Private Policy

Privacy Policy
Introduction
As part of our operations, bestconet collects and processes certain types of information (such as names, telephone numbers, addresses, etc.) of individuals that make them easily identifiable. These individuals include current, past, and prospective employees, merchants, suppliers/vendors, customers of merchants, and other individuals whom Bestconet communicates or deals with, jointly and/or severally (“Data Subjects”).
Maintaining the Data Subject’s trust and confidence requires that Data Subjects do not suffer negative consequences/effects as a result of providing Bestconet with their Personal Data. To this end, Bestconet is firmly committed to complying with applicable data protection laws, regulations, rules, and principles to ensure the security of Personal Data handled by the Company. This Data Privacy & Protection Policy (“Policy”) describes the minimum standards that must be strictly adhered to regarding the collection, use, and disclosure of Personal Data and indicates that Bestconet is dedicated to processing the Personal Data it receives or processes with absolute confidentiality and security.
This Policy applies to all forms of systems, operations, and processes within the Bestconet environment that involve the collection, storage, use, transmission, and disposal of Personal Data. 
This Policy applies to all employees of Bestconet, as well as to any external business partners (such as merchants, suppliers, contractors, vendors, and other service providers) who receive, send, collect, access, or process Personal Data in any way on behalf of Bestconet, including processing wholly or partly by automated means. This Policy also applies to third-party Data Processors who process Personal Data received from Bestconet. 
General Principles for Processing of Personal Data
Bestconet is committed to maintaining regarding the processing of Personal Data. 
To demonstrate this commitment as well as our aim of creating a positive privacy culture within Bestconet, Bestconet adheres to the following basic principles relating to the processing of Personal Data:
Lawfulness, Fairness, and Transparency
Personal Data must be processed lawfully, fairly, and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of Bestconet must be in accordance with the specific, legitimate, and lawful purpose consented to by the Data Subject, save where the processing is otherwise allowed by law or within other legal grounds recognized in the
Data Accuracy
Personal Data must be accurate and kept up to date. In this regard, Bestconet: 

1. shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to the Data Subject;
2. make efforts to keep Personal Data updated were reasonable and applicable; and
3. make timely efforts to correct or erase Personal Data when inaccuracies are discovered.

Purpose Limitation
Bestconet collects Personal Data only for the purposes identified in the appropriate Bestconet Privacy Notice provided to the Data Subject and for which consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except a new Consent is obtained. 
The purposes for which Bestconet will use your personal data include:

1. For the provision of services to you. For example, when you purchase any of our products or services, we will use your personal data to process your order.
2. For customer care and billing. When you use our products or services, we will use your personal information to bill you and to respond to inquiries and concerns that you may have about our products and services.
3. Customer service messages. We will use your personal data to keep you updated with the latest information or changes about our products and services.
4. For marketing purposes. In order to serve you better, we will use your personal data to market our products and services to you. 
5. Fraud prevention and security. We will process your personal and traffic data in order to protect you against and detect fraud, to protect and detect misuse or damage to our platform.
6. Managing our platform and understanding platform usage. We do this to manage the volume of jobs and to understand how you use our platform, products, and services.

Data Minimization

1. Bestconet limits Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed.
2. Bestconet will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized data must be used.

Integrity and Confidentiality

1. Bestconet shall establish adequate controls in order to protect the integrity and confidentiality of Personal Data, both in digital and physical format, and to prevent personal data from being accidentally or deliberately compromised.
2. Personal data of Data Subjects must be protected from unauthorized viewing or access and from unauthorized changes to ensure that it is reliable and correct. 
3. Any personal data processing undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties is unauthorized.
4. Employees may have access to Personal Data only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Data for their own private or commercial purposes or to disclose them to unauthorized persons, or make them available in any other way. 
5. The Human Resources Department must inform employees at the start of the employment relationship about the obligation to maintain personal data privacy. This obligation shall remain in force even after employment has ended. 

Personal Data Retention

1. All personal information shall be retained, stored, and destroyed by Bestconet in line with legislative and regulatory guidelines. For all Personal Data and records obtained, used, and stored within the Company, Bestconet shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity, and requirement to retain. 
2. To the extent permitted by applicable laws and without prejudice to Bestconet’s Document Retention Policy, the length of storage of Personal Data shall, amongst other things, be determined by: 
1. the contract terms agreed between Bestconet and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
2. whether the transaction or relationship has statutory implication or a required retention period; or
3. whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require Bestconet to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
4. whether Bestconet has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
3. Bestconet would forthwith delete Personal Data in Bestconet’s possession where such Personal Data is no longer required by Bestconet or in line with Bestconet’s Retention Policy, provided no law or regulation is in force that requires Bestconet to retain such Personal Data. 

