Swiss Pharma Nigeria Limited (“Swipha”) takes its responsibilities with regard to the management of personal data very seriously and we do not take lightly the trust you have reposed in us, in providing us with your personal information. This Policy describes how Swipha processes your personal data, but it may not address all possible data processing scenarios. This Privacy Policy is a guide to help you understand:

(1) The Information We Collect
(2) How We Collect and Use Your Data
(3) Consent and Access Rights
(4) Personal Data Protection Principles
(5) User Responsibility
(6) Data Security
(7) Links to Third Party Websites
(8) Third Party Access
(9) Violation of Privacy
(10) Data Retention
(11) How to Contact Us


1. The Information We Collect
We collect the following information: name, data of birth, residential and contact address, telephone number, email address, marital status, nationality, gender, tax identity number, bank details, posts on social networking information on family members, medical information, educational background, genetic data, biometric data, identity number, location, photograph, IP address, MAC address, IMEI number, IMSI number and other information relevant.

2. How We Collect and Use Your Data
2.1 Swipha collects the above-mentioned information using forms, email and physical requests, cookies, JWT, web tokens.

2.2 When you send email or other communications to Swipha, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. When you access Swipha’s services, our servers automatically record information that your browser sends whenever you visit a website.

2.3 We use the above-mentioned information for due diligence, transaction advisory, legal advisory, litigation, regulatory compliance, marketing, business development, listing on legal directories, publicity, human resources management, recruitment, events planning and hosting, in-house security, research, analysis and vendor registration.

3. Consent and Access Rights
3.1 We require your consent for the processing of your data and shall obtain your consent to individual matters, where any document deals with other matters.
3.2 We can process your personal data in the absence of consent where:

a. processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

b. processing is necessary for compliance with a legal obligation to which you are subject;

c. processing is necessary in order to protect your vital interests or that of another natural person; and

d. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in us.

3.3 If we intend to use your data for a purpose which is different from the purpose for which your data was obtained, we will seek your consent prior to the use of your data for that other purpose.
3.4 In the event of any arrangement whereby Swipha sells or transfers all, or a portion of, its business or assets (including in the event of a reorganization, dissolution or liquidation) to third parties, you hereby consent that your personal data held with Swipha can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by Swipha prior to such arrangement. Swipha shall at all times ensure that you are notified when your personal data is intended to be transferred to third parties in the circumstances outlined in this clause.
3.5 No Consent shall be sought, given or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.
3.6 You may withdraw your consent at any time and may request access to your personal information in our possession. We can, however, deny you access to the information where we determine that your request is unreasonable.
3.7 You reserve the right to request the modification or amendment of your personal data in our possession.
3.8 In all cases of access or modification/amendment of personal information, we shall request for an adequate proof of identification to enable us to confirm that you are the owner of the data sought to be accessed or modified/amended.

4. Personal Data Protection Principles
When we process your personal data, we are guided by the following principles, which require personal data to be:
a) processed lawfully, fairly, in a transparent manner and with respect for the dignity of the human person.

b) collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

d) accurate and where necessary kept up to date.

e) removed or not kept in a form which permits identification of data subject for longer than is necessary for the purposes for which the personal data is processed.

f) processed in a manner that ensures its security, using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage.

5. User Responsibility

You are required to familiarise yourself with this policy and to ensure that the information you provide to us is complete, accurate and up to date.

6. Data Security
6.1 Swipha implements and maintains appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to their personal data.

6.2 Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting the confidentiality (i.e. that only those who need to know and are authorised to use personal data have access to it), integrity and availability of the personal data. we regularly evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal data.
6.3 You should, however, be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot guarantee absolute security. Swipha, therefore, accepts no liability for any damage or loss, however caused, in connection with transmission over the Internet or electronic storage.

7. Links to third party sites
The Swipha website when it is set up may contain links to other websites owned and operated by third parties. These links are provided for your information and convenience only and are not an endorsement by Swipha of the content of such linked websites or third parties. The information that we collect from you will become available to these websites if you click the link to the websites. These linked websites are neither under our control nor our responsibility. Swipha, therefore, makes no warranties or representations, express or implied about the safety of such linked websites, the third parties they are owned and operated by and the suitability or quality of information contained on them. This Privacy Policy does not apply to these websites, thus, if you decide to access these linked third-party websites and/or make use of the information contained on them, you do so entirely at your own risk. Swipha accepts no liability for any damage or loss, however caused, in connection with accessing, the use of or reliance on any information, material, products or services contained on or accessed through any such linked website. We advise that you contact those websites directly for information on their privacy policy, security, data collection and distribution policies.

8. Third Party Access
8.1 Swipha only shares personal information with other companies or individuals in the following limited circumstances:

a) We have your consent.

b) We provide such information to other professional advisers or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

c) We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Swipha, its users or the public as required or permitted by law.

8.2 Swipha is at all times, responsible for the security and appropriate use of that data as long as it remains with Swipha.

9. Violation of Privacy
9.1 We have put in place procedures to deal with any suspected personal data breach and will notify you of any personal data breach and let you know the steps we have taken to remedy the breach and the security measures we have applied to render your personal data unintelligible.
9.2 All suspected breach of personal data will be remedied with 1 (one) month from the date of the report of the breach.
9.3 If you know or suspect that a personal data breach has occurred, you should immediately contact the DPO at [.].

9.4 Swipha will not be responsible for any personal data breach which occurs as a result of:

a) an event which is beyond the control of Swipha;

b) an act or threats of terrorism;

c) an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises Swipha’s data protection measures;

d) war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo;

e) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises Swipha’s data protection measures;

f) the transfer of your personal data to a third party on your instructions; and

g) the use of your personal data by a third party designated by you.

10. Data Retention
We shall retain your personal data based on the following criteria:
i. 10 years after our last contractual agreement with you;
ii. immediately upon your request or your authorised representative where no statutory provision provides otherwise;
iii. upon presentation of evidence of death by a deceased’s relative (where applicable).

11. How to Contact Us

For any enquiries you have in relation to this Privacy Policy, please feel free to contact our Data Protection Officer at [.].




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