1. INTRODUCTION

NLNG Ship Management Limited (‘NSML’) is an organization incorporated under the laws of the Federal Republic of Nigeria with registered address at NLNG Road, Amadi Creek, Off Eastern Bye-pass, Port Harcourt, Rivers State, Nigeria.

The nature of NSML’s business necessitates interaction with companies and individuals in various parts, regions and countries of the world. As a responsible corporate organization, NSML complies with all relevant laws and regulations in all jurisdictions in which it carries on business activities including without limitation all laws and regulations relating to the protection of personal information and data including without limitation the European Union General Data Protection Regulations (Regulation (EU) 2016/679) and the Nigerian Data Protection Regulations.

NSML respects the rights and privacy of every individual and organization it interacts with and has put in place policies and procedures regarding the confidentiality and protection of personal data.

This Privacy Statement outlines NSML’s commitment to the protection of personal data in clear and simple terms; and provides all required information relating to the collection and use of personal data for business purposes. References to “NSML”, in this statement include NSML and it’s affiliates. References to personal data/information in this statement include any information which could be used to identify a living individual either on its own or in combination with any other information.

This Privacy Statement forms an integral part of the terms and conditions for use of or access to NSML sites, systems, platforms and all interaction with NSML.

Furnishing your personal data to NSML further to receipt of this statement means you have consented to the use of your personal data for NSML’s business purposes.

2. PERSONAL DATA

A. Collection of Personal Data: The personal data we collect and process may include:

1. Your name, identification number (international passport or other relevant identification type) and any other identification information you provide to us for business purposes;
2. Your employer (or previous employers), title and position in your organization;
3. Contact information including your physical address, email address, telephone number(s);
4. Financial information such as details of your bank account for the purpose of making payments;
5. Information relating to your activities within our system and business environment including your IP address and websites visited using our systems, user name and details;
6. Details of your movements, travel and itinerary when involved in our business process and activities, or as imagery captured by closed circuit or other security systems in place at NSML facilities;
7. Names and details of your family members and dependants.
8. Special data including but not limited to your race, blood group and other genetic information; and ix. Any other information you may provide to us or which we receive in the course of communication with you.

B. Use of your Personal Data:

All personal data we obtain will only be used as required for our business activities. This will include:

1. Maintaining employment records within NSML.
2. Activities relating to the relationship between NSML and your organization.
3. Communication with you in regards to item (i) above.
4. Provision of access to our various locations, systems, applications and various business platforms.
5. Processing of payments including benefits, allowances and salaries as may be due. vi. Provision of medical services (where necessary)
6. Fulfilment of any legal or statutory obligations and any other business use or purpose for which you are requested to provide (and for which NSML is obliged to retain) such personal data.
7. Any other use for which you provided the personal data to NSML.

c. Sharing of Personal Data:

NSML carries out business activities in various parts of the world, and your Personal Data may be shared with our subsidiaries and affiliates for business purposes and activities only.

NSML may also share your personal data with third parties who provide services to it, or to you on its behalf including but not limited to information technology and data management services, transportation and various logistic services; and with any law enforcement or government regulatory agency where so required by any laws or regulations.

d. Retention of Your Personal Data:

Your Personal Data may be stored in our systems and applications for a period in line with applicable NSML data retention policies and any relevant legal and statutory obligations.

e. Our Commitment to Data Security:

NSML has put in place reasonable technical and organisational measures to prevent unauthorised or accidental access, processing, erasure, loss or use of your personal data and to keep your personal data confidential. These measures are subject to ongoing review and monitoring.

To protect your personal data, we also require our third party service providers to take reasonable precautions to keep your personal data confidential and to prevent unauthorised or accidental access, processing, erasure, loss or use of personal data, and to act at all times in compliance with applicable data protection laws.

f. NSML cannot guarantee that our systems will function faultless and without any interruptions. We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.

3. PERSONAL DATA OF A MINOR

NSML may sometimes (including without limitation for the purpose of providing medical, educational, transport and logistics services) require the personal data of family members of individuals with whom we are engaged in various business activities including minors or other persons of reduced/diminished capability.

When this is the case, NSML will obtain the consent of the parent or guardian of such individual. All other terms of use under this Privacy Statement remain the same.

4. YOUR RIGHTS

NSML will upon your request:

1. Provide you with a copy of your personal data held within its organization.
2. Transfer your personal data to an organization of your choice.
3. Delete your personal data within its systems (subject to the provisions of sub-article 2(d) above); and
4. Rectify your personal data to correct any errors you have identified therein.

In addition to the foregoing, you also have the right to withdraw the consent you have given for the processing of your personal data and the right to lodge a complaint with any appropriate authority if considered necessary.

Note that this will not in any way affect the validity of the use or processing of information while such consent was in place. The withdrawal of consent will also amount to withdrawal from the purpose for which such consent was originally given.

5. CHANGES

NSML reserves the right to update and amend this Privacy Statement from time to time without recourse or notice to you. Any such amendment or update will subsequently be communicated as may be necessary. For the avoidance of any doubt, NSML will never use your personal data for marketing, profiling or any purpose outside the purpose for which such personal data was obtained.

All requests and inquiries relating to this Privacy Statement can be directed to [email protected]