Introduction

Welcome to Strata Advisory Limited’s (referred to as “Strata”, “we”, “us” or “our”) privacy policy. Strata is engaged in a diverse range of business activities, primarily focused on providing comprehensive business solutions. We provide various services including business intelligence, data analytics, and general business advisory.

Strata respects your privacy and is committed to protecting your Personal Data. This privacy policy will inform you of how we look after your Personal Data when you visit or use our Website or App (collectively referred to as our “Platform”) (regardless of where you visit or use it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. (Alternatively, you can download a pdf version of the policy [here]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy).

1. Important Information and Who We Are

2. The Data We Collect About You

3. How Is Your Personal Data Collected?

4. How We Use Your Personal Data

5. Disclosures of Your Personal Data

6. International Transfers

7. Data Security

8. Data Retention

9. Your Legal Rights

10. Glossary

Important Information And Who We Are

Purpose Of This Privacy Policy

This privacy policy aims to give you information on how Strata collects and processes your Personal Data through your use of the Platform, including any data you may provide through the Platform when you [sign up and create an account on our Platform OR utilise any of our services OR sign up for our newsletter OR take part in our competitions OR [OTHER EXAMPLE].

Our Platform is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policies or fair processing policies we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Strata is the Controller and responsible for your Personal Data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, or any requests to exercise your legal rights, please contact the DPO with the details set out below.

Full name: [DETAILS]

Email address: [DETAILS]

Postal address: [DETAILS]

Telephone number: [DETAILS]

You have the right to make a complaint at any time to the NDPC. We would, however, appreciate the chance to deal with your concerns before you approach the NDPC so please contact us in the first instance.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. This version was created on 03 December 2024.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-Party Links

Our Platform 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 data about you. We do not control these third-party websites and platforms and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every other platform you visit.

The Data We Collect About You

Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

2. Contact Data includes billing address, delivery address, email address and telephone numbers.

3. Financial Data includes bank account and payment card details.

4. Transaction Data includes details about payments to and from you and other details of services you have acquired from us.

5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform.

6. Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.

7. Usage Data includes information about how you use our Platform and Services.

8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature on our Platform. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

We do not collect any Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If You Fail To Provide Personal Data

Where we need to collect Personal Data pursuant to Applicable Laws, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

1. create an account on our Platform;

2. subscribe to our service or publications;

3. request marketing to be sent to you;

4. enter a competition, promotion or survey; or

5. give us feedback or contact us.

2. Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.

3. Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:

1. analytics providers such as Google;

2. advertising networks; and

3. search information providers.

4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

5. Identity and Contact Data from data brokers or aggregators.

6. Identity and Contact Data from publicly available sources.

How We Use Your Personal Data

We only use Your Personal Data for a specific purpose; and before We do, We must have a legal reason. For example, when it is necessary for us to perform a contract with You, for Our legitimate interest, where You have given us Your consent, or to fulfil Our legal obligations. These are all known as the “legal or lawful basis for processing”.

The legal or lawful basis We rely on for processing Your Personal Data are as follows:

1. Your consent: Where You agree to us collecting Your Personal Data by using Our Services. With Your consent, We may send marketing and promotional communications by email, SMS and push notifications (depending on Your choice of contact). We may send targeted marketing about Our services on third-party online services such as Google, Instagram and Facebook if We believe that You are likely to be interested in using Our services based on Your profile. Your consent to receive targeted adverts would have been obtained by these third parties on Our behalf;

2. We have a contractual obligation: Where it is required to perform the contract We are about to enter into or have entered into with You.

3. We have a legal obligation: To ensure We are fully compliant with all Applicable Laws, We must collect and store Your Personal Data.

4. We have a legitimate interest: We may also collect Your Personal Data where We have a legitimate interest to do so which shall be compatible with other lawful basis, provided that Your rights do not override such interests. We want to emphasise that an interest shall not qualify as legitimate if You would not have reasonably expected your Personal Data to be processed in the manner processed.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased Services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into Our Platform and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly. For more information about the cookies we use, please view our cookie policy.

Change Of Purpose

We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Law.

Disclosures Of Your Personal Data

We handover or divulge the Personal Data We collect from You to third-parties such as legal advisors, professional advisors, such as law firms, tax advisors or auditors, insurers, tax and customs, regulatory bodies, stock exchange authorities, providers of identity verification services, credit reference agencies, law enforcement agencies, government agencies, third-party service providers that provide, run and support Our IT infrastructure (such as CRM solutions, identity management, hosting, data analysis, back-up, security and cloud storage services) and for the storage and secure disposal of Our hard copy files.

