1. INTRODUCTION

Brane Technologies Limited (“Brane”, “We”, “Our” or “Us”) respects your privacy and is committed to protecting your personal data. This privacy policy (the “Policy”) will inform you as to how we look after your personal data when you engage our services or visit our website and informs you about your privacy rights and how the law protects you. By visiting www.getbrane.co, you are accepting and consenting to the practices described in this Policy.

2. IMPORTANT INFORMATION AND WHO WE ARE

(a) THE PURPOSE OF THIS PRIVACY POLICY

This Policy aims to give you information on how Brane collects and processes your personal data, including any data you may provide through our website when you sign up to our newsletters, send us an inquiry, engage our services or communicate with us otherwise.

It is important that you read this Policy together with any legal notices, cookie policy, and any other fair processing policy we may provide when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

(b) RESPONSIBILITY FOR THIS PRIVACY POLICY

Ezekiel Imole is the designated Data Protection Officer of Brane who will be responsible for compliance with this Policy and relevant data protection legislation.

If you have any questions about this Policy or our privacy practices, please contact our DPO in the following ways:

• Name: Ezekiel Imole
• Email address: [email protected]
• Address: 188, Awolowo Road, Ikoyi, Lagos
• Telephone number: +2348141805564

(c) CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our Policy under regular review.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

(d) PROTECTION OF PERSONAL DATA ON THIRD-PARTY LINKS?

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, we are not responsible for their privacy statements, and we do not accept any responsibility for their use of your personal information. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. THE INFORMATION THAT WE COLLECT

We may collect personal data, i.e., any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular 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.

It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifiers such as, but not limited to, MAC address, IP address, IMEI number, IMSI number, SIM, Personal Identifiable Information (PII), and others (“Personal Data”).

4. HOW WE COLLECT, PROCESS, USE AND SHARE PERSONAL DATA

4.1. We may collect your Personal Data using forms, email and physical requests, cookies, JWT, web tokens, or third-party applications. You can set your browser to refuse all or some browser cookies, or to alert you if we access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

4.2. We use your Personal Data for verification of your identity; human resources management; access to computer systems and third-party software; know-your-customer and due diligence purposes; recruitment purposes; regulatory compliance; performance of a contract with you; compliance with legal obligations; marketing; litigation; events planning and hosting; in-house security; research, analysis, and other business purposes or legitimate interests.

4.3. When you send email or other communications to us, we may retain those communications to process your inquiries, respond to your requests, or improve our services provided on our platform. We may also collect information while providing our services to you. Our servers automatically record information that your browser sends whenever you visit our platform.

5. CONSENT AND ACCESS RIGHTS

5.1. We will obtain your consent prior to collecting or processing your Personal Data. Where we intend to use the information for a purpose other than the purpose for which it was collected, prior to such use, we will request your consent.

5.2. No consent shall be sought, given, or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts, and anti-social conducts.

5.3. You may withdraw your consent at any time and may request access to your Personal Data in our possession. Such withdrawal will not affect the lawfulness of the processing of your Personal Data prior to the withdrawal of your consent. We can, however, deny you access to the information where we determine that your request is unreasonable.

5.4. You have the right to request the modification or amendment of your Personal Data in our possession.

5.5. In all cases of access or request for modification or amendment of Personal Data, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed, modified, or amended.

5.6. Where you provide the Personal Data of a third party to us, you confirm to us that you have informed the owner of the data about the purpose for which the data is required and that you have obtained the consent of the owner of the data to provide the data to us for the purpose for which it is required and in accordance with this Policy.

6. PERSONAL DATA PROTECTION PRINCIPLES

When we process Personal Data, we are guided by the following principles. Personal Data shall be:

• 6.1. collected only for specific, legitimate and lawful purposes;
• 6.2. processed lawfully for the purpose for which it was collected and not further processed in a manner incompatible with that purpose(s);
• 6.3. processed adequately, accurately and without prejudice to the dignity of the human person;
• 6.4. adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed;
• 6.5. accurate and where necessary, kept up to date;
• 6.6. stored only for the period within which it is reasonably needed; and
• 6.7. processed in a secure manner and protected against unauthorized or unlawful access or processing or accidental loss, destruction or damage.

