Caveat Guard Privacy Policy

Your privacy is important to Caveat Guard and its affiliates which provide administrative and technical support (collectively, "Caveat Guard"). This Privacy Policy covers how Caveat Guard collects, uses, discloses, transfers, and stores information. Please take a moment to familiarize yourself with these privacy practices and email us at support@caveatguard.com if you have any questions. Caveat Guard is considered a data controller under the definition found in the Nigerian Data Protection Act 2023 ("NDPA").

This policy may be amended at any time by posting a revised version at www.caveatguard.com. The revised version will be effective as of the time it is posted.

Our Guiding Principles On Data Processing

In processing your personal data, Caveat Guard adheres strictly to the principles of data processing as set out under S.24 of the NDPA. Our obligation in terms of the principle is to ensure that personal data is:

• Processed in a fair, lawful, and transparent manner.
• Collected for specified, explicit, and legitimate purposes, and not to be further processed in a way incompatible with these purposes.
• Adequate, relevant, and limited to the minimum necessary for the purposes for which the personal data was collected or further processed.
• Retained for not longer than is necessary to achieve the lawful bases for which the personal data was collected or further processed.
• Accurate, complete, not misleading, and, where necessary, kept up to date having regard to the purposes for which the personal data is collected or is further processed.
• Processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing, access, loss, destruction, damage, or any form of data breach.

Furthermore, we are committed to ensuring accountability, demonstrating duty of care to you and also upholding data Confidentiality, Integrity and availability.

Consent

Except as otherwise required by operation of law or principles of law, your consent as the data subject is paramount in our considerations. You have the right to give, withhold or otherwise withdraw your consent to data processing. For further understanding of the operation of the principle of consent under data processing, see S.26 of the NDPA 2023.

Rights Of Data Subjects

At Caveat Guard, we hold your privacy rights very dear to our operations. Apart from the right to give, withhold or withdraw consent, you have rights to all relevant information that may guide you in making informed decisions about your personal data. For example, you have the right to be notified of anyone or any place to which we may transfer your personal data. Your rights under S.34 and S.35 NDP Act include but are not limited to the following:

• Right to be Informed: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request us to correct any inaccurate or incomplete personal data we hold about you.
• Right to Object to Processing: You can object to how we use your personal data in certain situations. You can also request that we limit the way we use your personal data.
• Right to Data Portability: You can request a copy of your personal data in a format that allows you to easily move it to another service provider.
• Right to be Forgotten: You have the right to request that your data with us be forgotten.
• Right in Relation to Automated Decision Making: This essentially entitles you to human intervention.
• Right to Withdraw Consent: You have a right to withdraw at any time, consent to the processing of your personal data.

Note that you also have a right to lodge a complaint with the Nigerian Data Protection Commission.

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person.

You may be asked to provide your personal information anytime you are in contact with Caveat Guard. Sometimes the information collected may be either a statutory or contractual obligation. Caveat Guard may share this personal information with its affiliates and technical support teams and use it in any manner that is consistent with this Privacy Policy. Caveat Guard may also combine it with other information to provide and improve its services and content. You are not mandated to provide the personal information that Caveat Guard has requested, but if you choose not to do so, in many cases Caveat Guard will not be able to provide you with its services or respond to any queries you may have.

Please note that if your information is required for Caveat Guard to provide a service and you wish to restrict or delete that data, it may impact the ability of Caveat Guard to provide such service(s).

Personal Information Caveat Guard Collects

When you apply for any service, Caveat Guard may collect a variety of information including, but not limited to:

• Name
• Mailing address
• Phone number
• Email address
• Contact preferences
• Other banking information

Sometimes, in order to process your request, Caveat Guard may have to collect government-issued identification ("ID"), photo, or other form of documentation to prove your identity and/or residence. This may include an ID number, or other similar unique identifier, as well as information about your:

• Age or date of birth
• Marital status
• Ethnic origin
• Education
• Health
• Disciplinary history

Examples of services where personal information may be collected include:

• Filing of caveats against arrest of vessels
• Processing of caveat registration
• Registration of caveats with necessary authorities
• Conduct of search at the caveat registry
• Conduct of search at the land registry
• Billing
• Other activities related to the above

If the Payment Website services are used, the following types of information may also be collected by Caveat Guard or a contracted third party:

• Contact information: Username, address, phone, email, and/or other similar information
• Financial information: Credit card numbers provided through the Payment Website

How Caveat Guard Uses Your Personal Information

Caveat Guard may use your personal information to provide your requested service and comply with local and international laws, trade regulations, and other similar obligations while providing its services to you. Additionally, Caveat Guard may use personal information for:

