Clients, Partners	Legitimate Interest
	Tax & pension management	Email, SMS, Telephone call	Identity Information, Financial Information, Compliance Data	Employees, Clients, Partners	Legal Obligation
	Statutory reports and audits	Email, SMS	Identity Information, Financial Information, Compliance Data	Employees, Client, Vendor, Partners	Legal Obligation, Legitimate interest
	Business budget process	Email, SMS, Telephone call	Identity Information, Financial Information, Contact Information	Employees, Vendor, Partners	Legitimate Interest
IT	Maintain IT network	Email, SMS, Telephone	Identity Information, Technical Data	Employees, Partners	Legitimate Interest
	Maintain Personal computers	Email, SMS, Telephone Calls	Identity Information, Contact Details	Employees, Partners	Legitimate Interest
	Maintain applications	Emails, SMS, Telephone Call	Identity Information, Technical Data	Employees, Partners	Legitimate Interest
Branding & Marketing	Event management	Photography Vendor, Email, SMS, Telephone call, social media	Identity Information, Contact Information, Contact Information, Professional Information, Audiovisual Data	Employees, Clients, Visitors, Partners	Legitimate Interest, Consent
	Social media engagement (Where such engagement contains your Personal Data)	Social Media, Email, SMS, Telephone call,	Identity Information, Contact Information, Professional Information Audiovisual Data	Employees, Clients, Visitors, Partners	Consent
	Publications (Where such publication contains your Personal Data)	Website, Email, SMS, Telephone Call, social media	Identity Information, Contact Information, Professional Information Audiovisual Data, Technical Data	Employees, Clients, Visitors, Partners	Consent
	Awards	Email, SMS, Telephone call	Identity Information, Contact Information, Professional Information Audiovisual Data	Employees, Clients, Partners	Contractual, Consent, Legitimate Interest
Library services	E-library management	Email	Identity Information, Contact Information	Employees, Partners	Legitimate Interest
Library services	Internal newsletter	Email	Identity Information, Contact Information	Employees, Partners	Legitimate Interest
Professional Legal Services	Legal services engagement (this includes data collected prior to engagement (e.g. KYC and conflict checks)	Email, SMS, Telephone call	Identity Information, Contact Information, Compliance Data	Prospective Clients, Clients, Employees, Partners	Contractual, Legal Obligations
Professional Legal Services	During engagement	Email, SMS, Telephone call	Identity Information, Contact Information, Sensitive Personal Data, Identity Documentation, Credential Documentation, Referential Data	Clients, Employees, Partners	Contractual, Consent, Legal Obligation
General	Storage, archiving and deletion		Identity Information, Contact Information, Sensitive Personal Data, Identity Documentation, Credential Documentation, Referential Data, Compliance Data	Employees, Prospective Employees, Clients, Prospective Clients, Vendors, Visitors, Partners	Legitimate Interest Legal Obligation Consent
NOTE: We will ONLY process Sensitive Personal Data and Children’s Personal Data where you have provided your consent for the use or where there are other recognised legal bases.

Other Business Purposes

In addition to the purposes highlighted above for which Personal Data may be used to offer and provide you with Our Services and to support our business functions, the following are other purposes for which we may process your Personal Data:

to provide the information on Our Service requested by the individual or as reasonably expected given the context in which the Personal Data was collected;
to protect the security and integrity of systems, networks, applications, and data, including detecting, analysing and resolving security threats, and collaborating with cybersecurity centres, and law enforcement about imminent threats;
fraud prevention and other legal or information security risks;
for corporate audit, analysis and reporting;
to communicate with you, we use your Contact Information to send Short Messaging Service (SMS), email, instant messaging (e.g. WhatsApp), or other electronic media to you in respect of any inquiry, complaint or concerns about your Personal Data or other relevant matters;
to provide, administer, and communicate with you about Our Services;
to enforce our terms;
to enforce our contracts and protect against injury, theft, legal liability, fraud or abuse, and to protect people or property, including physical security programmes;
to de-identify, de-personalise, or anonymise the Personal Data or create aggregated datasets, such as for consolidating reporting, research or analytics;
to comply with applicable laws and regulations, or as requested by any judicial process, law enforcement or governmental agencies having or claiming jurisdiction over the Firm and as may be reasonably needed for compliance with the Firm’s policies and procedures, such as privacy programmes, anti-money laundering programmes, security and incident response programmes, intellectual property protection programmes;
to make back-up copies for business continuity and disaster recovery purposes;
for restructuring purposes. For example, if we sell any business or assets, any part of our business or assets are acquired by a third-party, or we enter into an alliance or arrangement with another person, we may disclose your Personal Data relating to those business and assets to the prospective buyer acquiring third-party or any member of our alliance or arrangement; and
for other purposes for which we provide specific notice at the time of collection, and as otherwise authorised or required by law.
Additionally, we may further collect and use/process your Personal Data for such legitimate interest pursued by us which is not incompatible with the purposes we have highlighted above.

