Privacy Policy & Data Protection
Scope of this Privacy Policy
This privacy policy applies to all visitors to our website. It applies to IESL GLOBAL use of all data collected by us or provided by visitors to the site in relation to their use of the website.
It does not extend to any websites that can be accessed by you from this website including, but not limited to, any links we may provide to social media websites. By clicking on such links, you may be providing your personal data to third parties over whom we have no control and for whose data practices we accept no responsibility. We encourage you to review the privacy policies of those sites before sharing any personal information.
Definitions and interpretation
In this privacy policy, the following definitions are used:
“Data” means IESL GLOBAL all personal information relating to you, whether provided by you or collected automatically, including but not limited to information submitted via the Website, collected through cookies and tracking technologies, or otherwise obtained in connection with your use of the Website, in each case to the extent constituting personal data under applicable Data Protection Laws.’
“Data Protection Laws” means all applicable laws and regulations relating to the processing of personal data, including but not limited to the Nigeria Data Protection Act 2023, any regulations, directives, or guidelines issued by the Nigeria Data Protection Commission, and, where relevant, foreign data protection laws such as the UK General Data Protection Regulation (UK GDPR).
“Website” means the website that you are currently using, www.ieslglobal.com, and any sub-domains of this site unless expressly excluded by their individual terms and conditions.
“Personal Data” means any information relating to an identified or identifiable natural person (a “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. For the avoidance of doubt, this includes information collected automatically through your use of the Website, such as IP addresses and cookie identifiers, where such information is capable of identifying you.
“Processing” means any operation or set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, including but not limited to: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. References to “process” and “processed” shall be construed accordingly.
“Data Processor” means any natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of IESL GLOBAL as Data Controller, pursuant to a written data processing agreement and in accordance with the instructions of IESL GLOBAL; a Data Processor does not include an employee of IESL GLOBAL acting in the course of their employment, but includes third-party service providers such as cloud hosting providers, email service providers, analytics platforms, and other technology vendors engaged by IESL GLOBAL from time to time;
“Consent” means a freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of their Personal Data for one or more specified purposes. Consent shall not be valid where it is bundled with other terms and conditions, obtained through pre-ticked boxes, silence, or inactivity, or where there is any element of compulsion, significant imbalance, or inability to refuse without detriment. A Data Subject may withdraw Consent at any time, and such withdrawal shall not affect the lawfulness of processing carried out on the basis of Consent prior to its withdrawal;
“Sensitive Personal Data” means Personal Data revealing or concerning a Data Subject’s race or ethnic origin; political opinions or affiliation; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where processed for the purpose of uniquely identifying a natural person); physical or mental health condition; sex life or sexual orientation; financial information beyond what is required for a specific transaction; or criminal records, allegations, or proceedings, each as defined and regulated under the NDPA 2023 (s.30). IESL GLOBAL shall only process Sensitive Personal Data where an explicit legal basis under the NDPA 2023 applies, and shall implement enhanced safeguards in respect of any such processing;
Data Collected
We may collect the following data, which includes personal data, from you:
- Contact details: Name, e-mail, address
Purpose: To respond to your enquiries and service requests; to administer and maintain our relationship with you; to provide information about our services; and, where you have given your Consent, to send you marketing communications about IESL GLOBAL
- Identifying data: IP address, login information, browser type and version, time zone, browser plug-in types, geolocation information, operating system and version.
Purpose: To ensure the security and integrity of the Website; to detect, prevent and investigate fraud, unauthorised access and other malicious activity; to perform analytics and diagnose technical faults; and to comply with applicable legal and regulatory obligations.
- Usage data: Your URL clickstreams, pages viewed, page response times, download errors, time spent on pages, actions taken on pages, frequency of visits.
Purpose: To understand how visitors use the Website; to improve the user experience, content relevance and website performance; to measure the effectiveness of features and navigation; and to conduct internal research and analytics. Lawful basis: legitimate interests of IESL GLOBAL in improving its Website and services, provided such interests are not overridden by your rights and freedoms.
When and How We Collect Data
We collect data from the first moment you interact with our website. Data can either be collected automatically or be provided by you.
Data We Collect Automatically
- When you visit our website: This information helps us to make improvements to website content and navigation, and includes your IP address, the date, times and frequency with which you access the website and the way you use and interact with its content.
