Last Updated 3RD May 2021
Important information and who we are
E-TRAVEL NIGERIA LTD is the data controller and responsible for your Personal Information.
The data we collect about you
Personal Information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes physical address, email address and telephone numbers.
- Transaction Data includes includes financial data and details about payments to and from you and other details of products and services you have requested from us
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, type of device used and other technology on the devices you use to access this website.
- Profile Data includes your username and password, requests or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use the Sites.
- Communications Data includes your communication preferences
We do not collect any Special Categories of Personal Information about you—this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
If you fail to provide Personal Information
Where we need to collect Personal Information by law, or under the terms to provide a service or product to you, and you fail to provide that data when requested, we may not be able to provide the service or product we have or are trying to provide to you. In this case, we may have to cancel a product or service you have with us but may still notify you if this is the case at the time.
How is your Personal Information collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You
may give us your Identity, Contact, and Transaction Data
by filling in forms or by corresponding with us by post,
phone, e-mail or otherwise. This includes Personal
Information you provide when you:
- apply for or subscribe to our products or services;
- create an account on any of the Sites; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with the Sites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources.
We will receive Personal Information about you from
various third parties and public sources as set out
Technical Data from the following parties:
- analytics providers such as Google based inside or outside Nigeria;
- search information providers based inside or outside Nigeria.
- Contact and Transaction Data from providers of technical, payment and delivery services such as Paystack based inside or outside Nigeria.
- Identity and Contact Data from data brokers or aggregators based inside or outside Nigeria.
- Identity and Contact Data from publicly available sources.
- Direct interactions. You may give us your Identity, Contact, and Transaction Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes Personal Information you provide when you:
How we use your Personal Information
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
- Where we need or about to provide a service or product to you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Purposes for which we will use your Personal Information
We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user||(a) Identity (b) Contact||Provision of a service or product to you|
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover fees owed to us||(a) Identity (b) Contact (d) Transaction (e) Communications||(a) Provision of a service or product to you (b) Necessary for our legitimate interests (to recover fees due to us)|
|To administer and protect us and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for provision of services, network security, and to prevent fraud. (b) Necessary to comply with any legal obligation|
|To deliver relevant platform content to you and measure or understand the effectiveness of the services we provide to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Communications (f) Technical||Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our offerings and to inform the Sites/user strategy)|
|To use data analytics to improve the Sites, products/services, user relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of users for our products and services, to keep the Sites updated and relevant, to develop our business and to inform the Sites/user strategy)|
|To issue directives and receive suggestions and recommendations about our services.||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Communications||Necessary for our legitimate interests (to develop our products/services.)|
Legitimate Interest means the interest of our mandate, object, and services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Provision of a Service or Product means processing your data where it is necessary for the performance of a service or product you requested from us and to which we have agreed or obliged to provide to you.
Comply with a legal obligation means processing your Personal Information where it is necessary for compliance with a legal obligation that we are subject to.
Cookie and Other Tracking Technologies
A cookie is a small text file that includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet-enabled device when you visit an on-line site. Cookies and other tracking technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as "cookies".
We also use web beacons—electronic images (or single-pixel gifs) that we use to help deliver cookies on the Sites. We may also use web beacons in our emails. So when we send emails to you, we may track behavior such as who opened the emails. This allows us to measure the performance of our emails.
Withdraw Your Cookies Consent at Any Time
How to Manage and Delete Your Cookies
Change of purpose
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your Personal Information
We may share your Personal Information with the parties set out below for the purposes set out in the table [Purposes for which we will use your Personal Information] above.
Internal Third Parties including our employees.
External Third Parties including (x) service providers acting as processors based in Nigeria or any other country who provide IT and system administration services; (y) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Nigeria or any other country who provide consultancy, banking, legal, insurance and accounting services; and (z)such other third parties as may be necessary to us and the use, safety, security, and performance of the Sites.
We require all third parties to respect the security of your
Personal Information and to treat it in accordance with the
law. We do not allow our third-party service providers to use
your Personal Information for their own purposes and only
permit them to process your Personal Information for specified
purposes and in accordance with our instructions.
E-TRAVEL NIGERIA LTD is based in Nigeria and stores and processes your Personal Information on computers in Nigeria. Where we need to transfer your Personal Information to another country, we will take all reasonable steps to ensure that any such transfers comply with applicable law. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of Nigeria.
Where you are accessing the Sites or services from outside Nigeria, please note that any information collected may be processed in accordance with Nigerian laws, which may be different from the laws applicable in your country of residence.
We are very particular about preserving your privacy and protecting your data at E-TRAVEL NIGERIA LTD. Therefore, to avoid the loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction of your information, we have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
Despite this, we cannot completely guarantee the security of any information you transmit via the Sites, as the internet is not an entirely secure place. We have put in place procedures to deal with any suspected Personal Information breach and will notify you.
How long will you use my Personal Information?
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal or regulatory.
Your legal right as a Data Subject
Because we determine the purposes for and the manner in which your Personal Information may be processed, we are regarded as a data controller. Likewise, because you can be identified directly or indirectly through certain categories of data that is specific to your identity, the law regards you as a data subject.
As a data subject, the law vests you with certain rights—they include the right to:
Request access to the Personal Information we hold about you, and request correction of such information where you believe it to be inaccurate.
Obtain a copy of the Personal Information we hold about you.
Restrict the processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: If you want us to establish the data's accuracy; Should our use of the data be unlawful but you do not want us to erase it; Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Object to the processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Where feasible, receive all Personal Information you have provided to us—in a structured, commonly used, and machine-readable format—and to transmit the information to another data controller.
Withdraw your consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request the erasure of your Personal Information (also known as the right to be forgotten.)This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, in the event your information has been processed unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
If you wish to exercise any of the rights set out above at any time, please send us an email at at hello@E-TRAVEL NIGERIA LTD.com
No fee usually required
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may notify you and keep you updated.