1. Who is responsible for your data
SmartSMB Advisory Ltd. is the data controller responsible for the personal data described in this Policy.
Data protection contact: Abdulrafiu Ibrahim / Website Developer
Email: abdulrafiu.dev@gmail.com
Address: Abuja, FCT, Nigeria
2. What personal data do we collect
Depending on how you interact with us, we may collect:
- Contact and identity data - your name, business name, role, email address, phone number, and similar details you give us when you contact us, request information, or become a client.
- Engagement data - information you share with us in the course of an advisory engagement, which may include business and financial information about your enterprise.
- Communications - the content of messages you send us by email, web form, WhatsApp, or phone.
- Technical and usage data - information collected automatically when you visit the Website, such as your IP address, browser type, device information, pages viewed, and the date and time of your visit. This may be collected through cookies or similar technologies.
We collect only the personal data we reasonably need for the purposes set out below.
3. How we use your data and our lawful basis
Under the NDPA, we rely on one or more of the following lawful bases:
| What we use it for | Lawful basis |
|---|---|
| Responding to your enquiries and providing the information you request | Your consent / steps taken at your request before a contract |
| Delivering our advisory services and managing the engagement | Performance of a contract with you |
| Sending administrative communications, invoices, scheduling, and service updates | Performance of a contract / legitimate interest |
| Sending occasional updates or marketing where you have opted in | Your consent, which you may withdraw at any time |
| Keeping records and meeting legal, regulatory, or tax obligations | Compliance with a legal obligation |
| Maintaining the security and proper functioning of the Website | Our legitimate interest in protecting our business |
We do not sell, rent, or trade your personal data.
4. Confidentiality of client information
Information you share with us in a private session or engagement is treated as strictly confidential. We do not disclose a client's personal or business financial information to anyone outside the engagement without that client's consent, except where we are required to do so by law or a competent authority.
6. How long do we keep your data
We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet contractual, legal, accounting, or regulatory requirements. When data is no longer needed, we securely delete or anonymise it.
7. How we protect your data
We apply appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, or alteration. No method of transmission or storage is completely secure, so while we work hard to protect your data, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights, we will notify the NDPC within the timeframe required by law and, where appropriate, inform you.
9. Your rights
Under the NDPA, you have the right to:
- be informed about how your personal data is processed;
- request access to the personal data we hold about you;
- request correction of inaccurate or incomplete data;
- request deletion of your data in certain circumstances;
- object to or request restriction of certain processing;
- withdraw consent at any time, where processing is based on consent; and
- lodge a complaint with the Nigeria Data Protection Commission.
To exercise any of these rights, contact us using the details in Section 1. We will respond within the timeframe required by law. We may need to verify your identity before acting on a request.
10. Children's data
The Website and our services are not directed at children under 18, and we do not knowingly collect personal data from them. If you believe a child has provided us with personal data, please contact us so we can remove it.
11. Third-party links
The Website may link to other websites we do not control. This Privacy Policy does not apply to those sites, and we encourage you to read their privacy notices before sharing any personal data with them.
12. Changes to this Policy
We may update this Privacy Policy from time to time. The current version is always the one published on the Website, with its "Last updated" date shown above. Material changes will be highlighted where appropriate.
13. Contact us and complaints
For any question, request, or complaint about your personal data:
SmartSMB Advisory Ltd.
Email: oluwatosinadegoroye@smartsmbadvisory.com / info@smartsmbadvisory.com
WhatsApp / Call: +2348084086295
Location: Abuja, FCT, Nigeria
If you are not satisfied with our response, you may contact the Nigeria Data Protection Commission (NDPC) - www.ndpc.gov.ng.