PRIVACY STATEMENT

Ethnos Cyber Limited is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, ETHNOS IT is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, “personally identifiable information” or “PII”) that has been collected online.

Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this privacy statement to learn more about how we collect, use, share and protect the personal information that we have obtained.

Collection and Use of Personal Information

  • What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal information to ETHNOS (if, for example, you are a former employee). If you choose to register or login to a ETHNOS web site using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with ETHNOS, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to
share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

By registering and/or submitting personal information to ETHNOS IT, you are also acknowledging that ETHNOS IT may
use this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a ETHNOS IT web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other ETHNOS sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with ETHNOS, we will use the information that you provide to match you with available ETHNOS job opportunities.

In some cases where you have registered for certain services, we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

  • The legal grounds we have to use your personal information

ETHNOS generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection. The law in Nigeria allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:  

  • Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
  • Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or  law enforcement agency;
  • Legitimate interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
  • Your consent: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so.  You may withdraw your consent at any time by contacting ethnos@ethnos.com.ng


ETHNOS IT only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person’s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to ETHNOS, and under any circumstances, do not provide sensitive information to ETHNOS, unless you thereby consent to ETHNOS IT use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in ETHNOS IT databases. If you have any questions about whether the provision of sensitive information to ETHNOS IT is, or may be, necessary or appropriate for particular purposes, please contact ethnos@ethnos.com.ng

  • Automatic collection of personal information

In some instances, ETHNOS IT and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of ETHNOS IT online presence, and to measure the effectiveness of our marketing activities.

  • IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

  • Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes. On some of our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies. Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.

Further information about managing cookies can be found in your browser’s help file or through sites such as wallaboutcookies

Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly. Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

  • Location-based tools

ETHNOS may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

  • Social media widgets and applications

ETHNOS web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of ETHNOS web sites. Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, ETHNOS web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any ETHNOS social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

  • Children

ETHNOS understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Sharing and transfer of personal information

  • Transfers to third parties

We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:

  •   Our service providers: ETHNOS work with reputable partners, service providers or agencies so they
       can process your personal information on our behalf. ETHNOS will only transfer personal information to
         them when they meet our strict standards on the processing of data and security. We only share
         personal information that allows them to provide their services.
  •   If we are reorganized or sold to another organization: ETHNOS may also disclose personal information in connection with the sale, assignment, or other transfer of the business of the site to which the data relates.
  •   Courts, tribunals, law enforcement or regulatory bodies: ETHNOS may disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.
  •  Audits: disclosures of personal information may also be needed for data privacy or security audits and/or
      to investigate or respond to a complaint or security threat.

In addition, ETHNOS may transfer certain personal information outside of the (Economic Community of West African States) ECOWAS to offshore companies working with us or on our behalf for the purposes described in this Privacy Statement. ETHNOS may also store personal information outside of the ECOWAS. If we do this your personal information will continue to be protected by means of contracts we have in place with those organisations outside the ECOWAS, which are in a form approved by the ECOWAS. By providing personal information on online, visitors are consenting to this transfer and/or storage of their personal information across borders.

ETHNOS will not transfer the personal information you provide to any third parties for their own direct marketing use.

Choices

In general, you are not required to submit any personal information to ETHNOS, but we may require you to provide certain personal information in order for you to receive additional information about our services and events. ETHNOS may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

Your rights

If you have submitted personal information to ETHNOS, you have the following rights:

  • Access and correction: you have the right to access to that data. This is sometimes called a
       ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we
         will provide it to you free of charge. Before providing personal information to you, we may ask for proof
         of identity and sufficient information about your interactions with us that we can locate your
         personal information. If the information we hold about you is incorrect, you may ask us to correct
         any inaccuracies in the personal information.
  • Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have
         its processing restricted in certain circumstances.

You can make a request or exercise these rights by contacting ETHNOS at 
ethnos@ethnos.com.ng and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Data security and integrity

ETHNOS has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite ETHNOS’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual’s request or until that person asks that the information be deleted and, in any case, no longer than 7 years.

Links to other sites

Please be aware that ETHNOS web sites may contain links to other sites, including sites maintained by other ETHNOS member firms that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

By registering on any ETHNOS web site and then navigating to another ETHNOS web site while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the ETHNOS web site you are visiting.

Changes to this statement

ETHNOS may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how ETHNOS is protecting your information.

Policy questions and enforcement

ETHNOS is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at ethnos@ethnositcom. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

If you are not satisfied with the response you receive, you may escalate your concern to the Global Privacy Officer by sending an email to ethnos@ethnos.com.ng.
We will acknowledge your email within 2 working days and seek to resolve your concern within 3 months or receipt.  We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.

In any event, you always have the right to lodge a complaint with the Nigerian regulator in charge of protecting personal information.

“ETHNOS,” “we,” “our,” and “us” refers to ETHNOS Professional Services, a Partnership registered in Nigeria  a member of the ETHNOS network of independent firms affiliated with ETHNOS International.