7. SECURITY MEASURES

We have put in place and will maintain appropriate security measures to prevent your Personal Data from being used, accessed, altered or disclosed in an unauthorized way.

8. ACCESS BY THIRD PARTIES

We may share your Personal Data with third parties in the following circumstances:

1. where we have your consent;
2. with our parent company(ies), subsidiary, or affiliates when it is required to perform a contractual obligation due to you; for the verification of your identity;
3. where we provide such information to other professional advisers or other trusted businesses or persons for the purpose of processing Personal Data on our behalf or other legitimate business purposes. We would require such parties to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures;
4. where we have a legal basis that access, use, preservation or disclosure of such information is reasonably necessary to:
   1. satisfy any applicable law, regulation, legal process, or enforceable governmental request,
   2. enforce applicable terms of service, including investigation of potential violations thereof,
   3. detect, prevent, or otherwise address fraud, security or technical issues, or
   4. protect against imminent harm to our rights, property, or safety as required or permitted by law.

9. TRANSFER OF PERSONAL DATA OUTSIDE THE COUNTRY

9.1. We may transfer Personal Data outside Nigeria in the following circumstances:

1. with your consent;
2. the transfer is necessary for the performance of a contract between you and Brane or the implementation of pre-contractual measures taken at your request;
3. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between Brane and another natural or legal person;
4. the transfer is necessary for important reasons of public interest;
5. the transfer is necessary for the establishment, exercise, or defense of legal claims;
6. the transfer is necessary in order to protect your vital interests; or of other persons, where you are physically or legally incapable of giving consent.

9.2. We are a Nigerian company, and our website is subject to the laws of the Federal Republic of Nigeria. If you are accessing our website from other jurisdictions, please be advised that you are transferring your personal data to us in Nigeria, and by using our website, you are agreeing to the transfer and use of your Personal Data in accordance with this Policy. You also agree to abide by the laws of the Federal Republic of Nigeria concerning your use of the Platform and your agreements with us.

9.3. We may engage the services of third parties in order to process your Personal Data. The processing by such third parties shall be governed by a written contract with Brane to ensure adequate protection and security measures put in place by the third party for the protection of your Personal Data in accordance with the terms of this Policy and the relevant data protection laws in Nigeria.

9.4. The transfer of your Personal Data out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act, 2023. We shall put adequate measures in place to ensure the security of such data. In particular, we shall, among other things, conduct a detailed assessment of whether the said country is on the Whitelist of countries with adequate data protection laws. By consenting to the processing of your Personal Data, you consent to the transfer of your Personal Data outside Nigeria.

10. RETENTION OF PERSONAL DATA

10.1. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a compliant or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Where information is kept for a longer period, such as in backup storage, or archives, such information would be safeguarded in accordance with this Policy.

10.2. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, reporting or other requirements.

10.3. Where any information retained is stored in an encrypted format, considerations must be taken for secure storage of the encryption keys. Encryption keys must be retained as long as the data that the keys decrypt is retained.

10.4. In some circumstances, we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may retain and use this information indefinitely without further notice to you.

11. VIOLATIONS

We will take swift action to remedy any suspected breaches of Personal Data.

We will not be responsible for any breach of Personal Data which occurs as a result of:

If you know or suspect that a breach of Personal Data has occurred, or a violation of this Policy has occurred, you should immediately contact the Data Protection Officer at [email protected].

Violations of this Policy by employees may result in disciplinary action.

12. YOUR LEGAL RIGHTS

You have the right to:

If you wish to exercise any of the rights set out above, contact the Data Protection Officer at [email protected].

You will not have to pay a fee to:

Notwithstanding the above, we will charge a reasonable fee where:

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to 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.

13. CONTACT US

If you wish to exercise any of your rights under this Policy or know or suspect that a breach of your Personal Data or a violation of this Policy has occurred, or if you have any questions about this Policy or our privacy practices, please contact us at [email protected].