- When we contact you proactively by email or telephone – Where IESL GLOBAL initiates contact with you by email or telephone, we will only do so where we hold your Personal Data on a lawful basis. In such cases: (a) your Personal Data will have been obtained either directly from you at a prior point of interaction, or from a lawful third-party source (such as a publicly available directory, a referral partner, or a recruitment or scholarship platform) in accordance with the terms on which that source shared it; (b) we will identify ourselves clearly at the outset of any such contact and inform you of the purpose for which we are contacting you; (c) we will inform you of your right to object to further contact or processing of your Personal Data at any time, and provide you with a simple means to exercise that right (such as an unsubscribe link in any email or a verbal opt-out during any call); and (d) where your data was obtained from a third-party source, we will, at the time of first contact or as soon as reasonably practicable thereafter and in any event within thirty (30) days, inform you of: (i) the identity of that third-party source; (ii) the categories of Personal Data obtained; and (iii) the lawful basis on which we are processing it, in accordance with our obligations under the Nigeria Data Protection Act 2023 (s.26) and the Nigeria Data Protection Regulation 2019 (Art. 2.4). Lawful basis for proactive contact: Consent (NDPA 2023, s.25(2)(a)); legitimate interests of IESL GLOBAL in communicating with prospective clients, scholarship applicants, or professional contacts (NDPA 2023, s.25(2)(e)), subject to a balancing test confirming those interests are not overridden by your rights and freedoms; or performance of a contract or pre-contractual steps at your request (NDPA 2023, s.25(2)(b)), as applicable.
- We will collect your data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the website, please see the section below “Cookies”.
Data You Provide
- When you use the “Contact Us” form.
- When you subscribe to our mailing lists.
Our Responsibilities
Under applicable Data Protection Laws, IESL GLOBAL serves as the ‘data controller’ of personal data. This means we determine the purposes for the way your data is processed.
Your Responsibilities
- Read this privacy policy carefully.
- If you provide us with personal information about others, please ensure you have authorization to share it.
- If others provide us with your information, we will only use such information for the specific purpose for which it was provided.
- By submitting any information, you confirm that you have the right to authorize us to process it on your behalf, in accordance with this privacy policy.
How and Why We Use Your Data
Data protection law requires us to identify a specific, documented lawful basis for every activity in which we process your Personal Data. We may only process your Personal Data where at least one of the following lawful bases applies. The table below sets out each processing activity we carry out, the lawful basis we rely upon, and, where we rely on our legitimate interests, the specific interest pursued and our assessment that it does not override your rights and freedoms, in accordance with the Nigeria Data Protection Act 2023 (NDPA 2023, s.25(2)) and the Nigeria Data Protection Regulation 2019 (NDPR, Art. 2.2).
- Processing activity: Website improvement, testing of features, landing page optimisation, data analysis and research, including engaging third-party processors to assist with the foregoing.
Lawful basis: Legitimate interests (NDPA 2023, s.25(2)(e); NDPR, Art. 2.2(e)).
Specific legitimate interest: IESL GLOBAL has a legitimate interest in understanding how visitors interact with its Website in order to improve its content, services and user experience, and to measure the performance of its digital presence. This processing is necessary for that purpose and could not reasonably be achieved by less intrusive means. Balancing assessment: the data processed is limited to aggregated or pseudonymised behavioural and technical information; it is not used to make decisions that produce legal or similarly significant effects on individual data subjects; the processing is unlikely to be unexpected by visitors to a commercial website; and data subjects retain the right to object at any time. On that basis, IESL GLOBAL has assessed that its legitimate interests are not overridden by the rights and freedoms of data subjects. A full Legitimate Interests Assessment (LIA) is maintained internally and is available on request. - Processing activity: Monitoring and enhancing the security of the Website; detecting, investigating and preventing fraud, unauthorised access, cyberattacks and other malicious or illegal activity.
Lawful basis: Legitimate interests (NDPA 2023, s.25(2)(e)); compliance with a legal obligation (NDPA 2023, s.25(2)(c)) where applicable.
Specific legitimate interest: IESL GLOBAL has a legitimate interest in protecting the integrity, availability and confidentiality of its systems and in safeguarding the Personal Data of all data subjects whose information it holds. This processing is necessary for that purpose. Balancing assessment: security monitoring is a reasonable expectation of any data subject whose data is held by a digital service; the processing is targeted, proportionate and does not involve unnecessary access to content; and data subjects’ fundamental rights are served, not undermined, by effective security measures. A full LIA is maintained internally and is available on request. - Processing activity: Sending you marketing and promotional communications about IESL GLOBAL’s services, news, scholarship programmes and events by email or other electronic means.
Lawful basis: Consent (NDPA 2023, s.25(2)(a); NDPR, Art. 2.3). We will only send you marketing communications where you have given your prior, freely given, specific, informed and unambiguous Consent by means of a clear affirmative action (such as ticking an opt-in box). Your Consent is separate from and independent of your acceptance of this Privacy Policy. You may withdraw your Consent at any time by using the unsubscribe link in any marketing email, by contacting us at Corporate Email, or by any other means we notify you of. Withdrawal of Consent will not affect the lawfulness of any processing carried out prior to withdrawal.
