OUR PRIVACY POLICY
COMFORT STAY BLISS LIMITED PRIVACY POLICY
This Privacy Policy (“Policy”) is issued by Comfort Stay Bliss Limited (“the Company”), a company duly incorporated under the Companies and Allied Matters Act 2020 (as amended) with RC Number [BN 8226261] and having its registered office at [HOUSE 1, ROAD 2, OLUYOLE ESTATE EXT, IBADAN, OYO STATE], Nigeria.
This Policy governs the collection, use, storage, disclosure, and protection of your personal data when you visit or use our website https://comfortstaybliss.com/ (“Website”) and describes your rights regarding our use of such data in compliance with the Nigeria Data Protection Regulation 2019 (NDPR) and other applicable data protection laws in Nigeria.
LEGAL BASIS FOR DATA PROCESSING
The Company processes your personal data on the following legal grounds:
(a) Your consent;
(b) 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;
(c) Compliance with a legal obligation to which the Company is subject;
(d) Protection of your vital interests or those of another natural person; and
(e) Legitimate interests pursued by the Company, except where such interests are overridden by your interests or fundamental rights and freedoms.
PERSONAL DATA COLLECTION
In accordance with Section 2.1(1) of the NDPR, the Company collects the following categories of personal data:
(a) Identification Information: Name, residential address, email address, telephone number, and other contact details;
(b) Business Information: Company name, position, business address, and business contact details;
(c) Financial Information: Bank account details, payment information, and transaction history for the purposes of processing payments for services rendered;
(d) Technical Information: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website;
(e) Usage Information: Information about how you use our website, products, and services; and
(f) Communication Information: Your preferences in receiving marketing from us and our third parties and your communication preferences.
The Company collects personal data through the following methods:
(a) Direct interactions when you:
(i) Fill in forms on our website;
(ii) Create an account on our website;
(iii) Request construction services or quotations;
(iv) Subscribe to our publications or newsletters;
(v) Request marketing materials to be sent to you;
(vi) Provide feedback or contact us; or
(vii) Visit our office or construction sites.
(b) Automated technologies or interactions when you:
(i) Visit or interact with our website, whereby we automatically collect technical data about your equipment, browsing actions, and patterns using cookies and other similar technologies.
PURPOSE OF DATA COLLECTION AND PROCESSING
The Company processes your personal data for the following purposes:
(a) To register you as a new client or potential client;
(b) To process and deliver construction services, including:
(i) Managing payments, fees, and charges;
(ii) Collecting and recovering money owed to us;
(iii) Communicating with you about your project;
(c) To manage our relationship with you, including:
(i) Notifying you about changes to our terms or privacy policy;
(ii) Requesting feedback or reviews;
(d) To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data);
(e) To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
(f) To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences;
(g) To make suggestions and recommendations to you about goods or services that may be of interest to you; and
(h) To comply with legal and regulatory obligations
DATA RETENTION PERIOD
The Company shall retain your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, the Company considers:
(a) The amount, nature, and sensitivity of the personal data;
(b) The potential risk of harm from unauthorized use or disclosure of your personal data;
(c) The purposes for which we process your personal data and whether we can achieve those purposes through other means; and
(d) The applicable legal, regulatory, tax, accounting, or other requirements.
In accordance with Section 2.8 of the NDPR, the Company shall retain your personal data for a period not exceeding seven (7) years from the date of completion of the construction project or termination of the business relationship, whichever is later, unless a longer retention period is required or permitted by law.
TRANSFER OF PERSONAL DATA
The Company may transfer your personal data to the following categories of recipients:
(a) Internal third parties such as other members of the Company’s group acting as joint controllers or processors;
(b) External third parties such as:
(i) Service providers acting as processors based in Nigeria who provide IT and system administration services;
(ii) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in Nigeria who provide consultancy, banking, legal, insurance, and accounting services;
(iii) The Federal Inland Revenue Service, the Corporate Affairs Commission, and other regulatory authorities acting as processors or joint controllers based in Nigeria who require reporting of processing activities in certain circumstances.
The Company may transfer your personal data to countries outside Nigeria, provided that such countries ensure an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the Nigerian Data Protection Commission or where appropriate safeguards have been put in place.
Where the Company transfers your personal data outside Nigeria, it shall:
(a) Obtain your explicit consent; or
(b) Ensure that the recipient country or international organization ensures an adequate level of protection; or
(c) Enter into a contract with the recipient that incorporates the standard contractual clauses approved by the Nigerian Data Protection Commission.
SECURITY OF PERSONAL DATA
The Company has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:
(a) Encryption of personal data;
(b) Ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
(c) Ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
(d) Process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing; and
(e) Regular staff training on data protection and information security.
The Company has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
COOKIES AND SIMILAR TECHNOLOGIES
The Company uses cookies and similar technologies to distinguish you from other users of our website.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.
The Company uses the following types of cookies:
(a) Strictly necessary cookies: These are cookies that are required for the operation of our website;
(b) Analytical/performance cookies: These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it;
(c) Functionality cookies: These are used to recognize you when you return to our website;
(d) Targeting cookies: These record your visit to our website, the pages you have visited, and the links you have followed.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website.
YOUR RIGHTS AS A DATA SUBJECT
In accordance with Section 1.3 of the NDPR, you have the following rights regarding your personal data:
(a) Right to Information: You have the right to be informed about the collection and use of your personal data;
(b) Right of Access: You have the right to request a copy of the personal data we hold about you;
(c) Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you;
(d) Right to Erasure: You have the right to request that we delete your personal data in certain circumstances;
(e) Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances;
(f) Right to Data Portability: You have the right to request that we transfer your personal data to another organization or directly to you, in certain circumstances;
(g) Right to Object: You have the right to object to the processing of your personal data in certain circumstances; and
(h) 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, including profiling, which produces legal effects concerning you or similarly significantly affects you.
If you wish to exercise any of these rights, please contact our Data Protection Officer using the contact details provided below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
The Company will respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to lodge a complaint with the Nigerian Data Protection Commission if you consider that the processing of your personal data infringes the NDPR.
DATA PROTECTION OFFICER
The Company has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy.
Contact details of the DPO:
Name: Rahmat Ojo
Email address: rahmatojo01@gmail.com
Address: House 1, Road 2, Oluyole Estate Ext., Ibadan, Nigeria.
Telephone number: +234 803 548 8634
CHANGES TO THE PRIVACY POLICY
The Company reserves the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make substantial updates.
The updated version will be effective immediately upon posting on the Website.
We may also notify you in other ways from time to time about the processing of your personal data.
GOVERNING LAW
This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, particularly the Nigeria Data Protection Regulation 2019 and any subsequent amendments thereto.
CONTACT US
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details:
Comfort Stay Bliss
PHYSICAL ADDRESS: House 1, Road 2, Oluyole Estate Ext., Ibadan, Nigeria.
TELEPHONE NUMBER: +234 803 548 8634
EMAIL ADDRESS: rahmatojo01@gmail.com
Last Updated: 7th March, 2025
For queries and issues on our services, products and deals please email us at rahmatojo01@gmail.com
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