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Guinness Nigeria Policies

We respect your right to privacy, and we take the protection of your privacy and ensuring the security of your Personal Data very seriously.

We are committed to the fair and transparent processing of your personal data, hence, this Privacy Notice describes how we process your personal data, explain your rights in relation to the personal data we process, and states our commitment when processing your personal data in a compliant, ethical and secure manner.

This Privacy Notice constitutes our commitment to your privacy on our administrative records, websites, social media platforms, and premises.

The words “we, “us” or “our” in this privacy notice, refers to Guinness Nigeria PLC (“Guinness Nigeria”).

Whereas:

We provide this Privacy Notice to achieve our responsibilities under the General Applicable and Implementation Directive (GAID) which requires greater accountability and transparency from organizations regarding your personal information, and which gives you greater control over how we use it.
This Privacy Notice, therefore, clarifies how and when we collect personal data from and about you, why we do so, and how we treat this information and serves as a guide as to how personal data is managed by Guinness Nigeria. It also elucidates your rights concerning the collection of personal information and how you can exercise those rights.

Who does this notice apply to?

any person(s) who visits our websites, social media platforms, events and premises;
any person(s) who contracts with us for the provision of products and services, or who purchases a product from us (“customers”), including potential customers to the extent Guinness Nigeria processes your personal data;
resellers such a Guinness Nigeria distributor and agents as well as partners (“resellers”) including potential resellers to the extent Guinness Nigeria processes your personal data; and
any other persons (save for employees and job applicants) who share personal data with Guinness Nigeria including beneficiaries, Guinness Nigeria guests, etc (“other Data Subjects”).

Your Privacy Rights

This Privacy Notice describes your privacy rights regarding our collection, use, storage, sharing, and protection of your personal information.

You can exercise the following rights concerning your personal data with Guinness Nigeria:

Access: You have the right to request information from us as to whether and what personal data we hold.
Rectification: If any of your details are incorrect, inaccurate or incomplete you can ask us to correct the data.
Withdrawal of Consent: You have the right to withdraw consent at any time, provided that our processing is based on your consent.
Data Portability: In some circumstances you can ask us to send an electronic copy of the personal data you have provided to us, either to you or to another organization.
Restrict Processing: If you are uncertain about the accuracy or our use of your information, you can ask us to stop using your information until your query is resolved. We will inform you of the outcome before we take any further action in relation to this information.
Erasure: You can ask us to delete your personal data if deleting your data is not in conflict with our legal and regulatory obligations. If we are using consent to process your information and you withdraw it, you can ask us to erase your information.
Automated Processing: you have the right, under certain circumstances, not to be subjected to a decision based solely on automated processing of your personal data.

If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officer know.

Does Guinness Nigeria Process my Personal Data Automatically?

Guinness Nigeria will not perform any decision making, based solely on the automated processing (including profiling) of your personal data which results in legal consequences for you and/or which affects you in a similarly significant manner. We may use automated decision making if the decision is taken in connection with the conclusion or execution of a contract and

‘appropriate measures’ have been taken to protect the Data Subject’s legitimate interests (i.e. providing an opportunity for the Data Subject to make representations about the decision and providing the Data Subject with sufficient information about the underlying logic of the automated processing.

Dispute Resolution and Complaint Handling Mechanism

In line with our objective of creating a rewarding customer experience on our website, Guinness Nigeria has developed a dispute resolution and complaint handling process to ensure the effective management and timely resolution of all complaints relating to this Privacy Notice. In the event that you have any complaint regarding this Privacy Notice, please send us an email via nigeria.dpo@guinnessng.com. We will investigate and work towards ensuring the prompt resolution of all disputes and complaints relating to the use and disclosure of personal data in line with the provisions of the GAID.

In the event that the outcome of the resolution of your complaint is unsatisfactory, you are at liberty to lodge a complaint to the Nigeria Data Protection Commission (NDPC).

Contact Details of our Data Protection Officer (DPO)

In the event that you have any questions or inquiries relating to the collection and processing of your personal data or the exercise of your rights as a data subject, please send an email to our DPO via email at nigeria.dpo@guinnessng.com.

Cookies

Cookies enable us to distinguish you from other users of our website, which helps us to provide you with improved browsing experience. For more information about cookies and how we use them, please read our Cookie Policy.

Review of our Privacy Notice.

We may need to review and make necessary updates, modifications or amendments to our Privacy Notice to ensure compliance with applicable data protection legislation including the NDPA and GAID or as a result of changes in our systems and processes arising from the use of technology. We will notify you of any material changes in the way we collect and process your personal data by placing a notice online or via email.

WEBSITE PRIVACY NOTICE

Overview

This Privacy Notice provides information on how Guinness Nigeria collects and processes your personal data when you visit our website and other related platforms (“Site”). It sets out what we do with your personal data and how we keep it secure and explains the rights that you have in relation to your personal data.

