Risk Policy Statement - Ikeja Electric

This Privacy Notice (the “Privacy Notice” or “this Notice”) describes Ikeja Electric’s ("the Company", "We",
"Us" or "Our") commitment to protecting your personal information and respecting your privacy. This
Privacy Notice sets out the type of information we collect, what we use it for and the rights that applies
when you use our websites, mobile applications, online products and services and other tools or platforms
(collectively, our ‘’Services’’) to transact any business with us, and/or engage or otherwise interact with us.
Ikeja Electric is the ‘’data controller’’ for the purposes of the Nigeria Data Protection Regulation, 2019 (the
Regulation’’) and by visiting or using our websites, mobile applications, online products and services and
other tools or platforms (collectively, our ‘’Services’’) you accept the terms of the Notice.

Collection of Personal Information
We collect essential personal identifiable information about you which includes but is not limited to your
name and email address.
We collect your personal information from a range of sources not limited to the following:
• Information you give to us through our various touchpoints (i.e. websites, paper forms, mobile app
etc.).
• Information that we learn about you when you use our services or make specific requests or comments
on our various touchpoints.
• Information that we gather from the technology which you use to access our services (for example
location data from your mobile phone, or an IP address or telephone number) and how you use it (for
example pattern recognition).
With your permission or consent and/or as permitted by law, we may also collect information about you
from other organisations or third parties. These include fraud-prevention agencies, business directories
and credit reference agencies.

Purposes for which we use your personal data
Ikeja Electric will only use your information when you have provided your consent or when required by law
to do so. We may use the information we collect in the following ways:

Purpose/Activity Lawful basis for processing
To manage our relationship with you or your
business.

• Consent from you

To provide and maintain our Services, including
monitoring the usage of our Service.

• Performance of a contractual agreement
• Fulfilment of a legal obligation

To manage your account with us and your
registration as a user of the Service. The personal
data you provide can give you access to different
functionalities of the Service that are available to
you as a registered user.

• Consent from you
• Performance of a contractual agreement

For the performance of a contract: the
development, compliance and undertaking of the
purchase contract for the products, items or

• Performance of a contractual agreement

services you have purchased or of any other
contract with us through the Service
To contact You: To contact You by email,
telephone calls, SMS, or other forms of
communication, such as a mobile-applications,
push notifications regarding updates or
informative communications related to our service
and/or products, such as sending you information
when you sign up or change tariffs, service
announcements and administrative messages.

• Consent from you
• Performance of a contractual agreement

To send you electronic bills each month for energy
consumed by you.

• Performance of a contractual agreement
•
To provide you with news, special offers and
general information about other services and
events that we offer that are similar to those that
you have already received or enquired about
unless you have opted not to receive such
information.

• Consent from you
• Performance of a contractual agreement

To manage your requests and complaints. • Performance of a contractual agreement
To detect, investigate, and prevent security
incidents and other malicious, deceptive,
fraudulent, or illegal activity and protect the rights
and property of Ikeja Electric and its stakeholders.

• Compliance with a legal obligation
• Fulfilment of a legitimate interest

To comply with our legal and regulatory
obligations by sharing with regulators when
necessary.

• Compliance with a legal obligation
• Fulfilment of a legitimate interest
• Processing in the public interest

To fulfil any other purpose described to you at the
time the information was collected.