Note: marketing Consent is not a condition of accessing our Website or services. Refusing or withdrawing Consent will not result in any detriment to you. - Processing activity: Maintaining internal records of enquiries, service interactions and communications for administrative, operational and audit purposes.
Lawful basis: Legitimate interests (NDPA 2023, s.25(2)(e)); performance of a contract or pre-contractual steps (NDPA 2023, s.25(2)(b)) where applicable.
Specific legitimate interest: IESL GLOBAL has a legitimate interest in maintaining accurate records of its interactions with data subjects in order to manage its operations effectively, respond to queries, resolve disputes, and demonstrate regulatory compliance. Balancing assessment: data subjects would reasonably expect an organisation to retain records of communications it has with them; the data is accessed only by authorised personnel on a need-to-know basis; it is retained only for as long as necessary in accordance with the Data Retention section of this Policy; and it is not used for any purpose inconsistent with the original interaction. A full LIA is maintained internally and is available on request. - Processing activity: Processing Personal Data as necessary to comply with applicable legal, regulatory or judicial obligations, including obligations arising under the NDPA 2023, the NDPR, tax legislation, anti-money laundering laws, and any court order, regulatory direction or lawful request from a competent authority.
Lawful basis: Compliance with a legal obligation (NDPA 2023, s.25(2)(c)).
Where we process your Personal Data in order to comply with a legal obligation, we are not required to obtain your Consent and you are not able to object to such processing. We will, however, only process the minimum Personal Data necessary to fulfil the relevant legal obligation and will inform you of any such processing to the extent permitted by law.
Your Privacy Choices and Rights
- Your Choices:
- You can choose to use our website without providing personal data.
- You can manage cookies through your browser settings by turning them off, blocking or deleting them, while you continue to use our website.
- You have full control over whether we send you marketing communications. We will never send you marketing communications unless you have given us your prior, freely given, separate and specific opt-in Consent by means of a clear affirmative action. You may withdraw that Consent at any time, free of charge and without detriment, by: (i) clicking the unsubscribe link in any marketing email; (ii) sending an email to info@IESLplc.com. with the subject line “Unsubscribe”; or (iii) contacting us by post at our registered address. Withdrawal will be actioned within five (5) business days. For the full details of how we obtain and manage your marketing Consent, please see the section below: Marketing Communications — How We Obtain and Manage Your Consent.
Marketing Communications — How We Obtain and Manage Your Consent
- Scope of this section: This section applies to all marketing communications sent by IESL GLOBAL, including but not limited to promotional emails, newsletters, service announcements, scholarship and event information, and any other electronic message sent for a commercial or promotional purpose (collectively, “Marketing Communications”). It does not apply to service or transactional messages sent in connection with a specific enquiry, application or contractual relationship, which are sent on a separate lawful basis and are not subject to the consent requirements set out below.
2.Consent requirement: We will only send you Marketing Communications where you have given us your prior, freely given, specific, informed and unambiguous Consent, by means of a clear affirmative action, in accordance with NDPA 2023 (s.25(2)(a)) and NDPR (Art. 2.3). Your Consent to receive Marketing Communications: (a) is entirely separate from and independent of your acceptance of this Privacy Policy or any terms and conditions governing your use of the Website, acceptance of either shall not constitute or imply Consent to marketing; (b) will be sought by means of an unticked opt-in checkbox presented at the relevant point of data collection (for example, on our “Contact Us” form or mailing list subscription page), accompanied by a clear and plain-language description of what you are consenting to; (c) will never be a condition of accessing our Website, receiving our services, or submitting an application or enquiry, refusing or withholding Consent carries no detriment; and (d) will be recorded with a time-stamp and the specific consent language you agreed to, which record will be retained for as long as we rely on your Consent and for a reasonable period thereafter as evidence of compliance.
3.What your Consent covers: Where you consent to receive Marketing Communications, your Consent covers the following and nothing more: (a) Data used: your name and email address, and where provided, your telephone number and areas of interest or sector preferences, as submitted by you via the Website; (b) Marketing purpose: to send you periodic email communications about IESL GLOBAL’s services, scholarship and employment opportunities, industry news, events and other information we consider may be of interest to you; (c) Who processes it: IESL GLOBAL as Data Controller, and any email service provider engaged by us as Data Processor under a written data processing agreement subject to equivalent data protection obligations. We do not sell, rent or otherwise transfer your Personal Data to any third party for their own marketing purposes; and (d) Channel: electronic mail only, unless you separately consent to contact by telephone or other channel at the time of data collection.
