Privacy Policy
1. Introduction
LivingTree Consult Limited ("we," "us," or "our") is a software development company based in Nigeria. We are committed to protecting the privacy of our users ("you" or "your"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our software products and services (collectively, our "Services"). This policy is designed to be a single, comprehensive document that covers all products produced by LivingTree Consult Limited and aligns with the Nigeria Data Protection Act (NDPA) 2023.
2. Scope of this Policy
This Privacy Policy applies to all users of our Services, regardless of their location, as long as they are processing the personal data of Nigerian citizens or are located in Nigeria. It covers all personal data collected, processed, and stored by us in connection with our Services.
3. Definitions
- Personal Data: Any information relating to an identified or identifiable natural person ('data subject').
- Data Subject: An individual 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Data Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Data Processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as 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.
4. Information We Collect
We may collect the following types of personal data: Personal Identification Information: Name, email address, phone number, etc.
- Account Information: Username, password, and other registration information.
- Usage Data: Information about how you use our Services, such as features used, time spent on the platform, and other interaction data.
- Device and Technical Information: IP address, browser type, operating system, device identifiers, and other technical information.
- Payment Information: Credit/debit card details and other payment information, which are processed by our secure third-party payment processors.
5. How We Use Your Information
We use the information we collect for various purposes, including:
- To provide, operate, and maintain our Services.
- To improve, personalize, and expand our Services.
- To understand and analyze how you use our Services.
- To develop new products, services, features, and functionality.
- To communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes.
- To process your transactions.
- To find and prevent fraud.
- For compliance purposes, including enforcing our terms of service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
6. Legal Basis for Processing Personal Data
We process your personal data based on the following legal grounds as provided by the NDPA:
- Consent: We will process your personal data if you have given us your explicit consent to do so for one or more specific purposes.
- Contract: We will process your personal data if it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
- Legal Obligation: We will process your personal data where it is necessary for compliance with a legal obligation to which we are subject.
- Vital Interests: We may process your personal data where it is necessary to protect your vital interests or those of another natural person.
- Public Interest: We may process your personal data where it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
- Legitimate Interests: We may process your personal data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your fundamental rights and freedoms.
7. Your Data Protection Rights
Under the NDPA, you have the following rights:
- The right to be informed: You have the right to be informed about the collection and use of your personal data.
- The right of access: You have the right to request copies of your personal data from us.
- The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
- The right to erasure: You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions.
- Rights in relation to automated decision making and profiling: You have the right not to be subject to a decision based solely on automated processing.
- To exercise any of these rights, please contact us using the contact information provided below.
8. Consent
Where we rely on your consent to process your personal data, we will ensure that such consent is freely given, specific, informed, and unambiguous. You have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
9. Data Security
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.
10. Data Retention
We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
11. Data Sharing and Disclosure
We may share your information with third parties in the following situations:
- With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our Service, to show advertisements to you to help support and maintain our Service, to contact you, to advertise on third party websites to you after you visited our Service or for payment processing. For Business Transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- For Business Transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- With Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.
- With your consent: We may disclose your personal information for any other purpose with your consent.
- To comply with laws: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
12. International Data Transfers
Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you are located outside Nigeria and choose to provide information to us, please note that we transfer the data, including personal data, to Nigeria and process it there. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
13. Children's Privacy
Our Services are not intended for use by children under the age of 18. We do not knowingly collect personally identifiable information from children under 18. If you become aware that a child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a child under the age of 18 without verification of parental consent, we will take steps to remove that information from our servers.
14. Data Protection Officer (DPO)
If you have any questions about this Privacy Policy or our data protection practices, please contact our Data Protection Officer at:
- Email: dpo@livingtreeconsult.com
- Address: Flat 4, Goshen Lodge, Road 3, Oluwatedo Estate, Akobo Ojurin, Ibadan. Oyo State. Nigeria.
15. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
16. Contact Us
If you have any questions about this Privacy Policy, you can contact us:
- By email: info@livingtreeconsult.com
- By visiting this page on our website: www.livingtreeconsult.com/privacy-policy
- By phone number: +234 903 909 8039
17. References
[1] Nigeria Data Protection Act, 2023. (https://ndpc.gov.ng/)