Accountability
Any individual or employee who breaches this policy may be subject to internal disciplinary action (up to and including termination of their employment), and may also face civil or criminal liability if their action violates the law.
Data Privacy Notice

1. Bestconet considers Personal Data as confidential and as such must be adequately protected from unauthorized use and/or disclosure. Bestconet will ensure that the Data Subjects are provided with adequate information regarding the use of their Personal Data as well as acquire their respective Consent, where necessary.
2. Bestconet shall display a simple and conspicuous notice (Privacy Notice) on any medium through which Personal Data is being collected or processed. The following information must be considered for inclusion in the Privacy Notice, as appropriate in distinct circumstances in order to ensure fair and transparent processing:
1. Description of collectible Personal Data;
2. Purposes for which Personal Data is collected, used, and disclosed;
3. What constitutes Data Subject’s Consent;
4. Purpose for the collection of Personal Data;
5. The technical methods used to collect and store the information;
6. Available remedies in the event of a violation of the Policy and the timeframe for remedy; and
7. Adequate information in order to initiate the process of exercising their privacy rights, such as access to, rectification, and deletion of Personal Data.

Legal Grounds For Processing Of Personal Data 
The personal data we collect from our customers and how we collect it depends on the services that our customers subscribe to, how they use our services and how they interact or interface with us. This also applies to persons who are not customers of Bestconet but have interacted with Bestconet. We may also obtain your personal data from a third party with permission to share it with us.

1. where you give us consent to the processing of your Personal Data for one or more specific purposes. You are at liberty to withdraw the consent and Bestconet will cease to process your Personal Data where there is no other basis to do so.
2. Where the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which Bestconet is subject;
4. processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
5. 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 Bestconet.

We collect your personal data when you do any of the following:

1. Buy or use any of our products and services;
2. Use our network or other Bestconet products and services;
3. Register for a specific product or service;
4. Fill in your information on our KYC registration form, self-service applications, social media platforms;
5. Visit or browse our website;
6. Have given permission to other companies to share information about you;
7. Where your information is publically available;
8. Are the customers of a business we acquire or;
9. Take part in a competition, prize draw, or survey.

Personal data we have about our customers, where applicable include name, phone number, address, sex, photograph, ID card number, fingerprint, educational information, job experiences, signature, etc.
Consent 
Where the processing of Personal Data is based on consent, Bestconet shall obtain the requisite consent of Data Subjects at the time of collection of Personal Data. In this regard, Bestconet will ensure:

1. that the specific purpose of collection is made known to the Data Subject and the Consent is requested in clear and plain language;
2. that the Consent is freely given by the Data Subject and obtained without fraud, coercion, or undue influence;
3. that the Consent is sufficiently distinct from other matters to which the Data Subject has agreed;
4. that the Consent is explicitly provided in an affirmative manner;
5. that Consent is obtained for each purpose of Personal Data collection and processing; and
6. that it is clearly communicated to and understood by Data Subjects that they can update, manage or withdraw their consent at any time.

Valid Consent 

1. Consent in respect of Sensitive Personal Data must be explicit. A tick of the box would not suffice.

Consent of Minors
In the unlikely event that we deal with minors, the consent of minors will always be protected and obtained from minors’ representatives in accordance with applicable regulatory requirements. 

Data Subject Rights

1. All individuals who are the subject of Personal Data held by Bestconet are entitled to the following rights:
1. Right to request for and access their Personal Data collected and stored. Where data is held electronically in a structured form, such as in a database, the Data Subject has a right to receive that data in a common electronic format;
2. Right to information on their personal data collected and stored;
3. Right to objection or request for restriction;
4. Right to object to automated decision making;
5. Right to request rectification and modification of their data which Bestconet keeps; 
6. Right to request the movement of data from Bestconet to a Third Party; this is the right to the portability of data; and 
7. Right to object to, and to request that Bestconet restricts the processing of their information except as required by law or Bestconet’s statutory obligations. 
8. To opt out of marketing and unsolicited messages:

