This privacy notice describes our policies and procedures on the collection, use and disclosure of your information and tells you about your privacy rights and how you can exercise them. By ‘your information’, we mean any information provided to us by you or a third party

Definitions

This privacy notice (the “Privacy Notice” or “this notice”) relates to all personal information processing activities carried out by Pension Alliance Limited (PAL Pensions). PAL Pensions is a data controller for personal information collected and processed for our business (including the products and services that we provide). In this notice, references to:

You mean the individual or business customer, or partner (which includes suppliers or other organizations we do business with.

Company (either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Pensions Alliance Limited or PAL Pensions

Accounts means a unique account created for you to access our service or parts of our service.

Personal Information is any information that relates to an identified or identifiable individual.

CONSENT

We will provide you with our privacy policy whenever we collect your personal information, regardless of the medium used. Your consent will be obtained by asking you to click on a button to acknowledge the policy if the medium used to collect your personal information is in an electronic format. If your personal information is collected through a paper document, we will request that you sign the document, acknowledging your understanding of an agreement to our privacy policy.

PERSONAL INFORMATION COLLECTED

When using our service, we may request that you provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

User-Provided Information

• Data you share with us through various channels, such as our website, mobile applications, and paper forms.

Personal Identifiers

• Details including your name, age, gender, sex, and identification numbers.

Contact Information

• Physical and email addresses, as well as phone numbers.

Technical and Online Data

• Information related to your online activities, including cookies, geolocation data, and IP addresses.

Visual Identifiers

• Photographs, CCTV footage, and video recordings, along with official identifiers like your National Identification Number (NIN), Tax Identification Number (TIN), and Bank Verification Number (BVN).

Engagement Data

• Records of your interactions with us, including product usage, transactions, inquiries, applications, and complaints.

Analytical Reports

• Internal reports and derived data based on the personal information we gather.

Relationship Information

• Details about your connections with individuals or organizations that help verify your identity, such as family members, government agencies, and employers.

Sensitive Personal Data

• Additional sensitive information, including biometric data and ethnic background.

Publicly Available Information

• Data collected from public sources like news articles, company registries, and online search engines.

Third-Party Information

• Information received from external sources, including service providers, government agencies, and regulatory bodies.

Technology-Related Information

• Data gathered from the devices you use to access our services, such as location data from mobile phones or IP addresses, as well as patterns of usage.

PERSONAL INFORMATION USAGE

When you provide your information to us, we may use the information we collect in the following ways:

To manage our relationship with you or your business

Service Delivery and Monitoring

• To deliver and sustain our services, including tracking their usage.

Compliance Checks

• To conduct necessary business integrity checks and conduct checks for compliance, including onboarding, due diligence, and assurance reviews.

Adherence to Regulations

• To meet regulatory and legal obligations while managing risks.

Code of Conduct Compliance

• To follow both mandatory and voluntary codes of conduct.

Fraud Prevention

• To identify, prevent, and report activities related to theft, terrorist financing, money laundering, corruption, and other illegal actions that may result in losses.

Account Management

• To oversee your account registration, allowing you access to various features available to registered users based on the personal data you provide.

Contract Fulfillment

• To develop, comply with, and execute the purchase agreement for the services you subscribe to, or any other contracts established through our service.

Communication

• To reach out to you via email, phone, SMS, or other digital communication methods, including app notifications about updates and important information related to our services.

Promotional Information

• To inform you about news, special offers, and general updates regarding services and events similar to those you have shown interest in, unless you have opted out of receiving such information.

Request Management

• To address and manage any inquiries or requests you submit to us.

INFORMATION SHARING

When you share your information with us, we may use the information for the following purposes: 

Business Transactions

If PAL Pensions is involved in a merger, acquisition, or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the company may be required to disclose your personal data if compelled to do so by law or in response to valid requests from public authorities (e.g., a court or government agency).

Other requirements

The Company may disclose your personal data in good faith where such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
• Consent is provided
• Required by court orders or legal process
• Violation of any part of our Privacy Notice
• Third parties conduct business on our behalf. These parties process such information for specific and limited purposes, in compliance with the privacy notice and any other appropriate confidentiality and security measures

Sensitive personal data (also known as special categories of personal data) makes up the information we collect from you. We may process biometric data for services that require it. We process such sensitive personal data when you have provided your consent or otherwise required by applicable law, and this information will be collected and processed only for the particular purposes and activities for which the information is provided.

Transfer of Your Personal Data

Your information, including personal data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to—and maintained on—computers located within Nigeria. Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.

PAL Pensions will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your personal data will take place to an organization or a country without your consent and adequate controls in place.

Information Retention

PAL Pensions will retain Your Personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will retain and use your personal data to the extent necessary to comply with our contractual obligations with you and once our contract with you has come to an end (e.g. closure of your account), we will only retain your personal data for a period of time that is, depending on the type of personal data, and the purposes for which we hold that information

 The Company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when it is used to strengthen security or improve the functionality of our service, or when we are legally obligated to retain this data for longer periods.

Your Rights
Subject to applicable laws, Nigeria Data Protection Regulations, and/or pension industry guidelines, you have the following rights:

• To request a copy of the personal data processed in relation to you
• To request that we correct your personal data
• To request that we delete your personal data, for example, if we no longer have a valid reason to process it
• To object to how we process your personal data
• You may request that your personal data be sent to another third party under specific conditions. Once the data is transferred, that third party will be responsible for its protection. Please be aware that this right applies only to information for which you initially gave us consent to use or that we used to fulfill a contract with you.
• To restrict how your personal data is processed in certain cases, such as when the accuracy of your personal data is contested
• To request a copy of the personal data you have given to us in a machine-readable format
• Lodge a complaint with the Nigerian Data Protection Commission (NDPC).                 

Governing Law

This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2023) or any 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.

Contact us

Pensions Alliance Limited (PAL Pensions) strives to resolve your private complaints and concerns as quickly as possible. If you have a concern, complaint, or question regarding this Privacy Notice, you may contact us through the following means:

Head Office: Plot 289, Ajose Adeogun Street, Victoria Island, Lagos.

Phone: 0201-2776900, 080072573674667 (Toll-free)

E-mail: dataprotectionofficer@palpensions.com or info@palpensions.com

Website: www.palpensions.com