PRIVACY POLICY

This Privacy Policy discloses the privacy practices for (www.seamlesstravel.ng) This privacy policy applies to personal information collected by the company and to all types of systems, operations and processes within our environment that involve the collection, storage, use, transmission, and disposal of Personal Information (described below). It is provided to help you understand what information we collect about you, how the information collected is used, how we protect it, and your rights to it, among others.

This Privacy Policy is strictly restricted to only our services and therefore does not apply to services that are not owned or controlled by us, including third-party platforms/websites. We are committed to handling all personal data provided to us in compliance with both applicable and model data privacy and protection laws.

It will inform you of the following:

1. What personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared.
2. What choices are available to you regarding the use of your data.
3. The security procedures in place to protect the misuse of your information.
4. How you can correct any inaccuracies in the information.

INFORMATION COLLECTION, USE, AND SHARING

We are the sole owners of the information collected on this site. We only have access to collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone.

We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request.

Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.

PERSONAL INFORMATION

As part of our operations, we collect and process certain types of information (such as names, telephone numbers, addresses etc.) of individuals that makes them easily identifiable. These individuals include current, past, and prospective employees, guarantors, referees, suppliers/vendors, customers or former customers, and other individuals whom we communicate or deal with, jointly and/or severally (“Data Subject(s)”).

You may voluntarily provide us with certain Personal Information, to enable you to gain access to and use our services. This information relates to an identified person or information that can be used to identify you.

1. Individual personal information (e.g., name, previous names, date, and place of birth, etc.);
2. Individual personal contact details (e.g., address, email address, mobile numbers);
3. Identifying information (e.g., photo ID, nationality, utility bill, national ID card and/or number, guarantor’s details, referee details, vendor’s personal data);
4. Information about the ways you interact with the company (e.g., channels used, geographic information, software used and information concerning your complaints);
5. Information captured in customer documentation or data exchange such as application forms or advisory documents or via telephone (e.g., records of advice);
6. Information from third parties providing information to identify and manage fraud;
7. Data from closed circuit television (CCTV) in and around the company’s facilities (these may collect photos or videos of you); and
8. Other information about you that is voluntarily provided by filling in online forms or by communicating with us, whether face-to-face or via other available channels (e.g., by phone, email, or online).

WE USE YOUR PERSONAL INFORMATION TO:

1. provide you with the required services;
2. respond to your questions or requests;
3. improve features, platform and website content and analyse data to develop services;
4. address inappropriate use of our Services;
5. prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools;
6. verify your identity and the information you provide in line with our statutory obligations using internal and third-party-tools;
7. maintain up-to-date records;
8. resolve disputes that may arise, including investigations by law enforcement or regulatory bodies; and
9. any other purpose that we disclose to you in the course of providing our Services to you.

OUR LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION

We will only use and process your personal data as permitted by the Nigerian Data Protection Act, 2023. We have set out below a description of all the legal bases we may rely on to process your personal data:

1.  Where you have given us consent to the processing of your personal data for one or more specific purposes;
2. where processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
3.  where processing is necessary for compliance with a legal obligation to which we are subject;
4. where processing is necessary to protect your vital interests or the vital interests of another natural person,and
5. where processing is necessary for the performance of a task carried out in the public interest or in exercise of an official public mandate vested in us.
6.   For the purpose of the legitimate interests pursued by us as data controller or data processor, or by a third-party to whom the data is disclosed.

  Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us by sending an email to: info@victorytravels-ng.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground may have been used to process your personal data.   For the purpose of this Privacy Policy, consent means any freely given, specific,informed, and unambiguous indication of the Data Subject's wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.

YOUR ACCESS TO AND CONTROL OVER INFORMATION

Once your Personal Information is held by us, you are entitled to reachout to us to exercise the following rights which are guaranteed by the Nigeria Data Protection Act with some limitations.

1.  Request access to your personal data (commonly known as a “data subject access request”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively,we may notify you of our refusal to comply with your request in these circumstances. Where we have reasonable doubts concerning the identity of the natural person making the request for information, we may request the provision of additional information necessary to confirm the identity of the Data Subject. Where data is held electronically in a structured form, such as in a Database, as the Data Subject, you have a right to receive that data in a common electronic format;
2. Right to request correction of the personal data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected, complete or updated,though we may need to verify the accuracy of the new data you provide to us.
3. Right to request erasure or deletion of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Right to object to the processing of your personal data: Where we are relying on a legitimate interest (or those of a third party) there maybe something about your situation which could justify an objection to processing on this ground as you may feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Right to request restriction of processing of your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
   1. If you want us to establish the data’s accuracy;
   2. Where our use of the data is unlawful but you do not want us to erase it;
   3.  Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
   4.  You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6.  Request the transfer of your personal data to you or to a third party: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7.  Right to withdraw consent at any time where we are relying on consent to process your personal data:This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations. You may decline to provide your Personal Information when it is requested by us, however,certain services or all services may be unavailable to you. You may review and update your Personal Information directly or by contacting us.

