Privacy Policy

TINCAN ISLAND CONTAINER TERMINAL LAGOS.

1. Introduction

This Privacy Policy (“Policy”) sets out the basis on which any personal data that Tincan Island Container Terminal Lagos (“TICT”, “we” or “us”) collects from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy, if you have any comments on this Privacy Policy, please email them to NG009-privacy@tict-ng.com.

2. Scope

This privacy policy applies to individuals whose personal data is processed by TICT, more specifically this policy applies to visitors of the TICT’s website, job applicants, customers, suppliers, contractors, government agencies staff, agents, all visitors of TICT’s sites.

3. Consent

You accept this Privacy Policy when you give consent upon access to our website, digital and non-digital platforms, or use our services, content, features, technologies or functions offered on our website or digital platforms or visit any of our offices for official or non-official purposes. By using our services, visiting our premises or clicking on the “accept” button or by ticking the “accept” box, you are accepting and consenting to the practices described in this Policy.

Note that you can withdraw your consent at any time, however such withdrawal of consent would not affect the lawfulness of processing information based on consent given before its withdrawal.

4. Who We Are

Our corporate website address is www.tict-ng.com. All information concerning who we are available there.

5. What We May Collect

We will collect and process the following data about you:

5.1 Information and Content, you provide

We collect the content, communication and other information you provide when you use our services. These include when you:

5.1.1 use any of our services;

5.1.2 fill forms, questionnaires or surveys;

5.1.3 sign up for an account with us;

5.1.4 contact us with an enquiry or ask us to provide you with information;

5.1.5 register in our offices on our website or leave any comments or reviews;

5.1.6 inform us of your marketing preferences; and/or communicate with us via social media websites, third party apps or similar technologies.

5.2 Information we collect about you and how we use it

Regarding each of your visits to our website, office or the use of our products, as visitors, contractors, suppliers, customers, we may collect the following information:

• CCTV recordings of you as we have placed CCTV cameras on and around our physical sites. These cameras may from time to time make recordings of you as you pass the areas that are covered by the CCTV cameras. These recordings also qualify as your personal data and therefore are managed by this privacy policy. The camera recordings are removed after 4 weeks, unless there are legal requirements for keeping the recordings for a longer period, for example in case of an investigation of an incident. In this context, we process your personal data for the following purposes:

• Access control and safeguarding security;
• Prevention of damage and criminal acts and/or acts that are prohibited by TICT’s internal policies and procedures; and
• To conduct internal investigations of suspected criminal/prohibited behaviour.
  • When you perform work or visit a TICT location for business purposes, we may collect your name, address, email address, other contact information, company name, job title, visiting purpose and hours, and biometric data for access purposes. We may ask you to provide your ID document, which consequently shall be checked visually, we will not make copies thereof. We may also ask you to provide criminal records, to the extent permitted by applicable law, including criminal records in the context of background checks. In this context, we process your personal data for the following purpose:
• To enter into a business relationship and agreement with you; 

• • To perform agreements and carry out instructions;
  • To ensure your security and integrity as well as the security and integrity of TICT;
  • To help develop and improve products and services;
  • For account management purposes;
  • To enter into and perform agreements with suppliers and other parties we work with;
  • To comply with legal obligations; and 
  • To carry out business processes and for the purpose of management reports and internal management.

• If your business or organization transfers any personal data concerning employees or other representatives to us, we also expect your employees, executive directors or other representatives to be informed about this. You can give this privacy policy to them so that they can learn how we deal with their personal data. For the purposes listed above, we may collect your name, address, email address, other contact information, information relating to or used for agreements / contracts or financial statements, payment and transaction data, conversations we have with you, and you have with us, by telephone, emails you send to us and which we receive from you, camera images that we take in our premises, information about criminal convictions, data we receive from other parties, data we require to combat fraud, to ensure your security and ours, and to prevent money laundering and the financing of terrorism.
• We process your personal data to execute the contract between you and TICT, to meet our legal obligations and to pursue our legitimate interests, which include our legitimate interest to transmit your personal data to our affiliates for administrative purposes and to ensure network and information security and safeguarding security on TICT’s sites. If you would choose not to share the requested personal data with us, we would not be able to meet some of our purposes, as described in this privacy policy.
• We may also use data collected for the following purposes:

• notify you about changes to our service;
• administer our product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• improve our product to ensure that content is presented in the most effective manner for you and for your device;
• participate in interactive features of our service, when you choose to do so;

5.3 Information we receive from other sources.

Refer to section 5.2.3. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will inform you at the point of data collection, if we intend to share your data internally and combine it with data collected on www.tict-ng.com. We will also tell you for what purpose we will share and combine your data. We may work with third parties from time to time and shall notify you when we receive information about you from them and the purposes for which we intend to use that information.

6. Use of Cookies

Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. We use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of our website. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/.

