1.1 Scope

This privacy policy will help you understand how Samsung Heavy Industries Nigeria (SHIN) / SHI-MCI FZE 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 visit our website (www.shi-mci.com) frequently.

1.2 What User Data We Collect

When you visit the website and engage us, we may collect the following data including but not limited to:
● Your name, Identity card details, nationality, bank information.
● Your phone no, contact information and email address.
● Other information such as interests and preferences.
● Data profile regarding your online behaviour on our systems.

1.3 Why We Collect Your Data:

We are collecting your data for several reasons including but not limited to:
● Fulfillments of contracts (Employments, Business, and Sub-contractors etc.)
● Fulfillment of legal obligations (Tax etc.)
● Provision of Welfare Services (Health Insurance etc.)
● Security, Safety and access to our premises. (Access card, Surveillance cameras, etc.)
● Legitimate interest where necessary (promotional emails, surveys, market research, etc.)
● To customize our website according to your online behaviour and personal preferences.

1.4 Safeguarding and Securing the Data

While we will not transfer your personal data outside Nigeria without your prior consent, SHIN/SHI-MCI FZE is however committed to securing your data and keeping it confidential in accordance with international best practices. SHIN/SHI-MCI FZE shall do all in its power to prevent data theft, unauthorized access, and disclosure by implementing policies, processes, and technologies, which help us safeguard all the information we collect. Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

1.5 Terms and Definitions

● “Us”,” We” And “Our” refer to Samsung Heavy Industries Nigeria (SHIN)/ SHI-MCI FZE ● “Your” refer to Data Subject

1.6 Responsibilities

The Data Protection Officer is responsible for all aspects of the implementation and management of this policy. 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 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 NDPA 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. In addition, as a Data Subject the following are your rights as contained in the NDPA:
• Right to be Informed: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request us to correct any inaccurate or incomplete personal data we hold about you.
• Right to Object to Processing: You can object to how we use your personal data, in certain situations. You can also request that we limit the way we use your personal data.
• Right to Data Portability: You can request a copy of your personal data in a format that allows you to easily move it to another service provider.
• Right to be Forgotten: You have the right to request that your data with us be forgotten.
• Right in Relation to Automated Decision Making (which essentially entitles you to human intervention).
• Right to withdraw Consent: You have a right to withdraw at any time, consent to the processing of your personal data.

2.2 Consent

Your acceptance of this Policy will give consent upon access to 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 also governs the use of our services and intervention projects by our users and stakeholders unless otherwise agreed through a written contract.

2.3 Your Personal Information

When you use our Services, we collect information sent to us by your computer, mobile phone, or other electronic access device. The automatically collected information includes but is not limited to data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, trace to and from the sites, referral URL, advertisement data, standard web log data, still and moving images etc. We may also collect the information you provide us including but not limited to information on a web form, survey responses, account update information, email, phone number, the organization you represent, social position, and correspondence with our support services. We may also collect information about your transactions, inquiries, and your activities on our platform or premises. We may also use information provided by these parties like social media sites.

2.4 What we will do with your personal information

The purpose of collecting your personal information is to give you efficient, enjoyable and secured services. We may use your information, including but not limited to:
1. Provide service and support
2. Process applications and send notice about your transaction to third parties
3. Verify your identity.
4. Resolve disputes / collect fees and troubleshoot problems
5. Manage risk or detect, prevent, or remediate fraud or other potentially prohibited or illegal activities.
6. Detect, prevent, or remediate violations of laws, regulations, standards, guidelines, and frameworks.
7. Improve our services by implementing aggregate customer or user preference
8. Measure the performance of our Company
9. Track information breaches and remediate such identified breaches
10. Manage and protect our information technology and physical infrastructure.

2.5 How we protect your personal information

We store and process your personal information on our Systems or records. We will seek consent when we need to send your data to a country without an adequate data protection law. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized 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.

2.6 How long we keep your information (retention period)

We retain your information in accordance with the retention period of each record category and securely destroy them when they are no longer required for that purpose in which they were obtained in accordance with NDPA requirement. In cases where it is required by law, we will retain it for the period specified by such.

2.7 Data Confidentiality Rights

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 information we keep on you if such requests are made in compliance with the Freedom of Information Act and other relevant enactments. While we are 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 authorized officers of the agency.

2.8 Links to other websites and premises

Certain transaction processing channels may require links to other websites or organizations other than ours. Please note that We are not responsible and has no control over the organization or website domain. We do not monitor or review the content they store which are linked to ours. Please be aware that we are responsible for the privacy practices or content of our organization. We encourage users to be aware that when dealing with such organizations, they should evaluate the security and trustworthiness before providing any personal information. We will not accept any responsibility for loss or damage in whatever way resulting from the disclosure to third parties of personnel information.

2.9 Governing Law

This Privacy Policy is made in accordance with the Nigeria Data Protection Act (2023) and other relevant Nigerian laws, regulations, or international conventions applicable in 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.

3 Breaches of Policy

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