Johnvents Group (“Johnvents Group”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you visit our website, communicate with us, use our online services, submit forms, subscribe to our communications, apply for opportunities or otherwise interact with Johnvents Group.
It also explains your rights in relation to your personal data and how you can exercise those rights.
This Policy is intended to apply to processing carried out in accordance with applicable data protection laws, including the Nigeria Data Protection Act 2023 (NDPA) and, where applicable, the EU General Data Protection Regulation (GDPR) and UK GDPR.
1. Who We Are
Johnvents Group and its affiliated and group companies operate across various sectors and markets.
For the personal data covered by this Privacy Policy, Johnvents Group or the relevant Johnvents Group company may act as the data controller, meaning the organization that determines why and how your personal data is processed.
Where another organization processes personal data on our behalf, that organization may act as a data processor.
2. Personal Data We Collect
Depending on how you interact with us, we may collect the following categories of personal data.
Information You Provide Directly
This may include:
- Contact information: name, email address, telephone number and company/organization;
- Contact and enquiry information: subject, enquiry type and message;
- Newsletter information: email address and subscription preferences;
- Report and document download information: first name, last name, email address, telephone number and company/organization;
- Employment information: information contained in applications, CVs and related correspondence;
- Business and partnership information: information provided when engaging with us in a professional or commercial capacity;
- Correspondence: information contained in communications you send to us by email, through our website or through our official social media channels.
Information Collected Automatically
When you use our website, we may automatically collect certain technical and usage information, including:
- IP address;
- browser and device information;
- operating system;
- approximate location;
- pages visited;
- time spent on pages;
- referring and exit pages;
- website interaction information; and
- information collected through cookies and similar technologies.
The information collected automatically depends on the technologies enabled on our website and your cookie preferences.
3. How We Use Personal Data
We may process personal data for the following purposes:
- To respond to enquiries, requests and partnership opportunities;
- To provide documents or information requested by you, including our Sustainability Report;
- To administer newsletter and mailing-list subscriptions;
- To send communications where you have requested or consented to receive them;
- To manage recruitment and communicate with job applicants;
- To operate, maintain, secure and improve our website;
- To understand website usage and improve our digital content and user experience;
- To manage our business relationships and engagements;
- To meet legal, regulatory, accounting and reporting obligations;
- To establish, exercise or defend legal claims and protect our rights and interests; and
- For other purposes communicated to you at the time your personal data is collected.
We will not use your personal data for purposes that are incompatible with the purpose for which it was collected unless permitted by applicable law or otherwise appropriately disclosed to you.
4. Lawful Bases for Processing
We process personal data only where we have a lawful basis to do so under applicable data protection law.
Depending on the circumstances, our lawful bases may include:
Consent
We may rely on your consent where you have voluntarily agreed to a particular use of your personal data, such as subscribing to certain marketing communications or consenting to non-essential cookies where required.
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
Contract or Steps at Your Request
We may process personal data where it is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract.
Legal Obligation
We may process personal data where necessary to comply with applicable legal, regulatory, accounting or reporting obligations.
Legitimate Interests
We may process personal data where necessary for our legitimate interests or those of a third party, provided that those interests are not overridden by your fundamental rights and freedoms.
Our legitimate interests may include operating and securing our website, managing business relationships, responding to business enquiries, improving our services and protecting our legal and commercial interests.
Where we rely on legitimate interests, we consider the impact of the processing on your rights and interests.
Other Lawful Bases
Where applicable, we may rely on other lawful bases recognized under the NDPA or other applicable data protection legislation.
5. Sustainability Report and Document Downloads
If you request to download or receive a Johnvents report or other document, we may collect information such as your name, email address, telephone number and company/organization.
We use this information to:
- provide the requested document;
- administer and maintain the download service;
- understand interest in our reports and publications;
- respond to related enquiries; and
- where permitted and appropriately authorized, communicate with you about relevant Johnvents updates or initiatives.
Receiving a requested document does not, by itself, mean that you have agreed to receive marketing communications.
Where we wish to send you marketing or promotional communications, we will obtain consent where required by applicable law and provide an appropriate way to withdraw that consent.
6. Marketing Communications
Where you subscribe to receive newsletters or other marketing communications, we may use your contact information to send you relevant updates about Johnvents Group, including company news, sustainability initiatives, publications, events and other communications that you have agreed to receive.