4.Withdrawal of Consent: You may withdraw your Consent to receive Marketing Communications at any time, without giving any reason and without detriment to any other aspect of your relationship with IESL GLOBAL, by any of the following means: (a) clicking the clearly labelled unsubscribe link included in the footer of every Marketing Communication we send you; (b) sending an email to Corporate Email. with the subject line “Unsubscribe” or “Withdraw Marketing Consent”; or (c) writing to us at our registered address. We will action your withdrawal request within five (5) business days of receipt and will send you a confirmation of unsubscription. Withdrawal of Consent does not affect the lawfulness of any Marketing Communications sent before the date of withdrawal. After your withdrawal has been actioned, we will retain a suppression record of your email address to ensure we do not contact you again for marketing purposes unless and until you provide fresh Consent.
5.Re-consent and preference updates: We will periodically invite you to review and refresh your marketing preferences in order to ensure our records remain accurate and that our communications remain relevant to you. Where we intend to use your Personal Data for a new or materially different marketing purpose not covered by your original Consent, we will seek fresh Consent before doing so. We will not infer continued Consent from your failure to respond to a re-consent request.
6.Internal record keeping; separate purpose: For the avoidance of doubt, the maintenance of internal administrative records (including records of enquiries, service interactions, applications, and communications) is carried out as a distinct and separate processing activity on the lawful basis of legitimate interests, as described in the “How and Why We Use Your Data” section above. Such record keeping is not contingent on your marketing Consent and will continue irrespective of whether you provide, refuse or withdraw marketing Consent. Conversely, granting marketing Consent does not authorise any use of your Personal Data beyond the Marketing Communications purpose described in paragraph 3 above.
7.Compliance notice: All Marketing Communications sent by IESL GLOBAL will comply with the requirements of the Nigeria Data Protection Act 2023 (s.25(2)(a)), the Nigeria Data Protection Regulation 2019 (Art. 2.3), and the Cybercrimes (Prohibition, Prevention, etc.) Act 2015 (s.22), which prohibits the sending of unsolicited commercial electronic messages. Every Marketing Communication will: (a) clearly identify IESL GLOBAL as the sender; (b) contain a clear and prominent unsubscribe mechanism in the footer; (c) include our registered address; and (d) not contain false, deceptive or misleading subject lines, sender names or content. If you believe you have received a Marketing Communication from us in error, or without having given valid Consent, please notify us immediately at Corporate Email. and we will investigate and respond within five (5) business days.
- Your Rights:
You can exercise any of the rights listed below by contacting our Data Privacy Officer at Corporate Email. or by writing to us at our registered address. We will acknowledge your request within five (5) business days and respond substantively within one (1) month of receipt. Where your request is complex or we receive a high volume of requests, we may extend that period by up to two (2) further months, in which case we will notify you of the extension and the reasons for it. There is no charge for exercising your rights unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or decline to respond.
You have the following rights in relation to your data;
- Right to access – You have the right to request access to the information we hold about you at any time. The information will be provided to you within a month of your request, unless doing so will adversely affect the rights and freedoms of others (for instance another person’s confidentiality or intellectual property rights). We will inform you of our inability to meet your request and provide reasons for same.
- Right to correct – You have the right to request that we modify, update, or correct any incomplete or inaccurate personal data about you. It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.
- Right to give or withdraw consent – Your consent is required in processing your data. We will request your consent to process your data as required by law. You have the right to give consent, refuse to give consent, and/or where consent has been previously given, withdraw such consent at any time.
- Right to restrict/ object to our use of your data – You have the right to limit or object to our use of your data, including where we use it for our legitimate interests. e.g., for profiling or making automated decisions about you. We may use your data to determine whether to provide you with information that might be relevant to you, such as tailoring emails based on your behavior on our website.
- Right to transfer your data to another service – We will provide you with a copy of your data in Comma Separated Value (CSV) File or JavaScript Object Notation format, allowing you to share such data with another service. When requested and technically feasible, we will transfer your data to the other service on your behalf. However, data will not be transferred where it involves disclosing data about another individual.
- Right to Erasure — You may request that we erase your Personal Data where: (a) it is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw Consent and there is no other lawful basis for continued processing; (c) you object to processing carried out on the basis of legitimate interests and there are no overriding legitimate grounds; or (d) your Personal Data has been unlawfully processed. We will respond to your request within one (1) month. We may decline to erase your data where retention is required by law, is necessary for the establishment, exercise or defence of legal claims, or where another lawful basis for retention applies, in which case we will inform you of our reasons in writing.
- Right to Data Portability — Where we process your Personal Data by automated means on the basis of your Consent (e.g., marketing preferences) or for the performance of a contract, you may request a copy of that data in a structured, commonly-used and machine-readable format (CSV or JSON). Where technically feasible and on your request, we will transmit that data directly to another data controller. This right does not apply to processing carried out on the basis of our legitimate interests or a legal obligation, and does not apply where its exercise would adversely affect the rights and freedoms of others.