7. How We Use Your Personal Information

7.1 We use information held about you in the following ways, that is to:

7.1.2 carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

7.1.3 notify you about changes to our service;

7.1.4 ensure that content from our product is presented in the most effective manner for you and for your computer;

7.1.5 administer our product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

7.1.6 improve our product to ensure that content is presented in the most effective manner for you and for your device;

7.1.7 participate in interactive features of our service, when you choose to do so;

8. Legal Basis for processing of personal information

8.1 We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purpose for which we have collected and use your personal information.

8.2 The legal basis for processing is any of the following:

8.2.1 Consent: This will apply where you have provided your consent to the processing of your personal data for one or more specific purposes;

8.2.2 Performance of a contract with you: This will apply where processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract with you;

8.2.3 Protection of vital interests: This is where processing is required for the protection of your vital interests.

8.2.4 Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

8.2.5 Public interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public.

9. Privacy by Design

When designing and implementing a new business or technological process involving the collection or use of personal data, we will take into consideration, among other considerations, the need for structured privacy planning for this process. For example, we will consider collecting only the types of information required for the business process in the first place.

10. Security

We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected. We take steps to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We have also taken measures to comply with global Information Security Management Systems (ISMS) we therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.

11. Disclosure of your Information

11.1 We will usually not share your personal information with other third parties without your consent. Where we need to transfer your data to another country, such country must have an adequate data protection law. Where we need to send your data to a country without an adequate data protection law, we shall ensure that such transfer is subject only to the exceptions contained in Section 24 of the Nigeria Data Protection Act 2023.

11.2 You agree that we have the right to share your personal information with:

11.2.1 any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined under the Nigerian Companies and Allied Matters Act Cap C20 Laws of the Federation of Nigeria 2004.

11.2.2 authorized employees of TICT only for the purpose of resolving issues associated with the use of our services.

11.2.3 selected third parties including:

11.2.3.1 business partners, suppliers or sub-contractors for the performance of any contract we enter into with them;

11.2.3.2 analytics and search engine providers that assist us in the improvement and optimization of our corporate and products website.

11.3 We may share your data without your consent in any of the following situations:

11.3.1 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of TICT, our clients, or others;

11.3.2 where we are requested to provide information by authorized third parties or regulatory/governmental agencies investigating illegal activities;

11.3.3 in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;

11.3.4 if TICT or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets;

11.3.5 we may hold events including seminars and conferences which are sponsored by third parties or have third party speakers. Where you register for one of these events, we may share your details with those third parties.

12. Where we Store your Data

12.1 The data that we collect from you will be transferred to and stored at destinations within and outside Nigeria. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

13. Retention of Information

13.1 Your personal information will not be retained for longer than is necessary for the purposes for which it was processed unless a longer retention period is required or permitted by law.

13.2 Please contact NG009-privacy@tict-ng.com to request our Data Retention Policy for further information.

14. Your Rights

14.1 The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your personal data.

14.1.1 RIGHT TO WITHDRAW CONSENT – You have a right to consent to this Privacy Policy and to withdraw your consent at any time. Refer to section 3 on the ways in which we obtain consent.

14.1.2 RIGHT OF ACCESS – You have a right to a copy of the personal data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We will respond to your access request within one month of receiving your request. Where we are not able to provide this personal data to you within the one-month timeline provided by the Nigerian Data Protection Laws, we will communicate same to you, and may request an additional time within which we will provide the information to you. Your Personal Data shall be provided to you in a structured, commonly used, and machine-readable format. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.

14.1.3 RIGHT TO PORTABILITY – You have a right to freely transfer your data received from us to another organization.

14.1.4 RIGHT TO RECTIFY – You have the right to have the information we hold about you corrected if it is factually inaccurate. You may contact us for this purpose.

14.1.5 RIGHT TO BE FORGOTTEN – In some circumstances, you have the right to the deletion of the information that we hold about you.

14.1.6 RIGHT TO LODGE COMPLAINT – You have a right to lodge a complaint about the handling of your Personal Data with the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng/

14.1.7 RIGHT TO OBJECT – You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

14.2 NDPC’s website ( https://ndpc.gov.ng/)has a wealth of useful information in respect of your rights over your personal data.

14.3 If you wish to exercise your rights, you may contact the office of our data protection officer at NG009-privacy@tict-ng.com.

14.4 Where we do not act on your request to exercise any of your rights, we shall inform you within one month of receipt of your request, of the reasons for not taking action and on the possibility of lodging a complaint with NDPC.

15. Breach/ Privacy Violation

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, TICT shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to the Commission.

Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.

16. Changes to our Privacy Policy

16.1 Any changes we make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.

16.2 Please note that our products may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

17. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the DPO, by emailing, NG009-privacy@tict-ng.com, Attn: The DPO or visit our offices at: 1-3 Point Road, Apapa, Lagos, Nigeria.

Updated: May 2024

Version: 2.0