Personal Data We Collect and Process

Guinness Nigeria collects the following personal data directly from you when you register your personal details on our Site:

Demographic information such as your date of birth and gender;
online registration information such as your password and other authentication information; and
in certain cases, your marketing preferences.

We automatically collect and store certain types of information regarding your use of our Site including information about your searches, views, downloads and purchases.

Use of Your Personal Data

We may use your personal data collected on our Site:

to verify your eligibility and to grant you access to the Site.
to process and respond to your needs on our platform.
to manage your relationship with us.
to improve our website functionalities, products and services.
to comply with our legal and regulatory obligations, including verifying your identity where necessary.
to prevent, detect and manage risk against fraud and illegal activities.
any other purpose that we disclose to you in the course of providing products and services to you.

Legal Basis for the processing of Your Personal Data

We are committed to ensuring that we legally process your personal data in our custody.

Guinness Nigeria shall only process your personal data if at least one of the following conditions apply:

you have given your consent to the processing of your personal data for one or more specific purposes;
the processing 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;
processing is necessary for compliance with a legal obligation to which Guinness Nigeria is subject;
processing is necessary in order to protect your vital interests or that of another natural person;
processing is necessary for the purpose of the legitimate interest pursued by Guinness Nigeria, or by a third party to whom the data is disclosed subject to certain conditions; and
processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Guinness Nigeria.

Sharing of Your Personal Data with Third Parties

We may need to share your personal data with third parties under the following circumstances:

to enable provide our services to you, end to end.
to analyze data, provide marketing assistance, process payments, transmit content, and provide customer service.
to comply with applicable laws and regulations or to respond to valid legal process, including from law enforcement or other government agencies.
to protect the rights of our customers, operate and maintain the security of our systems and network to ensure the preservation of life and property and prevention of fraud and cyberattack.
to protect the rights or property of Guinness Nigeria or others, including enforcing our agreements, terms, and policies.

Transfer of Personal Data

Guinness Nigeria shall implement appropriate safeguards to ensure the security of personal data to be transferred to a foreign country in compliance with the provision of the Nigeria Data Protection Act 2023 (“NDPA”) and the General Application Implementation Directive (“GAID”) or any other applicable data protection legislation. In particular, we shall, among other things, enter into Data Processing Agreements with the recipients of such personal data in the foreign country to ensure protection of your personal data.

Where personal data is to be transferred to a recipient in a foreign country deemed to have inadequate data protection laws, Guinness Nigeria will take all necessary steps to ensure that informed consent is obtained from you, and you are aware of the risks inherent including ensuring that personal data is transmitted in a safe and secure manner.

Data Security and Retention

We take the security of your personal data in our possession seriously. In line with our commitment to protect your personal data in our possession, we have developed appropriate organizational, technical and physical measures to protect the personal data you provide, or we collect against unauthorized access, loss or theft, as well as against any risk of loss, disclosure, copying, misuse or modification. Such measures include but are not limited to the use of secure servers, firewall, multiple factor authentication security, data anonymization and pseudonymization (as may be necessary), data encryption and granting access on a need-to-know basis only to employees in order to perform their job responsibilities.

Guinness Nigeria will only retain your personal data under the following circumstances:

as long as reasonably necessary for the purpose of providing our services to you; and
for the period needed to comply with our legal and statutory obligations under applicable law.

VISITORS PRIVACY NOTICE

This privacy notice is designed to help you understand how we use and protect the information obtained about you when you register to gain access into Guinness Nigeria premises, or any of our facilities, and during or after your visit with us.

The notice describes how we collect and use your personal information, in accordance with the General Application Implementation Directives (GAID).

How we collect your data

We collect information from you when you visit our premises for the purpose of Identification and determining whether to grant you access into the premises. It is important that you read this notice, so that you are aware of how and why we are using such information.

In accordance with data protection legislation, we are legally responsible for the personal data we collect and hold about you. However, this notice does not form part of a contract to provide services and we may update this notice periodically.

How we use your personal information and the legal basis of processing

We process your personal data for the following purposes:

Ensuring the security and safety on our premises.
Managing access of visitors to our premises.
Issuing visitor and access badges.
Making meeting room bookings or managing restaurant booking or catering services.
Responding to inquiries and request made during your visit.
Maintaining a record of visitors for security purposes.

We pursue this purpose based on our legitimate interests in managing visits to our premises and to comply with security and legal obligations. We may also use your personal information for other purposes that are compatible with the purposes mentioned above.

How long we keep your personal data

Your personal data is automatically deleted within 90 days after your visit.

Do we share your personal information?

We may disclose your personal data to third parties, in connection with the purposes set forth in this privacy notice. These recipients are contractually required to comply with applicable data protection laws as well as any applicable confidentiality requirements.