• Consent from you

Information Sharing
We do not share or sell personal information about you with third parties, Mailing list or direct marketing
companies other than entities who perform business functions integral to our business administration. The
exception to this is sharing your information based on the following requirements:
• Business Transactions
If Ikeja Electric is involved in a merger, acquisition or asset sale, your personal data may be
transferred. We will provide notice before your personal data is transferred and becomes subject
to a different privacy policy.
• Law Enforcement
Under certain circumstances, the company may be required to disclose your personal data if
required to do so by law or in response to valid requests by public authorities (e.g., a court or a
government agency).
• International Transfer of Data
Ikeja Electric may transfer your data to foreign countries in compliance with the provisions of the
Nigeria Data Protection Regulation and other existing laws on data protection in Nigeria.
• Other requirements
The Company may disclose your personal data in good faith that such action is necessary to
attain the following:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability
• Where you have provided consent that your personal data be disclosed in a specific manner
• Fulfilment of court orders or legal process
• Prevention of a violation of any part of our Privacy Notice
• Third parties conducting business on our behalf. These parties process such information for
specific and limited purposes, in compliance with the privacy notice and any other
appropriate confidentiality and security measures
• Sensitive personal data (also known as special categories of personal data) make up information
we collect from you. In particular, we may process, biometric data, for services that require it. We
process such sensitive personal data when you have provided your consent or otherwise required
by applicable law. This information will be collected and processed only for the particular purposes
and activities for which the information is provided.
Information Retention
Ikeja Electric Plc will retain your personal data only for as long as is necessary for the purposes set out in
this Privacy Notice. We will retain and use your personal data to the extent necessary to comply with our
legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve
disputes, and enforce our legal agreements and policies. We will retain and use your personal data to the
extent necessary to comply with our contractual obligations with you and once our contract with you has
come to an end (e.g., following retirement or closure of your account), we will only retain your personal
data for a period that is, depending on the type of personal data, and the purposes for which we hold that
information.
The Company will also retain usage data for internal analysis purposes. Usage data is generally retained
for a shorter period, except when this data is used to strengthen the security or to improve the functionality
of our service, or We are legally obligated to retain this data for longer time periods.

Protection of Personal Information
We will take all reasonable precautions to ensure that all the personal information that you have submitted,
including via our websites and associated touchpoints remains confidential as required by the Regulation,
we have strict security procedures regarding the storage and disclosure of personal information.
Your Rights
Subject to applicable laws, you have the following rights:
• To request a copy of the personal data processed in relation to you
• To request that we correct your personal data
• To request us to delete your personal data, for example, if we no longer have a valid reason to process
it
• To object to how we process your personal data
• To restrict how your personal data is processed in certain cases, such as when the accuracy of your
personal data is contested
• To request a copy of the personal data you have given to us in a machine-readable format

Fees
You will not have to pay a fee to exercise any of your 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.
You may exercise any of these rights by submitting a request at any of our designated contact addresses
or sending a request via email to DPO@ikejaelectric.com.
Cookies
Cookies may be used once you visit or register as a user on our websites and touchpoints. “Cookies” are
small text files placed on your hard drive that assist Us in providing a more customised website experience.
If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases,
a visitor may refuse a cookie and still fully navigate Our Website.
To properly manage Our websites, we may log general statistical information on our operational systems
and identify categories of visitors by items such as domain name, IP address and browser types. This
information is processed and anonymously by Us to enable Us show activity and trends of Our website
usage to Our webmasters and third-party content providers and to help Us ensure that Our website
presents the best web experience for visitors and is an effective information resource. The log file
information does not contain personally identifiable information.
Changes to this Privacy Notice
This Notice which governs your use of Our websites and associated touchpoints may be changed from
time to time without notice to take into account new laws and technology and changes to Our operations.
By using the websites or Our touchpoints, you are deemed to have accepted the terms and conditions
contained in this Notice. Our use of your personal Information is subject to the terms and conditions of our
Notice in force at the time when we use the information in question.
Governing Law
This Privacy Notice is made pursuant to the Nigeria Data Protection Regulation (2019) or any other relevant
Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this
Notice is inconsistent with a law, regulation or convention, such provision shall be subject to the overriding
law, regulation or convention.
Contact us
Ikeja Electric Plc strives to resolve your privacy complaints and concerns as quickly as possible. If you
have a concern, complaint or questions regarding this Privacy Notice, you may contact us through the
following means:
Head Office: 178 Obafemi Awolowo Way, Alausa, Ikeja, Lagos.
Phone: 01-7000-250, 0908-794-0825
E-Mail: DPO@ikejaelectric.com
Website: www.ikejaelectric.com

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