7. Automated Decision-Making (Profiling)

We do not make automated decisions about you that may significantly affect you, unless (a) the decision is necessary as part of a contract that we have with you; (b) we have your explicit consent; or (c) we are required by law to use the technology.

8. Marketing

You may receive marketing communications from us if you have (a) provided your consent or (b) we have recognised lawful basis for doing so.

However, you may exercise your right to object to such contact from us or opt out from the marketing communication at any time through any of the means provided in the section on “Exercising your Rights, Complaints and Remedies”.

We do not share your Personal Data with third-parties for their own marketing purposes without your express consent.

9. Cookies Policy

We utilise Cookies to differentiate you from other users, gauge your interaction with our website, and enhance Our Services. Depending on your Cookie management settings and preferences, we may store Cookies on your device when you visit our website. We will exclusively deploy analytics Cookies if you provide consent or accept these Cookies. Certain browsers may automatically accept Cookies, while others can be adjusted to reject Cookies or notify you when a website intends to place a Cookie on your computer. Opting to disable non-essential Cookies could potentially limit your ability to fully experience our website. For additional details about the Cookies we employ and instructions on modifying your Cookie preferences, please refer to our Cookies Policy.

10. Disclosure of your Information: How and to Whom We Share Your Personal Data

We may need to share your Personal data with Third Parties for the purpose of providing Our Services to you and will only share your Personal Data where we have a legal basis to rely on.

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 instructions. When these Third Parties process your Personal Data, they do so based on our instruction; they are acting strictly under contract with us, with strict confidentiality and data security provisions, and in accordance with the Applicable Data Protection Law.

Our Third Parties with whom we share your Personal Data are categorised as follows:

Categories of Third Party	Explanation
Awards Accreditation Organisations	These are organisations to whom we make award submissions to.
Catering Vendors	These are organisations that provide catering facilities to the Firm.
Client’s Affiliates	This includes our client’s professional advisers, employers, or place of business or any other third parties which interact with or provide services to our clients including local and offshore counsel.
Compliance Organisations	This includes regulatory authorities, law enforcement agencies, auditors, and government agencies that we are required to report to as part of our compliance obligations.
Corporate	This includes members of our ALN group and partners who aid the optimal delivery of Our Services to you. It may also include third parties whom we may choose to sell, transfer or merge parts of our business or our assets.
Couriers	These are organisations that provide delivery and dispatch services to the Firm.
Courts & Tribunals	We may be required to engage courts or tribunals and other dispute resolution channels in the course of delivering litigation and other dispute resolution services to you.
Event Management	This includes event planners, photographers, security, third parties with whom we have co-promotional arrangement for the purpose of delivering Firm-organised or sponsored events.
Financial Institutions	This includes our merchant banks, insurers and any other organisations offering financial services to the Firm.
IT Productivity & Payroll Management	This includes website support, IT support, and technology organisations, including cloud service providers, such as data storage platforms and any other technology tools used optimise legal and administrative tasks within the Firm.
Phone Service Providers.	These are organisation responsible for providing closed user group services or such other telephone services to the Firm.
Health and Emergency Services	These are health management organisations, and any other organisations responsible for delivering health-related emergency and non-emergency services to the Firm.
Recruitment Services	This includes recruitment agencies, recruitment test platforms, and your referees involved in the recruitment activities of the Firm.
Security Services	These are organisations responsible for the security of our facilities at all of the Firm’s locations including our CCTV providers.
Travel vendors	These are organisations that support travel arrangement services in the Firm including hotels, airlines, car hire services, and embassies.
Other third parties	These are organisations with whom we may share aggregated data that does not personally identify you such as the number of users of a particular service with some other third parties.

