HOMELAND RECOVERY SERVICES LTD

1. INFORMATION WE COLLECT

Depending on your interaction with us, we may collect:

Personal and Identification Information

• Full name;
• Date of birth where necessary;
• Gender where necessary;
• Identification information;
• Residential or correspondence address;
• Telephone number;
• Email address; and
• Other information necessary to verify your identity.

Services and Case Information

Where necessary for the provision of our Services, we may collect information relating to your recovery request, claim, transaction, documentation, correspondence and other relevant circumstances.

Payment Information

We may collect information relating to payments, invoices, payment references and transaction status.

Where payment is processed through a third-party payment provider, your payment details may be processed directly by that provider in accordance with its privacy policy.

Technical Information

When you use our website, we may automatically receive information such as:

• IP address;
• Browser type;
• Device information;
• Operating system;
• Pages visited;
• Date and time of visits;
• Referring website; and
• Website usage information.

2. HOW WE COLLECT INFORMATION

We may collect information:

• Directly from you;
• Through our website or online forms;
• Through telephone, email, WhatsApp or other communication channels;
• From documents supplied by you;
• From authorised representatives;
• From relevant third parties where legally permitted; and
• Automatically through cookies and similar technologies.

3. WHY WE USE YOUR INFORMATION

We may process personal information to:

• Provide and administer our Services;
• Verify identity and information;
• Assess and manage requests;
• Communicate with clients;
• Process payments;
• Maintain records;
• Respond to complaints and enquiries;
• Prevent fraud and unlawful activity;
• Improve our website and Services;
• Meet legal and regulatory obligations;
• Protect our rights and property; and
• Carry out other legitimate business activities.

4. LAWFUL BASIS FOR PROCESSING

Depending on the circumstances, we may process personal information where:

• You have provided consent;
• Processing is necessary to perform a contract;
• Processing is necessary to comply with a legal obligation;
• Processing is necessary to protect legitimate interests;
• Processing is necessary to protect vital interests; or
• Another lawful basis recognised by applicable data-protection law applies.

5. SHARING OF PERSONAL INFORMATION

We do not sell your personal information.

Where necessary and lawful, we may disclose information to:

• Employees and authorised representatives;
• Professional advisers;
• Payment and technology service providers;
• Government agencies and regulators;
• Financial institutions;
• Legal representatives;
• Service providers assisting with your matter; or
• Other parties where you have authorised disclosure or disclosure is legally required.

We only seek to share information that is reasonably necessary for the relevant purpose.

6. INTERNATIONAL TRANSFERS

Where personal information is transferred outside Nigeria, we will take reasonable steps to ensure that the transfer and processing comply with applicable data-protection requirements.

7. DATA SECURITY

We implement reasonable technical, organisational and administrative safeguards designed to protect personal information against unauthorised access, alteration, disclosure, loss, misuse or destruction.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

8. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, to fulfil contractual or legal obligations, resolve disputes, maintain business records or otherwise comply with applicable law.

When information is no longer required, we will take reasonable steps to securely delete, anonymise or otherwise dispose of it.

9. YOUR DATA-PROTECTION RIGHTS

Subject to applicable law and relevant limitations, you may have rights to:

• Request access to your personal information;
• Request correction of inaccurate information;
• Request deletion of personal information where legally applicable;
• Object to or restrict certain processing;
• Withdraw consent where processing is based on consent;
• Request portability of certain information;
• Lodge a complaint regarding the processing of your personal information; and
• Exercise other rights available under applicable data-protection law.

The NDPC's compliance guidance recognises the importance of transparent privacy policies and appropriate notices concerning processing activities.

10. MARKETING COMMUNICATIONS

Where we send marketing or promotional communications, you may opt out by following the unsubscribe instructions provided or contacting us directly.

We will respect applicable requirements concerning direct marketing and consent.

11. CHILDREN'S INFORMATION

Our Services are not intentionally directed at children where the nature of the service requires an adult or legally authorised person.

We do not knowingly collect children's personal information except where permitted or required by applicable law and appropriate consent or authorisation has been obtained.

12. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites.

We are not responsible for the privacy practices, security or content of third-party websites. Users should review the privacy policies of those websites before providing personal information.

13. COOKIES

We use cookies and similar technologies as described in our Cookie Policy.

Where required, users will be provided with appropriate options to accept, reject or manage non-essential cookies.

14. DATA BREACHES

Where a personal-data breach occurs, we will take reasonable steps to investigate, contain and mitigate the breach and make any notifications required by applicable law.

15. PRIVACY CONTACT

For privacy-related enquiries or requests, contact:

16. POLICY UPDATES

We may update this Privacy Policy periodically.

The revised version will be published on our website with an updated "Last Updated" date.

17. ACCEPTANCE

By using our website or Services after this Privacy Policy has been made available to you, you acknowledge that you have read and understood this Policy.

Where applicable, we will obtain specific consent before processing information for purposes requiring consent.