Data Privacy Lawyers Association of Nigeria (DPLAN) Privacy Policy

1. Introduction

We, the Data Privacy Lawyers Association of Nigeria (DPLAN), are the controller of the personal data collected via this website and through other means. As the data controller, we are legally responsible for determining how and for what purposes your personal data is processed. We take your privacy very seriously. This privacy policy explains who we are and details how, why, and for what purposes we collect, store, use, and share any information related to you (your personal data) in connection with your use of our website and other interactions with us. It also outlines your rights regarding your personal data and provides contact details should you wish to raise any concerns or complaints.

2. Legal Basis and Age Requirement

We process your personal data in compliance with the Nigeria Data Protection Act 2023 (NDPA). In light of the nature of our website, we do not expect to collect personal data from anyone under the age of 18. If you become aware that any personal data of an individual under 18 has been inadvertently provided to our website, please notify us immediately so that we can delete the data.

3. Scope of This Privacy Policy

This policy applies to your use of our website and any dealings with us. Our website may contain links to third-party websites managed by trusted partners. These websites may have their own privacy policies; please review those policies separately to understand how your personal data is managed by those entities.

4. Personal Data We Collect

The personal data we collect depends on the services and interactions you have with us. The data we may collect includes, but is not limited to:

• Identification & Contact Information:
  Your name, address, email address, telephone number, and, where applicable, company details.

• Professional & Educational Details:
  Information regarding your professional and academic qualifications.
• Verification Data:
  Information used to verify your identity (e.g., date of birth).
• Demographic Information:
  Your gender, if you choose to provide it.
• Payment Information:
  Details necessary to process transactions.
• Communication Records:
  Information and feedback provided via phone, email, post, or social media.
• Online Presence:
  Details of your professional online profiles, such as your LinkedIn profile.
• Other Relevant Information:
  Any additional data you provide that is necessary for the specific services or interactions.

In cases where you have the option to provide personal data, we will clearly inform you if withholding such data may affect your ability to use our website or services.

5. How We Collect Your Personal Data

We collect personal data from you through the following channels:

• Direct Collection:
  When you voluntarily provide information by applying for membership, contacting us (including via email), providing feedback, completing surveys, or participating in competitions on our website.
• Indirect Collection:
  Through your browsing behaviour on our website, facilitated by technologies such as cookies and other tracking tools (details on cookies are provided below).

6. How and Why We Use Your Personal Data

We process your personal data only when there is a lawful basis for doing so. The legal bases include:

• Consent:
  When you have given explicit permission.
• Compliance:
  To adhere to legal and regulatory obligations.
• Contractual Necessity:
  For the performance of a contract with you or in preparation for entering into a contract.
• Legitimate Interests:
  Where we have a valid business or commercial interest, provided it does not override your rights.

Legitimate Interests Assessments:
When processing based on legitimate interests, we conduct an assessment to ensure that our interests are balanced against your rights. Details of this assessment can be provided upon request.

The table below summarises the purposes for which we use your personal data and the corresponding legal bases:

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7. Sharing Your Personal Data

We may share your personal data with third parties under the following circumstances:

• Service Providers:
  Third parties who assist with the planning and execution of our activities, events, and programmes (e.g., marketing agencies, website hosting and analytics providers, banks). We ensure these providers adhere to strict data protection measures.
• Professional Advisors and Auditors:
  Our external auditors and professional advisors (including lawyers) with whom confidentiality is strictly maintained.
• Legal and Regulatory Authorities:
  Law enforcement agencies, courts, tribunals, and regulatory bodies as required by law.
• Corporate Transactions:
  In connection with significant corporate transactions or restructuring (e.g., mergers, acquisitions, asset sales, initial public offerings, or insolvency). In such cases, personal data will be anonymised where possible and shared only as necessary. Any recipient is bound by confidentiality obligations.

For additional details on our data sharing practices, please contact us.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected. Once the retention period expires, your personal data will be securely deleted or anonymised.

9. Cookies and Other Tracking Technologies

A cookie is a small text file placed on your device when you visit our website. We use cookies—and similar technologies such as web beacons and single-pixel gifs—to recognise your device, remember your preferences, and analyse website usage. For detailed information on our cookie practices, how we request your consent, and how you can disable cookies, please refer to our Cookie Policy.

10. Your Rights

Under applicable data protection law, you have several rights regarding your personal data including:

• Access:
  The right to obtain a copy of your personal data.
• Correction:
  The right to have any inaccurate personal data corrected.
• Erasure:
  The right to request deletion of your personal data under certain conditions.
• Restriction:
  The right to request that we restrict the processing of your personal data.
• Data Portability:
  The right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to a third party under certain conditions.
• Objection:
  The right to object to the processing of your personal data, particularly for direct marketing purposes or when processing is based on our legitimate interests.
• Automated Decision-Making:
  The right not to be subject to decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects.
• Withdrawal of Consent:
  If processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing conducted prior to your withdrawal.

To exercise any of these rights, please contact us using the details provided below. When contacting us, please include sufficient information to verify your identity and specify which right(s) you wish to exercise.

11. Security of Your Personal Data

We have implemented appropriate security measures to protect your personal data from accidental loss, unauthorised access, or misuse. Access is limited to individuals with a genuine need to know, and we have robust procedures to address any suspected data security breaches. Should a breach occur, we will notify you and the relevant regulatory authority as required by law.

12. Complaints

If you have any queries or concerns about our use of your personal data, please contact us using the details below. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) by visiting their website.

13. Changes to This Privacy Policy

We may update this privacy policy from time to time. Should any significant changes occur, we will take reasonable steps to inform you.

14. How to Contact Us

For any inquiries or to exercise your rights, please contact:

Data Privacy Lawyers Association of Nigeria (DPLAN)
12 Berkeley Street
Lagos Island, Lagos, Nigeria

Attn: Data Protection Officer – Emmanuel Tochukwu Okpara
Tel: +2348060707269
Email: privacy@dplan.ng