SECURITY

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "HTTP" at the beginning of the address of the web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

REGISTRATION 

For effective use of this website, users are advised to complete the registration form. During registration a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on our site in which you have expressed interest. At your option, you may also provide demographic information (such as gender or age) about yourself, but it is not required.

COOKIES

We use "cookies" on this site. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, depending on your browser settings you would not have to log in a password more than once, thereby saving time while on our site.Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.

Some of our business partners may use cookies on our site (for example,advertisers). However, we have no access to or control over these cookies.

TRANSFER OF PERSONAL INFORMATION TO FOREIGN COUNTRY

Where Personal Information is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Information. In particular, we shall, among other things, confirm whether the country is on the Nigeria Data Protection Commission ("NDPC”)Whitelist of Countries with adequate data protection laws.

Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act ("NDPA”) 2023. We will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

1. the consent of the Data Subject has been obtained;
2.   the transfer is necessary for the performance of a contract between us and the Data Subject or implementation of per-contractual measures taken at the Data Subject’s request;
3.   the transfer is necessary to conclude a contract between us and a third party in the interest of the Data Subject;
4.   the transfer is necessary for reason of public interest;
5. the transfer is for the establishment, exercise, or defense of legal claims;
6. the transfer is necessary to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.

We will take all necessary steps to ensure that your Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

VISITING OUR WEBSITE FROM OUTSIDE NIGERIA

If you are visiting our website from outside Nigeria, please be aware that your information may be transferred to, stored, and processed in Nigeria from where our central database is operated. The data protection law and other laws of Nigeria may vary in content or may not be as comprehensive as those in your country, but please be assured that we take steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and to those third parties with whom we share it as described in this Policy.

PRIVACY POLICY

This privacy policy applies  to personal information collected through our website and personal information collected offline.

TERMSAND CONDITIONS

Please also visit our Terms and Conditions section establishing the use,disclaimers and limitations of liability governing the use of our website at http://www.seamlesstravel.ng

YOUR CONSENT

By accessing or using our services in any manner, you suggest to us that you have read and adopted this Privacy Policy and consent to the data practices described herein. You agree that upon granting us your consent, you have the legal capacity to give consent and you are aware of your privacy rights and your option to withdraw your consent at any given time.

If you do not accept this Privacy Policy and do not meet or comply with the provisions set forth herein, then you may not use our services.

YOUR CONSENT

By accessing or using our services in any manner, you suggest to us that you have read and adopted this Privacy Policy and consent to the data practices described herein.

You agree that upon granting us your consent, you have the legal capacity to give consent and you are aware of your privacy rights and your option to withdraw your consent at any given time.

If you do not accept this Privacy Policy and do not meet or comply with the provisions set forth herein,then you may not use our services.

AGE RESTRICTION

If you access our services or platform and you are below 18 years, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s).  If you have inadvertently provided personal data of a child to us, please notify us at info@victorytravels-ng.com we will delete such personal data.

Consistent with Section 8 of the Nigeria Child Rights Act (“the Act”),Cap C50, Laws of the Federation of Nigeria 2010, Section 31 of the Nigeria Data Protection Act 2023, we will never knowingly request Personally Identifiable Information from anyone below the age of 18 under the Act without prior verifiable parental consent. If we become aware that a child below the age of18 under the Act has provided us with personal data without verifiable parental consent, we will use our best efforts to remove such information from our files. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

COMPLIANCE

Please note that the collection, processing, security, storage, and erasure of your personal data including any updates to this privacy policy will be in accordance with existing or new privacy and data protection provisions and laws in Nigeria which includes but not limited to the following:

1. Constitution of the Federal Republic of Nigeria 1999 (as Amended);
2. Nigeria Data Protection Act 2023("NDPA”); 
3.  Nigeria Data Protection Regulation2019 ("NDPR”); 
4.  NDPR 2019 Implementation Framework ;
5. Nigeria Cybercrimes (Prohibition,Prevention, Amendement) Act 2024 ;
6. Nigeria Money Laundering (Prevention and Prohibition) Act, 2022;
7. Nigeria Federal Competition and Consumer Protection Act, 2018 (FCCPA);
8.  Nigeria Freedom of Information Act2011;
9. Central Bank of Nigeria Risk-Cybersquatting Framework and Guidelines for Other Financial Institutions 2022.