Privacy Policy

National Association of Seadogs (Pyrates Confraternity)

Data Privacy Policy

  1. Introduction

We respect your privacy and are committed to protecting your personal data and any personal information you share with us when you visit our website or that we obtain about you in the course of your engagement with us, either as a member, volunteer, or financial supporter.

As a non-governmental humanitarian charitable organisation with significant international presence, we are in tune with international best practices in this regard and are strongly committed to ensuring that our privacy policies comply with these standards.

Generally, we ensure that our processing of any personal information provided through any of the above referenced sources, is in compliance with all data protection regulations applicable to the National Association of Seadogs (Pyrates Confraternity) (also referred to below as NAS), including but not limited to the Nigerian Data Protection Regulation 2019 and the General Data Protection Regulation (GDPR).

Thus, as further discussed here, you can contact us to: request access to information that we have about you, correct any information we have about you; and or/delete information that we have about you. If you have additional questions about our data collection or storage, please contact us at the National Association of Seadogs, Plot 55, Gado Nasko Road, Kubwa, Abuja, FCT, Nigeria. Tel: +234 809 898 1952. Email: privacy@nas-int.org.

This privacy policy (“Privacy Policy”) will explain the following:

  • Who we are
  • What data we may collect about you?
  • How do we collect your data?
  • How would we utilise the data we collect about you?
  • How do we store your data?
  • What are your data protection rights?
  • Changes to our privacy policy
  • How to contact us
  1. Who we are

The National Association of Seadogs (Pyrates Confraternity) is an organization registered on 31 October 1980 as a charitable association with the Nigerian Federal Ministry of Internal Affairs under the Land (Perpetual Succession) Act. Following the repeal of the Land (Perpetual Succession) Act in 1990, the association was operated under the successor legislation, namely Part C of the Companies and Allied Matters Act 1990, which has now been repealed and replaced by Part F of the Companies and Allied Matters Act 2020.

For the purpose of data protection legislation, NAS is the data controller in relation to the personal data processed by the association as part of its membership administration services as well as its volunteering, advocacy and fundraising activities.

In this Privacy Policy, all references to “us” and “we” are references to the National Association of Seadogs (Pyrates Confraternity) (also referred to elsewhere in this Privacy Policy as NAS); references to “you” are references to anyone using our Services; while references to “our Services” are references to membership of NAS, its membership welfare and administration services, its public enlightenment, advocacy, fundraising, volunteering and humanitarian activities, its publications and other services and activities as well as information provided on its website.

  1. What data we may collect about you

Due to the nature of our operations, when you contact us to become a member, collaborator, volunteer,  donor or to sign up for advocacy services or any other activity via our various contact points (including telephone, email, website, or in person), we may typically require different forms of personal data or information. By providing us with this information, you enable us to provide you or other members of the public with our Services and information regarding fundraising, donations and other activities.

For clarity, personal data, or personal information, means any information, whether sensitive or non-sensitive about an individual from which that person can be identified. It does not include data where the identity has been removed or the data subject has been classified as anonymous.

In handling your personal data, we are principally guided by the Nigerian Data Protection Regulations (NDPR) 2019, the GDPR and other international best practice privacy laws regarding the use, storage, and processing of the data.

In compliance with the above referenced laws and best practices, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, next of kin, dependants, profession, occupation and IP address.
  • Contact Data includes email address and telephone numbers.
  • Technical and usage data about if and how you access or use our website. We collect this data by using cookies on our website. A cookie is a small file placed on your computer’s hard drive. It enables us to recognize your computer as you view different pages on our website, allowing us to give you a better website experience. Cookies allow us to store your preferences to present content and functions that are specific to you.
  • Profile Data includes your username and password, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our website, publications, products and any other one of our Services.
  • Communications Data includes your preferences in receiving sensitization updates from us and our third parties and your communication preferences.
  • Photos and video taken at our conferences, workshops, retreats and other events may be used for awareness and other legitimate purposes. Unless specifically notified otherwise, NAS reserves the right to take and use any photos from our events on our website and in our awareness campaign materials.

We do not collect any sensitive data under the definition of sensitive data as provided by the NDPR. For the avoidance of doubt, “Sensitive Personal Data” means Data relating to religious or other beliefs, sexual tendencies, health, race, ethnicity, political views, trades union membership, criminal records, or any other sensitive personal information.

  1. How we collect your data

Most of the data we collect is directly provided by you. Such data is typically collected through any of the following means:

  • When you apply to join us as a member.
  • When you become a full member of NAS.
  • When you volunteer for any of our campaigns or projects.
  • When you contact us by telephone, email, website, walk-in etc.
  • In addition, we may also receive your data indirectly when you enter into partnership with us for any activity or program.

 

  1. How we utilise your data

We collect your data to enable us to efficiently perform our Services and we will only use your personal data when the law allows us to in furtherance of this service. Most commonly, we will use your personal data in the following circumstances:

  • Where we have your consent to do so and by virtue of our interactions your personal data is required in performing an in-house data analysis function. In the case of our members, this includes the use of their personal data in our membership database as well in connection with various membership welfare and administration services.
  • 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 are required to use your personal data in discharging a legal obligation, whether imposed by law, statute, or a competent court of law.