- Right to complain – You have the right to lodge a complaint regarding our use of your data. We request that you please notify us first, to enable us to address your concerns.
Data Retention We retain your Personal Data only for as long as is necessary for the purpose for which it was collected and processed, in accordance with NDPA 2023 (s.25(1)(e)) and NDPR (Art. 2.1(1)(d)). The following retention schedule applies:
(a) Active Personal Data (data relating to an ongoing relationship, enquiry, or application): retained for the duration of that relationship or engagement, and for a period of twelve (12) months thereafter, to allow for the resolution of any follow-up queries, disputes or complaints arising from the interaction.
(b) Website Visitor Data (IP addresses, usage data, and cookie-generated identifiers where not linked to an active relationship): retained in active systems for a maximum of six (6) months from the date of your last visit. After that period, such data will be either permanently deleted or anonymised such that it can no longer be attributed to you. “Archived” for the purposes of this Policy means transferred to a separate, access-restricted storage environment with no ongoing operational use, pending scheduled deletion; it does not mean continued active use of your Personal Data.
(c) Marketing Data (name, email address and preferences collected on the basis of Consent): retained until you withdraw your Consent or request erasure, whichever is earlier, subject to our obligation to retain a suppression record thereafter to prevent accidental re-contact.
(d) Legal Hold Data (Personal Data relevant to actual, threatened or reasonably anticipated litigation, regulatory investigation, or audit): retained for the duration of the relevant proceedings or investigation and for such further period as may be required by applicable law or professional obligation, notwithstanding any shorter period set out above.
(e) Legally Mandated Retention: certain categories of Personal Data may be subject to minimum retention periods prescribed by Nigerian law (including tax, employment, anti-money laundering and corporate governance legislation). Where a legal minimum applies, data will be retained for that minimum period and deleted promptly thereafter, unless a Legal Hold applies.
In all cases, Personal Data that has reached the end of its applicable retention period will be securely and permanently deleted or anonymised. We conduct periodic reviews of our data holdings to identify and action scheduled deletions. If you wish to request early erasure of your Personal Data (subject to any legal retention obligation or Legal Hold), please refer to your Right to Erasure in the section below.
Data Storage
Your Personal Data is processed primarily at the offices of IESL GLOBAL in Nigeria. We also engage third-party service providers (including cloud hosting, email delivery and analytics providers) who may process your Personal Data on our behalf at facilities located outside Nigeria. Where any such international transfer takes place, we will ensure it is carried out in compliance with NDPA 2023 (ss.43–45) and NDPR (Art. 2.11), and in accordance with one or more of the following safeguards: (a) Adequacy: transfer to a country or territory in respect of which the Nigeria Data Protection Commission (NDPC) has issued an adequacy determination; (b) Standard Contractual Clauses: transfer governed by data transfer agreements incorporating clauses approved by the NDPC or a recognised equivalent authority, which impose obligations on the recipient equivalent to those applicable in Nigeria; (c) Binding Corporate Rules: where the recipient is a member of a corporate group that has adopted binding corporate rules approved by the NDPC; or (d) Explicit Consent: where you have given your explicit, informed consent to the specific transfer after being informed of the possible risks. We do not transfer your Personal Data to any country or territory that does not provide an adequate level of protection without first implementing one of the safeguards described above. You may request further information about the specific safeguards in place for any international transfer of your Personal Data by contacting us at Corporate Email.
Data Security
We take the security of your Personal Data seriously and have implemented appropriate physical, electronic, technical, organisational and managerial measures to protect it against unauthorised access, accidental loss, destruction, disclosure or alteration, in accordance with NDPA 2023 (ss.39–40) and NDPR (Art. 2.6). These measures include, without limitation: (a) Encryption: industry-standard Transport Layer Security (TLS/SSL) encryption for Personal Data transmitted to and from the Website; (b) Access Controls: role-based access restrictions limiting access to Personal Data to authorised personnel only, on a strict need-to-know basis, with access rights reviewed periodically; (c) Infrastructure Security: storage of Personal Data on access-controlled, password-protected servers with current security patching and monitoring; (d) Organisational Measures: internal data protection policies, staff awareness and training on data handling obligations, and confidentiality obligations for all personnel who handle Personal Data; and (e) Security Assessments: periodic review of our information security arrangements to identify and address vulnerabilities.
Personal Data Breach Notification: In the event of a Personal Data breach that is likely to result in a risk to your rights and freedoms, IESL GLOBAL will notify the NDPC without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with NDPA 2023 (s.40). Where the breach is likely to result in a high risk to you personally, we will also notify you directly without undue delay, describing the nature of the breach, the likely consequences, the measures taken or proposed to address it, and the contact details of our Data Privacy Officer. If you have reason to believe that your Personal Data has been compromised, please contact us immediately at Corporate Email
Cookies
IESL GLOBAL We, and authorised third parties, use cookies and similar tracking technologies on the Website. Under NDPA 2023 (s.25(2)(a)) and NDPR (Art. 2.3), non-essential cookies may only be set with your prior, informed, specific and freely given Consent. We obtain that Consent through a cookie consent banner presented on your first visit to the Website, before any non-essential cookies are set.