11. International Transfers

In the course of offering Our Services to you, we may need to transfer your Personal Data outside Nigeria. However, we will only do so (a) with your consent; (b) to perform our obligations under a contract with you or take steps at your request before entering into a contract; (c) solely for your benefit where you would have likely given your consent if it were possible for us to obtain it; (d) to establish or in defence of a legal claim against the Firm; or (e) to protect your vital interests.

Whenever we have to transfer or transmit your Personal Data internationally, we will take reasonable steps to ensure your Personal Data is handled securely in compliance with the Applicable Data Protection Law. We will ensure that your Personal Data is sent only to countries with Adequate Level of Data Protection, and where the country may not have Adequate Level of Data Protection, we will ensure that appropriate safeguards are in place to protect your Personal Data.

We may use any data transfer mechanisms which is available to us under the Applicable Data Protection Law, and which is adequate to ensure appropriate safeguards for your Personal Data or other data transfer mechanisms stipulated by the law.

12. Data Security

We take reasonable steps and have put appropriate security measures in place to hold information securely in electronic or physical form and to prevent unauthorised access, modification, disclosure or accidental loss. In addition, we limit access to your Personal Data to employees, agents, contractors and other third parties on a need-to-know basis. They will only process your Personal Data on our instructions and are subject to a duty of confidentiality.

We store information in our access-controlled premises or in electronic databases requiring logins and passwords. Also, we require our third-party data storage providers to comply with appropriate information security industry standards. All employees and third-party providers with access to confidential information are subject to confidentiality obligations.

We maintain administrative, technical, and physical controls designed to protect your Personal Data. We protect against loss or theft, as well as against any unauthorised access, risk of loss, disclosure, copying, misuse, or modification. Some of the security measures we may implement includes secure servers, firewalls, data encryption and granting access only to specific employees in order to fulfil their job responsibilities.

13. Retention Period: How Long Do We Retain Your Data

We will only retain your Personal Data for as long as the information is needed for the purposes set forth in this Privacy Policy or for any additional period that may be required or permitted by law. The length of time your Personal Data is retained depends on the purpose(s) for which it was collected, how it is used, and the requirements to comply with the Applicable Data Protection Law.

You may request that we delete your Personal Data by contacting us via email to AOPrivacyOffice@aluko-oyebode.com or writing to our Privacy Office at the address provided in this Privacy Policy. If we do not have a legal basis for retaining your information, we will delete it as required by the Applicable Data Protection Law and where we retain your Personal Data, we do so in compliance with limitation periods or retention obligations imposed by the Applicable Data Protection Law.

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.

14. Your Rights as a Data Subject

You have a number of rights under the Applicable Data Protection Law in relation to your Personal Data.

You have the right to:

Be informed on how we process your Personal Data: This Privacy Policy details how we process your Personal Data in compliance with the Applicable Data Protection Law.
Request access to your Personal Data (commonly known as a “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. To process your request, we may need to collect specific information from you as a security measure to help us confirm your identity and ensure that your Personal Data is not disclosed to any person who has no right to receive it.

You will not be required to pay any fees for us to process your subject access request. However, we may charge a reasonable fee where processing your request will impose unreasonable cost on us or refuse to comply with your request if you fail to do so. 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 a number of requests. In this case, we will notify you and keep you updated.

[Click here to exercise your access right]

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. However, we may need to verify the accuracy of the new data you provide to us.
Request deletion or removal of Personal Data where there is no good reason for us continuing to process it: You have the right to ask us to delete or remove your Personal Data where (a) we no longer need to process your data for the purpose it was collected; (b) you have withdrawn your consent to the processing of your Personal data and we cannot rely on any other legal basis to process your Personal Data; (c) you have successfully exercised your right to object to processing and we have no overriding interests; (d) we may have processed your information accidentally; or (e) where we are required to erase your Personal Data to comply with local law.

