Lafiya is committed to protecting the privacy of you and your organisation, while providing you with the opportunity to get involved in our global activities by registering with the website (Lafiya Nigeria). This policy (Online Privacy Policy) describes the ways in which we collect information from you when you use the Website, and what we may use it for. We are committed to processing data in accordance with our responsibilities under the EU/UK’s General Data Protection Regulation (GDPR), the Data Protection Act 2018 and other applicable laws. Our co-director (Celine Kamsteeg) shall take responsibility for the ongoing compliance with this policy, which shall be reviewed annually.

Lafiya Nigeria is the controller and is responsible for your personal data (collectively referred to as, "we", "us", "our" or “the company” in this privacy policy).

If you have any questions or need further information about our privacy practices, please contact us at info@lafiyanigeria.org

Article 5 of the GDPR (Articles 35-40 of The Data Protection Act 2018) requires that personal data shall be:

• Processed lawfully, fairly and in a transparent manner in relation to individuals;

• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes; adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

In this privacy notice, we provide information about how we manage our data privacy and security obligations according to the above principles.

Lafiya Nigeria is exempt from registering with the Information Commissioner’s Office (ICO). However, all data we process must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.

Where consent is relied upon as a lawful basis for processing data, we keep evidence of opt-in consent together with your personal data. Where communications are sent to you based on your consent, you will always have the option to revoke your consent. Such options will be clearly available and systems should be in place to ensure such revocation is reflected accurately in our systems.

• Personal information. Your name, mailing address, email address, phone number, other usage data

• Payment information. We may collect your bank account details when setting up a regular direct debit, a credit card or debit card number when processing payments by card, and details about your taxpayer status when claiming Gift Aid.

• Your preferences. We keep a record of what you’ve told us about how you like to be contacted (e.g. by email or direct mail).

• Usage Data. May include but is not limited to information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

• Cookies. A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g. a computer or smartphone) when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions. See more about cookies in our Cookie Policy.

This Online Privacy Policy describes how Lafiya fulfills its obligations under EU/UK GDPR laws .

We will use User Data we collect from you only in accordance with the following guidelines:

(i) To send you information about Lafiya’s programmes and other related activities.

From time to time, we, or third parties acting on our behalf, may wish to send you information about Lafiya which we believe you may be interested in and we may use User Data for this purpose. If you decide now, or at any later time, that you do not wish to receive this information, please e-mail us at info@lafiyanigeria.org

(ii) To provide the Website to you

We will use User Data to provide and improve the Website, to enable us to deal with any queries you have about the Website or Lafiya and to notify you of any changes to the Website.

(iii) To include User Data in anonymous statistics

We may provide anonymous statistics about our users to reputable third parties, but these statistics will not enable any third party to identify individuals or individual organisations.

Lafiya will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

The Internet is a global environment. We may sometimes need to transfer User Data to locations outside the European Economic Area (EEA). By accepting this Online Privacy Policy you hereby consent to such transfers, provided that they are limited to the purposes set out in section D above.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

We do not sell or exploit User Data commercially through third parties

Lafiya will not sell, rent, distribute or otherwise make User Data commercially available to any third party, except as described above, or except with your prior permission.

i) Right of withdrawing your consent.

Where we are processing data based on your consent, you have the right to withdraw this consent at any time.

ii) Right of access.

We maintain a register to ensure that our processing of your data is lawful, fair and transparent. You have the right to access your personal data and you can contact info@lafiyanigeria.org for such purposes. Any such requests made to us shall be dealt with in a timely manner.

iii) Right of objections.

You have the right to object to processing where we are using your personal information based on legitimate interests, for direct marketing or for statistical/research purposes (is this applicable?)

iv) Right of rectification.

You have the right to ask us to correct any inaccuracies in the personal information that we hold about you.

v) Right of erasure.

You have the right to ask us to delete your personal information at any time.

vi) Right of transfer.

You have the right to move, copy or transfer your personal information easily and safely from one IT environment to another, in some circumstances.

If you have any concerns about your privacy rights, please get in touch with us at info@lafiyanigeria.org.

You can also make a complaint to the data protection supervisory authority: The Dutch Data Protection Authority (DAP) or The UK’s Information Commissioner's Office (ICO).

You consent to the disclosure by us of confidential and/or personal data which is provided by you

(i) to any governmental agency, court, regulator or law enforcement authority, on request;

(ii) to our professional advisors and auditors, as reasonably required;

(iii) to affiliates and other third parties providing services to, or acting for and on behalf of, Lafiya, if reasonably required to comply with any law to which either we or they are subject. This may include providing your data to certain third parties for the purpose of carrying out anti-money laundering or similar investigations.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

This Online Privacy Policy may be amended by Lafiya at any time. We will notify you through the Website of these changes.

If you object to the use by Lafiya of your User Data in the manner described in this Online Privacy Policy please contact us at info@lafiyanigeria.org. By using the Website you acknowledge that you have read the terms of this Online Privacy Policy and that you consent to Lafiya’s use of User Data for the purposes set out above.

If you have any questions about our privacy policy, please get in touch at info@lafiyanigeria.org.

Lafiya Nigeria Ltd.

Unit 10,

The Linen House,

253 Kilburn Ln,

London

W10 4BQ

United Kingdom

Stichting Lafiya Nederland,

Bergstoep 20

2959 AA Streefkerk,

the Netherlands

KvK number: 92195458