Privacy Policy

Last Updated Date: 1st September 2025

 

SystemSpecs Holdings Limited (herein after referred to as “SHL” “we” “our” or “us”) strongly believes in providing total privacy and protection to our customer’s personal data. The information our customers give us are gotten with full consent, are processed under legal basis and are not sold, rented, loaned or otherwise disclosed to third parties. Our policies are created to provide protection of the confidentiality and security of our customer’s personal information. We only require the minimum amount of personal information needed to fulfil our service to our customers. Our privacy standards are in compliance with the National Data Protection Act 2023 (NDPA) and the General Data Protection Regulation (GDPR).

  1. OVERVIEW

This Privacy Policy describes the process involved in the acquisition, processing, porting, storage and disposing of your personal data in connection with our websites, portals, mobiles applications, tools and services. This Privacy Policy also governs your rights, and we take pride in securing and maintaining the privacy of the data we collect from you.

  1. CONSENT

This policy is enforced after you consent to it when you access functions offered from our websites, related sites, portals, applications and services

  1. YOUR RIGHTS AS A DATA SUBJECT

Your rights as a data subject under data protection laws in Nigeria include:

  • Right to confirm whether the data controller or a data processor operating on its behalf, is storing or otherwise processing personal data relating to you;

  • Right to request a copy of your personal data in a commonly used electronic format, except to the extent that providing such data would impose unreasonable costs on the data controller, in which case you may be required by the controller to bear some or all of the costs;

  • Right to have correction or, if correction is not feasible or suitable, deletion of your personal data that is inaccurate, out of date, incomplete, or misleading;

  • Right to have your personal data erased without undue delay;

  • Right to withdraw, at any time, consent to the processing of personal data under the Nigeria Data Protection Act 2023;

  • Right to object to the processing of your personal data;

  • Right to object to any decisions based on the automated processing of your personal data, including profiling;

  • Right to data portability;

  • Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise any of the above stated rights, kindly put your request in writing and send it to us through your usual registered channel (e.g. by registered email) and specify the right you wish to exercise.

For more information or to exercise your data protection rights, please contact our Data Protection Officer at [email protected].

  1. GENERAL PRINCIPLES FOR PROCESSING PERSONAL DATA

In processing your personal data, we adhere to the principles of data processing; our obligation in terms of the principle is to ensure that personal data is;

  • Processed in a fair, lawful and transparent manner;

  • Collected for specific and legitimate purpose, and not to be further processed in a manner that is incompatible with these purposes;

  • Adequate, relevant, and limited to the minimum necessary for the purposes for which the personal data was collected or further processed;

  • Accurate, complete and where necessary, kept up to date, having regards to the purposes for which the personal data is collected or is further processed; and

  • Processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing, access, loss, destruction, damage or any form of data breach.

We are also committed to ensuring accountability and upholding data confidentiality, integrity and availability.

  1. HOW WE USE YOUR PERSONAL INFORMATION

Our purpose for collecting your personal information is to give you an efficient, enjoyable, and secure customer experience. No Personal Data about you will be collected without your consent. Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide the services envisaged or requested.

On the lawful basis of your consent or our legal obligation, we may use your information to:

  • Provide our services to you including responding to your inquiries. SHL solely holds the information and engages in no contact-sharing program with other organizations.

  • Notify you of new products, services and/or offerings, newsletters and similar messages (“promotional messages”); or any enhancements/amendments to existing products services and/or offerings that we think may be of interest to you. If you do not want to receive such promotional materials from us, you may opt out at any time by sending an email to [email protected].

  • Contact you at any time through your provided telephone number, email address or other contact details;

  • Carry out other activities permitted by law including the fulfillment of our contract with you, compliance with legal and/or regulatory requirements, and to protect your vital interests or those of any other natural person;

  • Manage risk, or detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;

  • Detect, prevent, or remediate violations of policies or applicable user agreements;

  • If we intend to process your personal information for any purpose other than those listed in this policy, we shall provide you with relevant information on the further processing and seek your consent before the processing commences.

  • In case of surveys and polls, any feedback received from you shall only be used for the purpose of improving our services.

  • We use your information in profiling and automated decision-making for fine-tuning our product and service offerings to better meet your needs; we use your data for feature enhancement training of our Artificial Intelligence model, targeted in-app marketing communications and similar improvements.

  1. DATA TRANSFER AND SHARING

    1. We may be required to disclose your personal data in accordance with a legal obligation when needed by government authorities, regulatory bodies, law enforcement agencies or law courts on matters involving public interest, national security or law enforcement requirements.