Note however, that the exception to this right is (a) where the Applicable Data Protection Law requires us to retain a historical archive of your Personal Data to fulfil regulatory requirements; or (b) where you object to your data being used for marketing purposes and we have retained a set of your Personal Data to ensure we do not inadvertently contact you in future.

We may not always be able to comply with your request of erasure for specific legal reasons. Where we are unable to do so, you will be notified, if applicable, at the time of your request.

Object to processing of your Personal Data: You may object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests).

In some cases, we may demonstrate that we have compelling legitimate interest or public interest grounds to continue to process your information which override your right to object.

Object at any time to the processing of your Personal Data for direct marketing purposes.
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.
Withdraw consent at any time where we are relying on consent to process your Personal Data: Where your consent is required, we may not be able to provide Our Services to you if you withdraw your consent. Where this is the case, we will advise you accordingly at the time you withdraw your consent. Withdrawing your consent will not affect the lawfulness of any processing carried out before you withdrew your consent.

You may withdraw your consent by engaging with our AO Data Subject Tool through any of the following means:

click here to withdraw your consent; or
scan this QR code.

Lodge a complaint with the Nigeria Data Protection Commission.
Request to restrict the processing of your Personal Data: This enables you to ask us to suspend the processing of your Personal Data in one of the following scenarios:
if you want us to establish the data’s accuracy;
where our use of the Personal Data is accidental, but you do not want us to erase it;
where you need us to hold the Personal Data even if we no longer require it for any legitimate purpose; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

15. Complaints and Remedies

If you wish to exercise any of the rights set out above or have any query or complaint in respect of this Privacy Policy or how we process your Personal Data, please contact our Data Protection Officer in the AO Privacy Office using any of the following methods:

AO Data Subject Tool: Click here

Or Email us:

DPO@aluko-oyebode.com or AOPrivacyOffice@aluko-oyebode.com

Or write us:

ALN Nigeria | Aluko & Oyebode

1 Muritala Mohammed Drive,

Ikoyi,

Lagos, Nigeria

or scan the bar code:

Complaint & Remedies

We take your privacy seriously and so should you have any privacy related issues in respect of our data processing activities, we appreciate the chance to deal with your concerns before you take other legal steps available to you.

[Dispute Resolution Form]

In the event that, you have any complaint concerning how we process your Personal Data or any difficulty in exercising your right through any channels, including the above contact details, we kindly request that you escalate this through any other ALN NIGERIA| ALUKO & OYEBODE dispute resolution channels which we have provided in any of our terms and agreement with you.

Where we are unable to resolve this dispute within the agreed time with you after this escalation, you have the right to make a complaint to the Nigeria Data Protection Commission (NDPC), the national data protection authority in Nigeria.

16. Changes to this Privacy Policy

We keep our Privacy Policy under regular review. From time to time, we may change, amend or review this Privacy Policy to reflect changes in the Applicable Data Protection Law, our data protection practices or Our Services. Changes will be posted in all the medium where we display our Privacy Policy. It is your responsibility to review the amended Privacy Policy. This Privacy Policy governs the use of Personal Data by us, unless otherwise agreed through a written contract. The revised version will be effective immediately after publication.

17. Third-Party Links

You may choose to use certain features for which we partner with other entities or participating merchants or click on links to other websites for your convenience and information. Our 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 Personal 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.

18. Children/Persons with legal disability’s Data

We do not collect any Personal Data knowingly or directly from individuals who fall within this category. We may however collect these data through their legal guardian where required or where the law otherwise permits.

Where you have any belief that we have mistakenly or unknowingly collected information from a child, please contact us to enable us to investigate and restrict such data processing activities.

19. How to Contact the ALN NIGERIA | ALUKO & OYEBODE Privacy Office

If you have any questions about this Privacy Policy or require any other assistance, or want to submit a written complaint to us about how we handle your personal information, please contact us at:

[Click button below to Contact us]

Or Email us: DPO@aluko-oyebode.com or AOPrivacyOffice@aluko-oyebode.com