Cookies are organised into the following categories:
(a) Strictly Necessary Cookies: essential for the Website to function and cannot be switched off. They are set in response to your actions (such as logging in or filling in forms). No consent is required for these cookies.
(b) Functional Cookies: enable enhanced functionality and personalisation (such as remembering your preferences and language settings). These are set only with your Consent.
(c) Analytics and Performance Cookies: allow us and third-party providers (such as Google Analytics) to count visits and measure traffic sources so we can improve the Website’s performance. All data collected is aggregated and anonymous. These are set only with your Consent.
(d) Marketing and Targeting Cookies: may be set by us or by third-party advertising partners to build a profile of your interests and display relevant content. These are set only with your explicit Consent.
A detailed cookie table setting out each cookie by name, category, purpose, duration, and first- or third-party status is available via the cookie preference centre accessible from the footer of the Website. You may grant, refuse or withdraw Consent to each non-essential cookie category at any time by accessing the cookie preference centre. Withdrawal of cookie Consent will take effect immediately for new cookies; previously set cookies will be deleted from your browser as promptly as technically feasible. Please note that refusing or withdrawing Consent for certain functional or analytics cookies may affect the functionality of the Website. We review and update our cookie list at least annually.
How To Manage Cookies
You can enable, disable, block, and delete cookies by activating the cookie settings on your internet browser. Blocking or deleting cookies may affect the functionality of the website. Please note that we have no control over the use of cookies by third parties and their usage.
Who We Share Data With
We may share your data with the following groups of people for the following reasons:
- Third-Party Data Processors: We engage the following categories of third-party processors who process your Personal Data on our behalf and under our documented instructions, pursuant to written Data Processing Agreements (DPAs) that impose data protection obligations equivalent to those applicable under the NDPA 2023 (s.37) and NDPR (Art. 2.7): (i) Cloud Hosting and Infrastructure Providers — who host and maintain our Website and backend systems; (ii) Email Service Providers — who manage delivery of our transactional and marketing email communications; (iii) Analytics Providers — who assist us in understanding Website traffic and user behaviour (e.g., Google Analytics or equivalent); and (iv) Customer Communication Platforms — who support our customer relationship management and enquiry handling. Where any such processors are located outside Nigeria, the international transfer safeguards described in the Data Storage section of this Policy apply. We do not permit our processors to use your Personal Data for their own purposes; they may only process it for the specific purposes and in accordance with the instructions set out in their DPA with us;
- Any of our Group companies or Affiliates in furtherance of the aims of the business;
- Our employees, agents, and/or professional advisors ensure effective delivery of service, obtain professional advice, and comply with relevant legislation.
Your data is shared only when necessary and in accordance with our safeguards and best practices
Changes to this privacy policy
IESL GLOBAL We may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or regulatory guidance. We distinguish between material changes (which include, without limitation, changes to the purposes for which we process your data, the lawful basis relied upon, the categories of data collected, new sharing arrangements with third parties, or changes to your rights) and non-material changes (such as typographical corrections, clarifications that do not alter the substance of our obligations, and updates to contact details).
Material Changes: We will notify you of any material change to this Policy by email to the address we hold for you and/or by a prominent notice on the Website, not less than 30 days before the change takes effect. Where a material change involves a new or different processing purpose that requires your Consent, we will seek fresh, specific Consent before applying that change to your Personal Data. Continued use of the Website after the effective date of a material change does not constitute Consent to changed processing purposes. If you do not agree with a material change, you may exercise your Right to Erasure, your right to restrict processing, or your right to object, as described in the Your Privacy Choices and Rights section of this Policy.
Non-Material Changes: We will post non-material changes on the Website with an updated “Last Revised” date. Continued use of the Website following such changes constitutes acceptance of the updated Policy. Implied acceptance applies only to non-material changes and cannot constitute Consent to any new or different processing of your Personal Data, in accordance with NDPA 2023 (s.65) and NDPR (Art. 2.3), under which Consent must be freely given, specific, informed and unambiguous.
Data Protection Officer / Data Privacy Contact
IESL GLOBAL has designated a Data Privacy Officer / Data Privacy Coordinator (“DPO”) to oversee compliance with applicable data protection legislation, including the NDPA 2023 (s.32) and NDPR (Art. 4.1(4)), and to serve as the primary point of contact for data subjects and regulatory authorities on all data protection matters. If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, wish to raise a concern about our data processing practices, or wish to request a copy of any Legitimate Interests Assessment or data transfer safeguard documentation, please contact the DPO as follows:
Name / Title: …………………………………
Email: …………………………………………….
