Last updated: July 13, 2020
Data Subject is any individual about whom Flowgrids holds personal data.
Personal data is any information that allows an individual to be identified directly or indirectly (e.g., name, date of birth, title, address, telephone number and email address).
Sensitive personal data is that which, in cases of misuse, may cause unlawful or arbitrary discrimination or other serious risk to a data subject (e.g., racial or ethnic origin, nationality, political opinion, religious and philosophical beliefs, and physical or mental health conditions). Personal data and sensitive personal data are collectively referred to as “personal information.”
Collecting and Processing Personal Information
Flowgrids collects and processes personal information that is necessary for legitimate business purposes, which will be disclosed to the data subject at the time of collection. Flowgrids will use and process this information only for the purposes for which it was collected, retaining the personal information only for so long as is required for the specific purpose for which the information was collected.
Flowgrids will not collect sensitive personal data except when permitted or required to do so by law, and will do so only for legitimate business purposes. If in any other instance a need arises to collect sensitive personal data, Flowgrids will do so only with the data subject’s express consent, which can be withdrawn at any time.
Flowgrids will not sell, disclose or rent personal information for direct marketing purposes.
Transfer of Personal Information
Flowgrids may transfer the personal information outside the data subject’s home country when: (i) it has the consent of the data subject; (ii) it is necessary or appropriate as permitted by law to do so because it is relevant to Flowgrids ‘s dealings with the data subject; or (iii) it is required by law. Flowgrids will implement reasonable measures to protect the security and confidentiality of personal information and provide an adequate level of protection in each of the locations where the information is transferred.
In limited circumstances, Flowgrids may disclose personal information to a third party who is providing a service to Flowgrids. Flowgrids will only disclose personal information if the third party has provided satisfactory assurances to Flowgrids of its ability to provide appropriate and sufficient data privacy and security safeguards to protect the personal information from unauthorized disclosure, use or loss. Where Flowgrids learns that a third party is using or disclosing personal information in a manner contrary to this policy, Flowgrids will take reasonable steps to discontinue such use or disclosure.
Disclosures to third parties will be only for the purposes described in this policy, for a compatible purpose, or for a purpose authorized by the data subject.
Choice and Options
Flowgrids gives data subjects the opportunity to choose not to have his or her personal information transferred to third parties for use in a manner incompatible with the purpose for which it was originally collected. An employee may not opt out of the transfer of his or her personal information to a third party if it is being conducted for the purpose of: (1) meeting applicable legal requirements, or (2) furthering the legitimate employment relationship with Flowgrids. Prior to transferring sensitive personal data for use in a manner incompatible with the purpose for which it was originally collected, explicit (opt in) choice will be sought.
Security of Personal Information
Only authorized colleagues with a valid, work-related need may access a data subject’s personal information. In the event of a data breach, Flowgrids will issue breach notifications as may be required under applicable law.
Data Subject Rights
While personal information is maintained by Flowgrids, a data subject may access the information pertaining to him/her to the extent required by local law to review, update, and correct inaccuracies; To do so, the data subject should contact Flowgrids. Additionally, a data subject may ask Flowgrids to correct, update, supplement or delete personal information held on him/her.
Flowgrids may, in its discretion, charge a reasonable, cost-based fee for access or photocopying of this information. For security purposes, Flowgrids may require verification of identity before providing access to personal information.
If a data subject has a question about this policy or a complaint about the way Flowgrids has collected, processed, used, or disclosed his/her personal information, the data subject should contact Flowgrids.
Changes to this Policy Statement
1 Mingi XI Estate, Trans-Amadi Industrial Layout, PMB 5034 Port Harcourt, Rivers State, Nigeria.
Phone: (+234) 704 000 4567
We will use commercially reasonable efforts to promptly determine and remedy the problem.
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