You can unsubscribe from marketing communications at any time by using the unsubscribe option included in our communications or by contacting us.
We will not make continued receipt of marketing communications a condition for accessing a service where such consent is not necessary for that service.
9. International Transfers
Some of our group companies, service providers or business partners may operate in countries outside Nigeria and, where applicable, outside the European Economic Area or United Kingdom.
Where personal data is transferred internationally, we will take appropriate steps to ensure that the transfer is carried out in accordance with applicable data protection laws and that appropriate safeguards are in place where required.
Where applicable, you may contact us using the details below to request further information about relevant international transfers and safeguards.
10. Data Security
We use appropriate technical and organizational measures designed to protect personal data against unauthorized access, accidental loss, destruction, alteration, disclosure or other unlawful processing.
These measures may include access controls, authentication, confidentiality requirements, security monitoring and appropriate organizational procedures.
However, no method of transmission or electronic storage is completely secure. We therefore cannot guarantee absolute security of information transmitted to or stored by us.
11. Data Retention
We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including where necessary to satisfy legal, accounting, regulatory or reporting requirements.
The period for which personal data is retained depends on:
- the nature and purpose of the processing;
- the type and sensitivity of the information;
- whether we have an ongoing relationship with you;
- applicable legal or regulatory requirements; and
- whether the information is required to establish, exercise or defend legal claims.
When personal data is no longer required, we will take appropriate steps to securely delete, anonymize or otherwise dispose of it in accordance with our retention procedures.
12. Your Rights Under Nigerian Data Protection Law
If you are a data subject under the Nigeria Data Protection Act 2023, you may have rights including the right to:
- be informed about the processing of your personal data;
- request access to personal data we hold about you;
- request correction of inaccurate or incomplete personal data;
- object to certain processing;
- request restriction of processing in applicable circumstances;
- request deletion or erasure of personal data, subject to applicable exceptions;
- request portability of your personal data where applicable;
- withdraw consent where processing is based on consent;
- object to certain automated decision-making, where applicable; and
- lodge a complaint with the Nigeria Data Protection Commission.
These rights are subject to applicable legal conditions and exemptions.
13. Rights of EU and UK Data Subjects
Where the GDPR or UK GDPR applies to our processing of your personal data, you may have additional rights, including:
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restriction of processing;
- the right to data portability;
- the right to object to processing;
- the right to withdraw consent where processing is based on consent; and
- rights relating to automated decision-making and profiling, where applicable.
Where we process your personal data based on legitimate interests, you may have the right to object to that processing.
You may also have the right to lodge a complaint with the data protection supervisory authority in your country or jurisdiction.
14. Information You Are Required to Provide
In some circumstances, certain personal data may be necessary for us to respond to your request, provide a service, enter into a contract, process an application or comply with a legal obligation.
Where information is required, we will endeavour to indicate this at the point of collection.
If you choose not to provide information that is necessary for a particular purpose, we may be unable to provide the requested service or respond fully to your request.
15. Children's Privacy
Our website is intended primarily for a general business and professional audience and is not directed at children.
We do not knowingly collect personal data from children in circumstances where such collection is prohibited by applicable law.
If you believe that a child has provided us with personal data, please contact us so that we can assess the circumstances and take appropriate action.
16. Third-Party Websites and Links
Our website may contain links to third-party websites, platforms or services.
This Privacy Policy does not apply to those third-party websites. We encourage you to review the privacy policies of any third-party website you visit.
Johnvents Group is not responsible for the privacy practices, content or security of third-party websites.
17. Automated Decision-Making and Profiling
We do not currently intend to use personal data collected through this website to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.
Where this changes, we will provide appropriate information and protections as required by applicable data protection law.
18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business practices, technology, data-processing activities or applicable legal and regulatory requirements.
When we make changes, we will update the “Last Updated” date at the top of this page.
Where required by applicable law, we will provide additional notice or seek consent for material changes.
19. Contact Us
If you have questions about this Privacy Policy, wish to exercise your data protection rights, or have a concern about how your personal data is being processed, please contact us:
Johnvents Group
Email: support@johnvents.com
You may also contact us through the contact form available on our website.
When making a data protection request, we may need to take reasonable steps to verify your identity before responding.
Where applicable, you may also lodge a complaint with the Nigeria Data Protection Commission (NDPC) or the relevant data protection supervisory authority in your jurisdiction.
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