  1. We may also share your information with a third party when it is necessary to provide you with our service, and the information will only be provided for such limited purposes. Third parties could include:

  • Subsidiaries within the SHL group

  • Business partners

  • Professional advisors

  • Application Program Interface (API) Users

  • Security-cleared data processors/subcontractors, who are assisting us or the SHL group with IT or other services.

c. SHL partners with various technology vendors from time to time. This may result in a transfer of personal data to a third-party organization or country. To ensure an equal level of security for such transfer in accordance with the Nigeria Data Protection Act 2023, we enter into data processing agreements (DPAs) with all third-parties who process personal data on our behalf, ensuring that relevant safeguards are in place.

d. We will do our reasonable best to ensure that personal data provided by you to us and shared with a third-party, is done in accordance with the provisions of the Nigeria Data Protection Act 2023. We will also reasonably ensure that such third-parties with whom we share your personal data will ensure the security of the same as provided by this Policy and in accordance with the Nigeria Data Protection Act 2023.

e. When we transfer your personal data to business partners, you should be aware that they might have stored personal data concerning you collected through other means, e.g., if you have been in contact with them in another context.

f. We may further share your personal information with our affiliate entities, particularly members of the SystemSpecs Group (i.e., SystemSpecs Holdings Limited and other entities in which SystemSpecs Holdings Limited holds considerable influence and control), to enable us to provide you with information and services which we believe may be beneficial or may be of interest to you and/or members within your organisation. The affiliate entities may use the personal information for marketing and non-marketing activities. You may opt out at any time by sending an email to [email protected]

g. We recognise the privacy of minors, and we do not knowingly collect personal information belonging to minors.

  1. HOW WE PROTECT YOUR PERSONAL INFORMATION

    • SHL and its subsidiaries use a security-cleared data processor to store files and data on secure cloud-based servers. The data processors are certified under the applicable frameworks and thereby guarantee and operate an appropriate standard of data protection and data security.

    • We store and process your personal information on our computers in Nigeria, Africa and elsewhere in the world where our facilities are located. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. You have a right (upon your request) to be informed of the appropriate safeguards for data protection in the foreign country.

    • We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

    • Furthermore, in the event of an actual or suspected breach of your personal information, we will use best effort to remedy the breach within one (1) month of discovery or notification of such or such reasonable time as may become necessary in each given circumstance.

  1. DATA RETENTION

We shall not retain your personal data longer than is necessary for the purpose for which such personal data is processed. In determining the length of retention of your personal data, consideration is had to the nature and sensitivity of your data, the purpose for which we are processing such data and any applicable regulations.

All your personal data (which are collected through electronic storage on database may be retained for a period not more than 10 years from the end date of our business relationship with you and afterwards completely deleted and erased.

  1. CHILDREN’S PRIVACY

We are committed to protecting the privacy of children who participate in the SystemSpecs Children’s Essay Competition (CEDC). Our services are not intended for children under the age of 13, and we do not knowingly collect personal information from children under this age without verifiable parental consent.

 

  • Information Collection and Use

  • Parental Consent: Before collecting any personal information from children under the age of 13, we require verifiable parental consent. Parents or guardians must provide consent for their child’s participation in the CEDC.

  • Types of Information Collected: We may collect personal information such as the child’s name, age, school, and contact details, as well as the content of their essay submission.

  • Purpose of Collection: The information collected is used solely for the purpose of administering the essay competition, including evaluating submissions, notifying winners, and awarding prizes.

  • Data Security: We implement appropriate security measures to protect the personal information of children from unauthorized access, disclosure, alteration, or destruction.

  • Parental Rights: Parents or guardians have the right to review their child’s personal information, request its deletion, and withdraw consent at any time. To exercise these rights, please contact us at [email protected].

 

  1. LIMITATION OF LIABILITY

    • SHL will not be liable for loss of income, profits, business, opportunity, goodwill, contracts or any indirect, special, incidental or consequential damages arising out of or in connection with the Service, any computation on SHL, or this Agreement.

    • We will not be liable for any loss or damage arising as a result of unauthorised access to the Service if (a) you intentionally or negligently fail to take reasonable precautions to protect your security, access codes, login details or any device used to access the Service, (b) you failed to promptly notify us that the Service was being accessed in an unauthorised way after becoming aware of it, or (c) you acted fraudulently.

    • Our liability to you or any third party in any circumstance of proven liability by us, shall not exceed the fees paid to us in respect of the specific transaction that gave rise to the claim or liability, unless otherwise specified by a court of competent jurisdiction.

    • Notwithstanding any provision in clauses 8.1, 8.2 and 8.3, limitation of liability shall not apply if we breach any provision of the Nigeria Data Protection Act 2023 (“NDPA”)

  1. LINKS TO OTHER WEBSITES

Certain transaction processing channels may require links to other websites. Please note that SHL is not responsible for, and has no control over third party websites. We do not monitor or review the content of other party’s websites which are linked from this website. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and SHL should not be regarded as the publisher of such opinions or materials. You agree that we shall not incur any liability arising from your interpretation of any information on any third-party website linked to SHL. Please be aware that we are not responsible for the privacy practices, or content of any third-party sites and we encourage our users to read the privacy statements of these third-party sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to it. SHL will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of your personal information.

 

  1. CHANGES TO THIS POLICY

We may update this Policy from time to time without any prior notice to you or consent. Thus, you are advised to consult this Platform periodically for any changes. We will notify you of any changes by posting the revised Policy on this Platform. Please note that changes shall be effective immediately after they are updated on this Platform.

 

  1. QUERIES AND QUESTIONS

Any complaints, questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Data Protection Officer through [email protected]. and where your complaints are not sufficiently addressed, you may lodge a complaint with the Nigeria Data Protection Commission.

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