We may only share Your Personal Data with external third parties in the following limited circumstances:

1. We have Your consent. We require opt-in consent for the sharing of any Personal Data; We share Personal Data with third parties directly authorised by You to receive Personal Data, such as when You authorise a third-party application provider to access Your Personal Data with us. The use of Your Personal Data by an authorised third party is subject to the third party's Privacy Policy and We shall bear no liability for any breach which may arise from such authorisation by You;

2. We provide such information to Our Affiliates or other trusted third-party service providers for the purpose of processing Personal Data on Our behalf. We require that these parties maintain appropriate levels of data protection, security and confidentiality, and to process Your Personal Data based on Our instructions and in compliance with Data Protection Laws as well as any applicable legal requirements for transferring Personal Data outside the jurisdiction in which it was originally collected;

3. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to provide the Service;

4. To comply with Applicable Laws; Strata has a legal obligation to report suspicious transactions and other activity to relevant regulatory authorities under relevant anti-money laundering, terrorist financing and proliferation financing regulations;

5. To enforce applicable terms of service, including investigation of potential violations thereof; and

6. To detect, prevent, or otherwise address fraud, security or technical issues; Strata reports suspected criminal activity to the police and other law enforcement bodies. We are not always permitted by Applicable Laws to inform You about this in advance of the disclosure, or at all.

7. If Strata becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, We will provide notice before Personal Data is transferred and becomes subject to a different privacy policy.

International Transfers

Whenever we transfer your Personal Data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by NDPC.

2. We will only transfer your Personal Data in compliance with Data Protection Laws

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of Nigeria.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and the NDPC of a breach where we are legally required to do so.

Data Retention

How Long Will You Use My Personal Data For?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

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.

Your Legal Rights

Under certain circumstances, you have rights under Data Protection Laws in relation to your Personal Data. These include:

1. Right to access the information that We have on You. We will make sure to provide You with a copy of the Personal Data We process about You. In order to comply with Your request, We may ask You to give us some additional information that We will use to verify Your identity. If You fail to provide such information or if the information that You have already given to us is not enough to identify You, We may refuse to provide You with the information upon contacting us;

2. Right to have a copy of Your Personal Data in an electronic format provided such data would not impose unreasonable costs on us;

3. Right to have Your Personal Data corrected or deleted where correction is not feasible or suitable, for example, if it is incomplete, out of date or inaccurate;

4. Right to opt out or unsubscribe from receiving marketing campaign communications at any time. If You register on the Platform, Your Personal Data will be stored in Our CRM system. If You have unsubscribed or opted out, your contact details will remain on Our opt-out list to ensure we do not inadvertently contact You in the future and Your Personal Data will be erased completely;

5. Right to be provided with relevant information if We need to further process Your Personal Data other than the reasons for its collection;

6. Right to have your Personal Data erased without undue delay;

7. Right to disapprove the processing of Personal Data or request obliteration of Personal Data (in certain circumstances and subject to Data Protection Laws). These circumstances occur in the event where the Personal Data is no longer necessary for the purpose it was collected or processed, or You withdraw your consent, or if you object to the processing and there are no overriding legitimate grounds if the Personal Data was unlawfully processed, and if erasure is required to comply with Applicable Laws;

8. Right to obtain without constraint or unreasonable delay, Our confirmation that We are storing or processing Your Personal Data and the purpose of the processing, the categories of Personal Data concerned, the recipient(s) to whom the Personal Data has been or will be disclosed and the retention period;

9. Right to right to withdraw Your consent where You have provided Personal Data voluntarily, or otherwise consented to its use. Such withdrawal does not affect the lawfulness of processing of Your Personal Data up to that time; and

10. Right to complain to the NDPC or refer the matter to a court of competent jurisdiction where the need arises.

11. If you wish to exercise any of the rights set out above, please contact us via our DPO.

No Fee Usually Required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond

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.

Glossary

1. Affiliate means in relation to an entity, a subsidiary or a holding company of that entity, or any subsidiary of the holding company and all of its subsidiaries;

2. Aggregated Data means data and information related to your use of our Services that is used by us in an aggregate and anonymised manner, including to compile statistical and performance information related to the provision of the Services and the operation of the Platforms;

3. Applicable Laws means all applicable laws in force and effect as of the date hereof and which may be enacted or brought into force and effect hereinafter, including statutes, rules, regulations, directions, bye-laws, notifications, ordinances and judgments having force of law, or any final interpretation by a court of law having jurisdiction over the matter in question as may be in force and effect during the subsistence of this Privacy Policy;

4. Cookies means a small data file that is transferred to Your computer or mobile device to enable us remember Your account log-in information, IP addresses, web traffic, number of times You visit, browser type and version, device details, date and time of visits;

5. Data Controller or Controller means the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in compliance with Data Protection Laws;

6. Data Protection Laws means the Nigerian Data Protection Act 2023, the Nigeria Data Protection Regulation 2019 and all other applicable legislation relating to privacy or data protection;

7. Legitimate Interest pursued by us means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by Applicable Laws). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us;

8. NDPC means the Nigeria Data Protection Commission;

9. Personal Data means any information that can be used to identify a living person including Identity Data, Contact Data, Financial Data, Transaction data and/or such other data personally identifiable to You as specified in this Privacy Policy;

10. Platform means this website, application and other computer equipment, network, software and API that are proprietary or licensed to Strata or its Affiliates from time to time and utilised by Strata to provide the Services;

11. Services means the services, content, features, or functions provided by Strata; and

12. User or You or Your means anybody who uses or accesses Our Platform or Services.