 

  • We also use your contact details to communicate with you by email, SMS, telephone and social media if you live in Nigeria or overseas. Any subsequent information you provide to the helpline will also be recorded to continue to provide you with a tailored service and engagement.
  • We may also use the data collected to contact you to gauge your interest in taking part in studies, surveys and other research that we may be engaged in from time to time. In each message, you will be given the opportunity to unsubscribe from further communications. We will use anonymised data about you to deliver tailored messages on third party platforms, including social media – such as Facebook, Instagram, Twitter, Snapchat and Google search. Such anonymised data will also be used to identify and reach out to people that are similar to you.

In addition, with your consent, we will share data provided by our members with our partner insurance companies and similar or related service providers for purposes of processing life and health insurance services for such consenting members.  Rest assured that such data shared would be treated with similar standards as set out in this Privacy Policy.

  1. How we store your data

We ensure that the best data security measures are put in place to guarantee the protection of any data we may have collected about you. We take severe steps to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data by our employees, agents, contractors and other third parties on a strict need-to-know basis. Such persons will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Personal data of our members is retained indefinitely while all other personal data supplied to us will be stored in our data management system for 5 years unless, where applicable, the subject of such data exercises their right to be forgotten or the data is no longer necessary for the purposes for which it was being processed, and in both cases the data will be deleted.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Transferring data internationally

For the purposes of our various programmes and activities, we may need to transfer your information from your country of residence to another country in the usual course of our business. By dealing with us and submitting your personal information, you agree to the transfer, storage, and/or processing of your personal information outside of your country of residence as set out below.

             International Engagements

If you are based outside Nigeria and contact us to become a member, collaborator, volunteer, donor or to sign up for advocacy services or any other one of our Services via our various contact points (including telephone, email, website, or in person), then we may transfer the personal data that we collect from you to the National Association of Seadogs (Pyrates Confraternity) (also referred to elsewhere in this Privacy Policy as NAS) in Nigeria.

           Transferring outside of the EEA

We may transfer your personal information to a third-party data processor located in countries outside of the European Economic Area (‘EEA’).

NAS only transfers your personal information to those third parties where we can be sure that we can protect your privacy and your rights. Where we use service providers outside the EEA, we rely on approved data transfer mechanisms (for example, the EU Standard Contractual Clauses and the EU-US Privacy Shield), or where we have a contract in place with the relevant  third party which includes the European Commission’s standard data protection clauses, to ensure that your personal information is adequately safeguarded in the recipient country.

By continuing to use this website or our Services, you consent to the transfer of your personal data to such third-party data processors located in countries outside the EEA. Unfortunately, transmission of information over the internet is not completely secure. We will do our best to protect your personal information, but we cannot guarantee its security and any transmission is at your risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access.

  1. Why our use of your personal data is lawful

In order for our use of your personal data to be lawful, we need to meet one (or more) conditions in the data protection legislation. You have requested to receive this or any other one of our Services and therefore, together with this privacy notice (about the use of your personal data), you have agreed to your data being used to deliver the relevant service. However, the condition that we are relying on (once you have agreed to receiving the relevant service) is that under Article 6 (1)(e) of the General Data Protection Regulations (GDPR) we are processing your personal data in the performance of a task carried out in the public interest.

  1. Your data protection rights

We would like to make sure you are fully aware of all your data protection rights. Every person who uses our Services or agrees to collaborate with us is entitled to the following:

  • The right to access – You have the right to request from us copies of any of your personal data that we have collected. We may however charge you a nominal fee in this regard.
  • The right to rectification. – You have the right to request that we correct any information that we hold that you believe may be inaccurate. You also have the right to request that we complete information you believe may be incomplete.
  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request to exercise any of these rights, we will endeavor to respond to such request within a reasonable time and in any case not later than one month from the date of the request. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In such a case, we will notify you and keep you updated.

We may also need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

Please contact us at privacy@nas-int.org and enter Data Protection as a reference regarding any of the rights listed above.

  1. Change in Privacy Policy

We may need to update this privacy notice periodically, so we recommend that you revisit this information from time to time. We keep our Privacy Policy under constant review. This version was last updated on 1st August 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the course of your relationship with us.

  1. Right to lodge a complaint

If you are unhappy with our use of your personal data, please let us know by contacting us at privacy@nas-int.org or +2348098981952 Alternatively, you have the right to raise any concerns with the National Information Technology Development Agency (NITDA), via their website at https://nitda.gov.ng.

  1. How to contact us

If you believe that something is not addressed in this Privacy Policy or you have any questions in relation to it, the data we hold on you, or you would like to exercise any of your data protection rights, please do not hesitate to contact us via any of the following:

Telephone: +2348098981952
Email: privacy@nas-int.org
Website: www.nas-int.org

Or visit us at our head office at:
Plot 55, Gado Nasko Road, Kubwa, Abuja, FCT, Nigeria