COOKIES POLICY
At Bestconet We believe in being clear and open about how we collect and use data related to you. This Cookie Policy applies to any Bestconet product or service that links to this policy or incorporates it by reference.
This Cookies Policy explains how we use cookies and the choices you have.
By using our website (by clicking, navigating, or scrolling), you are consenting to our use of cookies in accordance with this Policy. If you do not agree to our use of cookies, you can prevent the installation of cookies through the settings of your browser or not use our website at all. However, if you disable the use of cookies, this might cause some parts of this website not to function properly for you and it may impact your user experience on this site. 
What are Cookies?
Cookies are messages or small files that are placed on your web browser when you visit an internet site. Cookies are useful and do a lot of different things, including allowing a website to recognize a user’s device, improving the online experience, etc.
How and Why do we Use Cookies?
We use cookies when you access our websites and our online products and services to make the site work better and to help us understand how you use our site. 
Cookies enable us to offer tailored products and to understand the information we receive about you, including information about your use of other websites and apps, whether or not you have an account with us.
Cookies help us provide, protect and improve our products and services, by personalizing, tailoring, and measuring the services and products we provide for a satisfactory and safe experience. We also use them to help authentication of users, assess the performance and functionality of our online products and services, and do analytical research.
We use two types of cookies: persistent cookies and session cookies. A persistent cookie lasts beyond the current session and is used for many purposes, such as recognizing you as an existing user, so it’s easier to return to Bestconet and interact with our Services without signing in again. Since a persistent cookie stays in your browser, it will be read by Bestconet when you return to one of our sites or visit a third-party site that uses our Services. Session cookies last only as long as the session (usually the current visit to a website or a browser session).

What is this Privacy Notice for?
Bestconet Nigeria (“Bestconet”, “the Company”, or “We”) values your Personal Data and we are committed to protecting your privacy whenever you interact with us. Please read this Privacy Notice (Notice) to understand our policies, processes, and procedures regarding the processing of your personal data. 
By this Notice, We explain to you how your Personal Data is collected, used, managed, and transferred by Bestconet and also explain how you can update your Personal Data with us and exercise your rights in respect of the Personal Data provided to us. 
The Personal Data that we collect 
We collect Personal Data that you give to us, for example, where you create an account with us, request further information about our product, fill out a form, apply for a job through our website or subscribe to newsletters on our website.
We may also automatically collect some technical information when you visit our website such as your IP address, and information about your visit, such as the pages that you viewed. This information helps us understand customer interests and helps us improve our website. When you visit our site, the pages that you look at, and a short text file called a cookie, are downloaded to your computer. By visiting and using our website, you agree to our use of cookies in line with Bestconet’s policies. For more details about cookies, please read our Cookies Policy available through this
What Purpose do we use your Personal Data?
We may process your Personal Data to communicate with you (including sending marketing or promotional materials to you), provide you with further information about our products and how we can serve you better, respond to your purchase orders or requests; process your application for employment with Bestconet or to fulfill our contractual obligations with you. We may also process your Personal Data to comply with provisions of applicable laws.
What Constitutes your Consent?
Where the processing of Personal Data is based on consent, We shall obtain the requisite consent at the time of collection of the Personal Data. In this regard, you consent to the processing of your Personal Data when you access our platforms or use our services, content, features, technologies, or functions offered on our website or other digital platforms. You can withdraw your consent at any time but such withdrawal will not affect the lawfulness of processing based on consent given before its withdrawal.
Security of your Personal Data
We take the security of your Personal Data seriously and We make every effort to keep your Personal Data secure. We have put in place technological and organizational procedures, including requiring our staff and any third parties who carry out any work on our behalf to comply with appropriate security standards in order to protect your Personal Data. 
Retention of your Personal Data
We take appropriate measures to ensure that your Personal Data is only Processed for the minimum period necessary in line with the purposes set out in this Notice or as required by applicable laws until a time it is no longer required or has no use. Once your Personal Data is no longer required, We destroy it in a safe and secure manner. 
Your Rights 
Bestconet collects Personal Data only for the purposes identified in this Policy and such information cannot be reused for another purpose that is incompatible with the original purpose.
You can exercise the following rights with respect to your Personal Data with Bestconet:

1. request for and access your Personal Data collected and stored by Bestconet; 
2. withdraw consent at any time. For example, you can withdraw your consent to the receipt of our marketing or promotional materials or unsubscribe to our newsletters; 
3. object to automated decision making;
4. request rectification and modification of Personal Data kept by Bestconet; 
5. request for deletion of your Personal Data;
6. be informed of and entitled to provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data was collected;
7. request that Bestconet restricts processing of your Personal Data; and 
8. request for information regarding any specific processing of your personal data.