Postal Address: ……………………………….
We will acknowledge receipt of your communication within five (5) business days and will endeavour to respond substantively within one (1) month. Where we are required to notify the Nigeria Data Protection Commission (NDPC) of a matter, or where you are entitled to escalate a complaint to the NDPC, we will provide you with the relevant NDPC contact details on request. You also have the right to lodge a complaint directly with the NDPC at any time at: www.ndpc.gov.ng.
Automated Decision-Making and Profiling
NDPA 2023 (s.34) grants data subjects the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning them. In the interest of transparency, IESL GLOBAL discloses its position as follows:
(a) Solely Automated Decisions with Legal or Significant Effects: IESL GLOBAL does not currently make decisions about you that are based solely on automated processing and that produce legal effects or similarly significantly affect you (such as automated application rejections, credit decisions, or access denials without human review). All decisions of material consequence to you involve meaningful human review.
(b) Profiling for Personalisation: We may use automated processing of your usage and behavioural data (such as pages visited and content interacted with) to build a general profile of your interests for the purpose of personalising the content you see on the Website and tailoring email communications to your interests, where you have given your Consent to marketing. This profiling does not produce legal or similarly significant effects and does not involve sensitive Personal Data.
(c) Your Rights in Relation to Automated Processing: You have the right to: (i) obtain meaningful information about the logic involved in any automated processing; (ii) object to profiling for marketing personalisation purposes at any time by withdrawing your marketing Consent or contacting us at info@IESLplc.com; and (iii) request human review of any decision that affects you significantly, if and when such automated decisions are introduced.
Note to IESL GLOBAL: If automated decision-making is introduced in future, a Data Protection Impact Assessment (DPIA) must be conducted before implementation (NDPA 2023, s.35; NDPR Art. 2.12), and this section must be updated to describe the logic, significance and consequences of such processing.]
TERMS & CONDITIONS
Welcome to www.ieslglobal.com. This website is owned and operated by International Energy Services Limited IESL GLOBAL By accessing this website (“Website”) or by otherwise accessing any content found on the Website, you agree to be bound by the following terms and conditions (the “Terms”).
IESL GLOBAL respects your privacy. Any information or data you provide will be processed in accordance with IESL GLOBAL’s Privacy & Cookies Policy.
Intellectual Property
This Website contains materials including text, photographs, designs, images and sounds (collectively referred to as “IESL Content”, which are copyright of IESL GLOBAL or have been licensed to IESL GLOBAL by the owners of such copyrights (hereinafter “licensors”). This Website also contains trademarks, including the IESL name and logo. All trademarks contained in this Website belong to IESL GLOBAL and its licensors.
You may
- access any part of the Website;
- print off one copy of any or all the pages of the Website for your personal reference.
Except as expressly permitted above:
You may not
- copy (whether by printing off onto paper, storing on a disk, downloading or in any other way), distribute (including distributing copies), broadcast, alter or tamper with in any way or otherwise use all or a part of the IESL Content except as set out under the “You may” section
- for any reason, use, reproduce, allow anyone to use or reproduce or remove any copyrights, trademarks or other intellectual property notices contained in the original material, from any material copied or printed from the Website; without express permission from IESL GLOBAL. If you require a hypertext or other link to this Website, please contact the Webmaster. Such requests are purely discretionary and IESL GLOBAL is under no obligation to grant or refuse same
Changes to Terms and Conditions
- IESL GLOBAL IESL GLOBAL reserves the right to amend these Terms from time to time. A “material change” means any amendment that: (a) materially alters your rights or obligations; (b) introduces new restrictions on use of the Website; (c) changes the basis on which IESL GLOBAL may exclude or limit liability; or (d) amends the governing law or jurisdiction clause.
Notice of material changes: We will give you not less than 14 days’ written notice of any material change, by email to the address we hold for you and/or by a prominent notice on the Website, before the change takes effect. If you do not agree with a material change, you may cease using the Website before the effective date; your continued use of the Website on or after the effective date of a material change constitutes your acceptance of the revised Terms.
Non-material changes (such as corrections to typographical errors, clarifications, and updates to contact details) will take effect immediately upon posting with an updated “Last Revised” date. Continued use of the Website constitutes acceptance of non-material changes. This clause has been amended to comply with FCCPA 2018 (s.130) and, where applicable, the Consumer Rights Act 2015 (Schedule 2, para. 1), both of which require that unilateral variation clauses be accompanied by notice and an exit right to be enforceable.
