INTRODUCTION
First Hydrocarbon Company Nigeria Limited (“FHN”) has created this Privacy Policy to explain how FHN collects, uses, retains, discloses, and protects your Personal Data, including any other information.
You accept this Privacy Policy and hereby give FHN consent to save, process and use your Personal Data to the extent as allowed by law when you provide us with details of your Personal Data or by clicking on the “accept” button. You have the right to withdraw your consent at any time, provided that we do not have another legal basis to keep processing your Personal Data.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or by sending you an email notification).
We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
COLLECTION OF INFORMATION
We may collect and process the following information about you:
- Information that you provide to us, for example when you fill out a contact or web form, or if you register to receive alerts or updates.
- When you provide your Personal Data while signing up for a service or purchasing a product.
- Personal Data that we obtain or learn, such as information about the browser or device you use to access this site, how you use this site and the pages you visit, traffic and location data. This being because servers located within FHN are hosted by third parties outside Nigeria, and they automatically log data about your visit to FHN’s site based on your IP address. This information does not identify you as an individual but identifies the computer or other device you use to access the website. This information we collect is used to see where the site is being used in the world to ensure coverage, and for click stream analysis to help better understand site usage. FHN does not link information automatically logged by such means with Personal Information about specific individuals.
- When you contact our customer support whether by phone, email, or chat.
- We may also ask you for information if you experience problems when using this site. We may also ask you to complete surveys for research purposes, although you don’t have to respond to these.
- Personal Data we receive from other sources: We will notify you when we receive Personal Data about you from them and the purposes for which we intend to use that Personal Data.
Use of personal information
If you choose to provide us with Personal Information it will be used to provide the information, products, or services you request or which we think may be of interest to you, to communicate with you for the same purpose or for any other purposes stated at the time at which the data is collected and subject to any preferences indicated by you at the time.
DISCLOSURE OF INFORMATION
FHN only discloses Personal Data with other companies or individuals in the following limited circumstances:
- We may provide such Personal Data to affiliated companies or other trusted businesses or persons for the purpose of processing Personal Data on our behalf. We require that these parties agree to process such Personal Data based on our instructions and in compliance with the Nigerian Data Protection Laws and any other appropriate confidentiality and security measures. When they no longer need your Personal Data to fulfil this service, they will dispose of the details in line with the Nigerian Data Protection Laws.
- With other third-parties such as email service providers that perform marketing services on behalf of FHN.
- With other non-affiliated companies for our everyday business purposes, such as processing transactions, maintaining accounts, responding to court orders and legal investigations.
- In response to a request for Personal Data, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation, or legal process.
- With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate.
- In connection with, or during negotiations of, any merger, sale of FHN’s assets, financing or acquisition of all or a portion of our business to another company; and
- With your consent or at your direction, including if we notify you that the Personal Data you provide will be shared in a particular manner and you provide such Personal Data.
- We may also share aggregated or de-identified or anonymized Information, which cannot reasonably be used to identify you.
When FHN does not have a lawful basis for disclosure of your Personal Data, FHN will obtain consent from you before sharing your Personal Data with third parties. Where FHN need to transfer your Personal Data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your Personal Data to a country without an adequate data protection law.
SECURITY
FHN takes reasonable measures to help protect all Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Additionally, FHN implements policies designed to protect the confidentiality and security of your Personal Data, including a Data Protection Policy. [We have also taken measures to comply with provision of security facilities for the protection of your Personal Data through the set-up of firewalls, limited access to specified authorized individuals, encryption, and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents].
Data retention
Data will be held for the lifetime your subscription is active for the purposes of contacting you effectively after which time it is depersonalized and non-identifiable.
WHERE WE STORE YOUR PERSONAL DATA
The personal data FHN collects from you may be transferred to and stored at a destination outside Nigeria. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely with an appropriate level of protection and that the transfer is lawful.
YOUR RIGHTS AS A DATA SUBJECT
The law gives you certain rights in respect to the Personal Data that FHN holds about you. Below is a highlight of some of those rights. At any point while we are in possession of or processing your Personal Data, you, the Data Subject has the following rights:
- RIGHT OF ACCESS – You have the right to request a copy of the information that we hold about you. We will respond to your access request within one month of receiving your request. Where we are not able to provide this personal data to you within the one-month timeline provided by the Nigerian Data Protection Laws, we will communicate same to you, and may request an additional time within which we will provide the information to you. Your Personal Data shall be provided to you in a structured, commonly used, and machine-readable format.
- RIGHT TO RECTIFY – You have the right to correct the Personal Data we hold about you that is inaccurate.
- RIGHT TO BE FORGOTTEN – In certain circumstances you may ask for the data we hold about you to be erased from our record.
- RIGHT TO RESTRICT PROCESSING – Where certain conditions apply, you have a right to restrict processing of your Personal Data.
- RIGHT TO PORTABILITY – You have the right to have your Personal Data transferred to another organization.
- LODGE COMPLAINT – You have a right to lodge a complaint about the handling of your Personal Data with the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng/
- RIGHT TO OBJECT – You have the right to object to the Processing of Personal Data.
NDPC’s website ( https://ndpc.gov.ng/) has a wealth of useful information in respect of your rights over your Personal Data. If you wish to exercise your rights, you may contact our Data Protection Officer at Nosike.Ezebo@fhnigeria.com and Israel.Ukot@fhnigeria.com.
Site traffic information and cookies
Servers located within FHN and hosted by third parties outside Nigeria automatically log data about your visit to our site based on your IP address. This information does not identify you as an individual but identifies the computer or other device you use to access the website. This information we collect is used to see where the site is being used in the world to ensure coverage, and for click stream analysis to help better understand site usage. We do not link information automatically logged by such means with Personal Information about specific individuals.
During the course of your visit to our website, we may also automatically download short text files called “cookies” to your computer. Cookies enable us to provide you with a better online experience by enabling the site to know that you have visited before and in some cases to record preferences in order to personalise your visit. Cookies also assist us to analyse the profile of our visitors. Cookies do not identify the individual user, but only the computer that is being used to view the site. These can be session cookies which are deleted when you close your browser and/or persistent cookies which remain on your computer for a longer period of time.
You can still use most of this site with cookies turned off. To stop cookies being placed on your terminal equipment refer to your specific internet browser. In a few cases blocking cookies may reduce the functionality of some sites or prevent access to them depending on your chosen browser options.
To delete or stop cookies being placed on your computer refer to your specific internet browser. In a few cases blocking cookies may reduce the functionality of some sites or prevent access to them depending on your chosen browser options.
For further information visit www.aboutcookies.org. This link will take you to another website that is opened in a new window. FHN is not responsible for the content of the www.aboutcookies.org website.
Hyperlinks
This website may provide links to third-party websites for your convenience and information. We do not endorse or make any representations about third-party websites. The FHN Privacy Statement does not cover the personal data you choose to give to unrelated third parties and we encourage you to review the privacy statement on any third-party websites before submitting your personal information on those sites.
BREACH/ PRIVACY VIOLATION
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, FHN shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to the Commission.
Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.
QUESTIONS OR CONCERNS
If you have any questions or concerns about this Privacy Policy or would like to contact us for any reason, you can contact us at Dataprivacy@fhnigeria.com.