SUPA Data Protection Policy.

1. Personal data that we process

The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.

• Name

• Residential Address

• Date of Birth

• Phone number

• Email

• Location

• National identification Number

• Website activity collected through cookies

• Any information that can be used to identify the person

2. How we use your data

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy.

For example, we may use your personal information to:

• Reply to enquiries you send to us;

• Handle transactions that you initiate;

• Send you communications by email relating to our work which we think may be of interest to you.

• Placement on C4E, Internment, Basic training and Certification

In addition, we will only pass data to third parties outside Nigeria where appropriate safeguards are in place as defined by the Nigerian Data Protection Act, 2023.

3. When we share your data

We will only pass your data to third parties in the following circumstances:

• You have provided your explicit consent for us to pass data to a named third party;

• We are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or

• We are required by law to share your data.

In addition, we will only pass data to third parties outside Nigeria where appropriate safeguards are in place as defined by the Nigerian Data Protection Act, 2023.

4. How long we keep your data

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.

Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.

5. Rights you have over your data

You have a range of rights over your data, which include the following:

• Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our emails).

• You have the right to ask for rectification and/or deletion of your information.

• You have the right of access to your information.

Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.

6. Cookies & usage tracking

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, e.g. remembering your preferences, and counting the number of people looking at a website.

Modifications

We may modify this Privacy Policy from time to time and will publish the most current version on our website.