Changes to Operation of Website
- IESL GLOBAL reserves the right, in its discretion and at any time to change or modify the format of the Website and add or remove part of the IESL Content available therein, suspend operation of the Website for any reason whatsoever and deny access to or restrict the use and accessibility of the Website at any time, without notice.
Complaints Procedure
Please contact IESL webmaster for any questions, complaints or enquiries you have concerning the Website.
Governing Law & Jurisdiction
These Terms are governed by and construed in accordance with English law. The courts of England shall have non-exclusive jurisdiction to settle any dispute which may arise out of, under or in connection with these Terms or the Website, whether in contract, tort or otherwise.
Notwithstanding the foregoing choice of governing law, nothing in these Terms shall operate to exclude, restrict or limit: (a) the rights of any user who is a resident of Nigeria (or any other jurisdiction) under the mandatory consumer protection, data protection or other laws of that jurisdiction that cannot be excluded or limited by contract, including without limitation the Nigeria Data Protection Act 2023, the Nigeria Data Protection Regulation 2019, the Federal Competition and Consumer Protection Act 2018, and the Consumer Protection Council Act (Cap C25, Laws of the Federation of Nigeria 2004), each of which shall apply to the extent required by law notwithstanding this choice of English law; and (b) the jurisdiction and enforcement powers of the Nigeria Data Protection Commission (NDPC) or any other competent Nigerian regulatory authority in respect of data protection matters.
Liability
IESL GLOBALIESL GLOBAL Warranties: The IESL Content is provided for general informational purposes only. To the maximum extent permitted by applicable law, IESL GLOBAL makes no warranty, express or implied, as to the accuracy, completeness, suitability, reliability or availability of the IESL Content for any particular purpose.
Exclusion of Indirect Loss: Subject to the paragraphs below, IESL GLOBAL, its affiliates, subsidiaries and licensors shall not be liable for any: (a) loss of profits, revenue, business opportunity, anticipated savings or goodwill; (b) indirect, special, incidental or consequential loss or damage; or (c) loss of or corruption to data, in each case whether arising in contract, tort (including negligence), breach of statutory duty or otherwise, even if advised of the possibility of such loss.
Liability Cap: Subject to the paragraph below, the total aggregate liability of IESL GLOBAL to you in connection with your use of the Website, whether arising in contract, tort, breach of statutory duty or otherwise, shall not exceed the greater of: (a) the total amount paid by you to IESL GLOBAL in the twelve (12) months immediately preceding the event giving rise to the claim; or (b) ₦50,000 (Fifty Thousand Naira)
DISCLAIMER
Important Notice: Please Read Carefully
This notice applies to all individuals accessing this site:
The information contained on this website is for general information purposes only. IESL GLOBAL makes no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability, or availability of the information contained herein.
In no event shall we be liable for any loss or damage, including without limitation, indirect or consequential loss or damage of whatever nature arising from loss of data or profits arising out of or in connection with, your use of this website. Access to this website is restricted. The information contained herein may be unlawful in certain jurisdictions. Individuals wishing to access information on this website must ensure they are not subject to any local regulations which prohibit or restrict their access.
The contents of this website are not intended for publication or distribution to individuals in jurisdictions where publication and distribution of such information is restricted by law. IESL GLOBAL shall neither be responsible nor liable for the website being temporarily unavailable or accessible due to reasons beyond our control.
Carve-Out — Privacy Policy and Terms & Conditions: The general information disclaimer set out above applies exclusively to informational and editorial content published on the Website (the “IESL Content”) and does not apply to, limit, qualify or diminish any obligations, representations or commitments made by IESL GLOBAL in: (a) this Privacy & Cookies Policy, which is required by applicable data protection law to be accurate, complete and up to date, and in respect of which IESL GLOBAL accepts full legal responsibility under the NDPA 2023 and NDPR; or (b) these Terms & Conditions. Any attempt by IESL GLOBAL to rely on the general information disclaimer as a defence to a complaint, claim or regulatory investigation arising from a breach of this Privacy Policy or applicable data protection legislation shall be without effect, in accordance with NDPA 2023 (s.25(1)(a)) and NDPR (Art. 2.1(1)(b)).
Disclaimer Notice: Impersonation and Fraudulent Acts
Our attention has been drawn to the fraudulent activities of individuals impersonating IESL GLOBAL, demanding monetary compensation from unsuspecting members of the public in exchange for scholarship awards or job placements. IESL GLOBAL and its subsidiaries will not, under any circumstances, demand for or accept payments or compensation of any kind from scholarship applicants or job seekers, and shall not be liable for business transactions conducted with individuals attempting to defraud the public. For the avoidance of doubt, it is our practice at IESL GLOBALto award scholarships and offer jobs solely on merit. Impersonators of IESL GLOBAL and its subsidiaries shall be reported to the relevant authorities and prosecuted if found guilty.