• Helping create, develop, operate, deliver, and improve services
• Loss prevention and anti-fraud purposes
• Internal and administrative purposes, such as auditing, data analysis, and research
• Sending important notices, such as communications about current services and changes to terms, conditions, and policies

How Personal Information May Be Used If You Use the Payment Website

The primary purpose of collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. Personal information may be used to:

• Provide the requested services and customer support
• Process transactions and send notices about user transactions
• Resolve disputes, collect fees, and troubleshoot problems
• Prevent prohibited or illegal activities
• Customize, measure, and improve Caveat Guard services and the content and layout of the Payment Website
• Compare information for accuracy and verify it with third parties when necessary

Disclosure to Third Parties

At times Caveat Guard may make certain personal information available to strategic partners or concerned parties that work with Caveat Guard to provide products and services, or that help Caveat Guard market to customers.

Personal information will only be shared by Caveat Guard to provide or improve products and services. It will not be shared with third parties for their marketing purposes or for any unlawful purpose.

Caveat Guard may share personal information with companies who provide services such as those providing customer service, conducting customer satisfaction surveys, and other similar entities.

Disclosure to Others

It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside of Nigeria for Caveat Guard to disclose your personal information. Caveat Guard may also disclose information about you if Caveat Guard determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

Caveat Guard may also disclose information about you if it determines that disclosure is reasonably necessary to enforce their terms and conditions or protect operations or users. Additionally, in the event of a reorganization, merger, or sale, Caveat Guard may transfer any and all personal information it collects to the relevant third party.

Disclosure to Third Parties if You Use the Payment Website

Personal information may be shared with:

• Service providers who support Caveat Guard services such as fraud prevention, bill collection, and technology services. These service providers may only use user information in connection with Caveat Guard services they perform and not for their own benefit.
• Law enforcement, government officials, or other third parties when:
  • Caveat Guard is compelled to do so by a subpoena, court order, or similar legal procedure.
  • It is necessary to comply with the law or credit card rules.
  • Disclosure is necessary to prevent physical harm or financial loss or to report illegal activity.
  • The user consents or directs Caveat Guard to do so.

Caveat Guard will not sell or rent any personal information to third parties for their marketing purposes and only shares personal information with third parties as described in this policy.

Protection of Personal Information

Caveat Guard uses cutting-edge technologies and foolproof protocols to provide you with comprehensive layers of security in the area of personal data. Hence, we are constantly vigilant in preventing cyber-attacks, fraudulent intrusion, unauthorized access, loss, or corruption of your personal data. We are equally cognizant of the obligations imposed on us by law in terms of data protection. Accordingly, we conduct reviews of process and privacy impact assessments, carry out trainings, and obtain strict warranties where applicable.

However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Caveat Guard cannot guarantee or warrant the security of any information transmitted over the Internet. Caveat Guard makes every attempt to ensure the security of all information collected.

Integrity and Retention of Personal Information

Caveat Guard makes it easy for you to keep your personal information accurate, complete, and up-to-date. It will retain your personal information, which may include all emails or similar correspondence, for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Third Party Sites and Services

Caveat Guard’s website, service portal, and services may contain links to third-party websites, products, and services. The inclusion of any link does not imply Caveat Guard endorsement of any other company, its products, services, or privacy practices. Furthermore, Caveat Guard is not responsible for personal information voluntarily disclosed by users to third parties that are contacted through links on any website.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. Caveat Guard encourages you to learn about the privacy practices of those third parties.

International Users

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy, including to carry out administrative purposes. This includes the transfer to and accessibility by all of Caveat Guard’s locations and any required third party, and to their respective Information Technology ("IT") servers.

Caveat Guard has a number of affiliated legal entities in different jurisdictions which are responsible for the personal information they collect and which is processed on their behalf. Caveat Guard employs appropriate technological and physical safeguards to keep information secure. However, please be aware that these safeguards may not meet the same standards as those required by the country in which you reside.

Commitment to Your Privacy

To make sure your personal information is secure, Caveat Guard communicates its privacy and security guidelines to its employees and strictly enforces privacy safeguards.

Privacy Questions

If you have any questions or concerns about this Privacy Policy or data processing, or if you would like to make a complaint about a possible breach of local privacy laws, please contact support@caveatguard.com.

When a privacy question or deletion request is received, Caveat Guard has a dedicated team which seeks to address the specific concern or query which you are raising. If you are unsatisfied with the response received, you may refer your complaint to the relevant regulator in Nigeria. Upon request, Caveat Guard will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

This Privacy Policy may be updated from time to time. When the policy changes in a material way, a notice will be posted on the company’s websites along with the updated Privacy Policy.