1.1. Purpose  and Scope This privacy policy will help you understand how Loma MFB uses and protects the data you provide to us when you visit and engage us. 

We reserve the right to change this policy at any given time, of which you will be promptly updated. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit our website.

1.2. Responsibilities

The Data Protection Officer is responsible for all aspects of the implementation and management of this policy, unless noted otherwise. 

Department heads and supervisors are responsible for the implementation of this policy, within the scope of their responsibilities, and must ensure that all staff under their control understand and undertake their responsibilities accordingly.

2.1 What User Data We Collect

When you visit the website and engage us, we may collect the following data:

• Your IP address.

• Your Name, contact information and email address.

• Other information such as interests and preferences.

• Data profile regarding your online behaviour on our website.

2.2 Why We Collect Your Data

We are collecting your data for several reasons:

• To better understand your needs.

• To improve our services and products.

• To send you promotional emails containing the information we think you will find interesting.

• To contact you to fill out surveys and participate in other types of market research.

• To customise our website according to your online behaviour and personal preferences.

2.3 Your Choices And Access To Your Information

We may communicate with you via the following channels for the duration of our business relationship;

• E-mail 

• SMS

• Phone call 

• Hard copy letter

• And so, we may need to retain the contact information and email communications for record keeping, analysis or other reasons, to the extent permitted by law.

• Also, in order to keep your personal information accurate, You can view, correct, or update the personal contact information you provide to Loma MFB.

• Contact our Data Privacy Officer to guide you on how to access and update the personal information you provided to Loma MFB. We will respond to validated requests in an appropriate time frame.

2.4 Your Privacy Rights

• This Privacy Policy describes privacy rights regarding the collection, usage, storage, sharing and protection of personal information. It is in line with NDPC including database applications, services, tools and physical contact with us regardless of how you access or use them. If you have created a username, identification code, password or any other piece of information as part of the access security measures, you must  treat such information as confidential, and you must not disclose it to any third party. We reserve the right to disable any user identification code or  password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these conditions.

2.5 Consent

• Loma MFB will acquire consent upon acceptance of privacy notice on our platforms, or use of services, content, features, technologies or functions offered on our website, digital platforms or visit any of our offices for official or non-official purposes. 

• This Policy governs the use of Loma MFB services and intervention projects by our users and stakeholders unless otherwise agreed through a written contract.

2.6 How we Collect Your Personal Information

• When you use Loma MFB Services, we collect information from our website, email, phone calls and digital forms. The automatically collected information includes but not limited to- data about the Loma MFB web pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information.

• We may also collect information you provide us including but not limited to- information on web form, survey responses, account update information, email, phone number, organisation you represent, social position, correspondence with Loma MFB support services. We may also collect information about your transactions, enquiries and your activities on our platform or premises. We may also use information provided by these parties like social media sites.

2.7 What we will do with your personal information

• The purpose of collecting your personal information is to give you efficient, enjoyable and secure services. We may use your information to:

• Provide service and support

• Process applications and send notice about your transaction to request parties

• Verify your identity.

• Resolve disputes / collect fees and troubleshoot problems

• Manage risk or detect , prevent or remediate fraud or other potentially prohibited or illegal activities.

• Detect , prevent or remediate violation of laws , regulations , standards, guidelines and frameworks.

• Improve Loma MFB services by implementing aggregate customer or user preference

• Measure the performance of Loma MFB   

• Track information breach and remediate such identified breaches

• Manage , protect our information technology and physical infrastructure. 

2.8 Cookies

• Cookies are small files placed on your computer’s hard drive that enables the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted  session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user.

2.9 Data Minimization

• Loma MFB limits Personal Information collection and usage to data that is relevant, adequate, and necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

2.10 Personal Information Sharing

• Accordance with ISO 27001 Requirements We take steps to protect personal information no matter what country it is stored in or transferred to. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls.

• We share your personal information only as described below and within Loma MFB:

2.11 Intra Transfer of personal data

• Loma MFB does not share Personal data of Data subjects with third parties, however, In the event that data is transmitted to a recipient outside the organisation, this recipient must agree to maintain a data protection level equivalent to this Policy. This does not apply if transmission is based on a legal obligation.

2.12 International Transfer of personal data

• Loma MFB does not currently transfer personal data of Data subjects to parties outside Nigeria, however, When it is needed for personal information to be transferred to, stored, and processed in a country other than the one in which it was provided, we shall do so taking into consideration the applicable data protection laws for the transfer of personal information.

2.13 Data Confidentiality

• Your information is regarded as confidential and will not be divulged to any third party except under legal and/or regulatory conditions. You have the  right to request sight of, and copies of any and all information we keep on you, if such requests are made in compliance with the Freedom of  Information Act and other relevant enactments. 

• While Loma MFB is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform logins details and adherence with physical security protocols on the premises, dealing with only authorised officers of the agency.

2.14 Information Security

• Loma MFB will always hold your information securely. To prevent unauthorised access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. This site uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. 

• The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.

• Loma MFB has also taken measures to comply with global Information Security Management Systems (ISMS) ; we therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.

2.15 Data Storage, Retention and Disposal

• Personal information and records of Data Subjects shall be securely housed within our Secured Systems and protected as defined above. These  information and records will only be stored, retained and disposed for in compliance with ISO 27001 and NDPA requirements

• Personal Data of data subjects shall be stored only for the duration of processing activity and securely disposed after a period of 6 Months. Personal Data of Data Subjects may be archived for future reference, if required by law or regulatory bodies.

2.16 Age Restriction

• Loma MFB does not provide services, collect or process Personal information of children. We do not knowingly transact or provide any services to children under 18.

2.17 Links to other website and premises 

• Certain transaction processing channels may require links to other websites or organisations other than ours. Please note that Loma MFB is not responsible and has no control over the website domain. We do not monitor or review the content of other websites which are linked from ours . Please be aware that we are responsible for the privacy practices or content of our websites. 

• We encourage users to be aware that when they visit the website they should evaluate the security and trustworthiness of the site before providing any personal information. Loma MFB will not accept any responsibility for loss or damage in whatever way resulting from the disclosure to third parties of personnel information. 

2.18 Governing Law 

• This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2019) and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.

2.19 Deletion of data upon request by a data subject.

• The Data Subjects are required to contact related Data controllers (Banks) as regards to the erasure of personal data if permitted by law or regulatory body. 

If you have questions or concerns regarding Loma MFB Nigeria’s privacy practices, please register them with us by sending an email to our Data Privacy Officer [ [email protected] ]

Privacy Policy shall be reviewed annually or as required.

Loma MFB will take all necessary measures to remedy any breach of this policy including the use of our disciplinary, legal or contractual processes where appropriate.