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 in connection with the BIC BTS Experience Centre (the “Event”), including Event registration, participation in the BIC BTS Literary & Debate Competition (the “Competition”), Event communications and related activities.
The words “we, “us” or “our” in this privacy notice, refers to Lucky Stationary Nig Ltd, a subsidiary of BIC Group (“hereinafter referred to as the Organiser”).
Please read this Privacy Notice carefully before registering for or participating in the Event. Where consent is required, the relevant consent will be obtained separately and will not be bundled with optional marketing consent.
1.0 PURPOSE OF THIS PRIVACY NOTICE
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 the Organiser. It also elucidates your rights concerning the collection of personal information and how you can exercise those rights.
This Privacy Notice applies to personal data processed in connection with the Event registration microsite, Event registration and check-in, the Competition, related Event communications, photography and filming, prize administration and other activities directly connected with the Event.
2.0 YOUR PRIVACY RIGHTS
This Privacy Notice describes your rights in relation to our collection, use, storage, sharing and protection of your personal data. Subject to applicable law and any applicable limitations, you may exercise the following rights in relation to your personal data held by the Organiser:
1. Right to be Informed: You have the right to be informed about the collection and use of your Personal Data by us.
2. Right of Access: You have the right to access and receive a copy of your Personal Data we hold about you and other information, including if applicable, if a machine-readable format.
3. Right to Rectification: You have the right to have inaccurate Personal Data rectified or completed if it is incomplete
4. Right to Withdraw Consent: Where we rely on your consent as the lawful basis for processing your personal data, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
5. Right to Data Portability: You have the right to obtain and reuse your Personal Data for your own purposes across different services.
6. Right to Restrict Processing: You have the right to request the restriction of the Processing of your Personal Data, under some circumstances and for certain purposes.
7. Right to erasure/delete/to be forgotten: You have the right to ask us to delete or remove Personal Data we collected from or about you. This right is subject to circumstances where we are required or permitted by law to retain or continue processing the data.
8. Right to Object: You have the right to object to us using your Personal Data in the context of direct marketing, and targeted advertising or where Processing is on the ground of legitimate interest. Objecting does not affect the lawfulness of the collection and Processing of Personal Data performed prior to the objection.
9. Rights Relating to Automated Decision-Making: You have the right, in circumstances provided by applicable data protection law, not to be subject to a decision based solely on automated processing of your personal data, including profiling, where such decision produces legal or similar significant effects concerning you. Where applicable, you have the right to obtain human intervention, express your point of view, and contest the decision.
10. Right to Lodge a Complaint: You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) where you believe that your personal data has been processed in violation of applicable data protection law.
Where a participant is a minor, these rights may be exercised by the participant’s parent or legal guardian, where permitted by applicable law and subject to appropriate verification.
To exercise any of these rights or to make a data protection enquiry, please contact the Organiser using the contact details provided in this Privacy Notice. We may take reasonable steps to verify the identity or authority of the person making the request before processing the request.
Does Organiser Process my Personal Data Automatically?
The Organiser will not make decisions based solely on the automated processing, including profiling, of your personal data where such decisions produce legal or similar significant effects concerning you.
Where permitted by applicable data protection law, the Organiser may use automated decision-making where such processing is necessary for the conclusion or performance of a contract, authorised by applicable law, or based on your explicit consent, provided that appropriate safeguards are implemented to protect your rights and legitimate interests.
Where applicable, you will have the right to obtain human intervention, express your point of view, and contest a decision based solely on automated processing.
3.0 WHAT PERSONAL DATA DO WE COLLECT?
Depending on how you interact with the Event, we may collect the following categories of personal data:
i. Identification and contact information, including full name, telephone number and email address.
ii. Demographic information such as age or where necessary date of birth to determine eligibility, particularly for Competition participants.
iii. School information, including the name of the participating secondary school and relevant details of the school representative.
iv. Parent or guardian information, including name and contact details where parental or guardian consent is required.
v. Participant and Competition information, including team membership, registration details and other information required to administer the Competition.
vi. Event Attendance Information including check-in information.
vii. Photographs, video recordings and audio recordings captured during the Event, subject to applicable consent and data protection requirements.
viii.
Prize and verification information, where required to verify eligibility and facilitate prize fulfilment.
ix.
Communications and correspondence relating to registration, Event attendance, Competition participation, enquiries or complaints.
x.
Technical Information including, IP address, browser/device information and similar information generated through use of the microsite registration site, where collected by the website or its service providers.
We will only collect information that is reasonably necessary for the relevant Event-related purpose and will process such data in accordance with applicable data protection laws and this Privacy Notice.
4.0 HOW DO WE COLLECT PERSONAL DATA?
We may collect personal data through the following channels:
i. Information provided directly through the Event registration microsite.
ii. Walk-in or on-site registration at the Event, where available and subject to capacity.
iii. Registration submitted by an authorized representative of a participating secondary school.
iv. Information provided by a parent or legal guardian in connection with an under-18 participant.
v. Information provided by participants, schools or authorized representatives during Competition registration and administration.
vi. Attendance, check-in and Event administration activities.
vii. Photography, filming and recording undertaken at the Event.
viii. Correspondence with Organizer or authorized Event personnel.
ix. Third-party service providers supporting the Event, where they lawfully provide information to us or process information on our behalf.
5.0 HOW DO WE USE PERSONAL DATA?
We may use personal data for the following purposes:
i. To process and administer Event registration.
ii. To confirm registration and communicate Event details, schedules, requirements and changes.
iii. To manage Event attendance, check-in, security and venue access.
iv. To administer Competition registration, eligibility, participation, judging, progression and results.
v. To verify the identity and eligibility of participants, participating schools and prize recipients.
vi. To administer and fulfil prizes and rewards.
vii. To manage safeguarding, health and safety, security and incident management where necessary.
viii. To prevent fraud, cheating, misuse or other conduct that could compromise the Event or Competition.
ix. To document the Event and create photographs, videos and other Event content.
x. To use Event photographs, recordings and Competition highlights for publicity, documentation, advertising and promotional purposes, subject to applicable law and required consents.
xi. To respond to enquiries, complaints and requests concerning the Event.
xii. To comply with applicable legal, regulatory, accounting, reporting or record-keeping requirements.
xiii. To protect our legal rights and interests and establish, exercise or defend legal claims.
xiv. To send marketing or promotional communications where the individual has separately provided the required consent or where otherwise permitted by applicable law.
xv. any other purpose that we disclose to you in the course of the Event
Marketing consent is optional. Registration for, or participation in the Event will not be made conditional on an individual’s agreement to receive future marketing communications.
6.0 LEGAL BASIS FOR PROCESSING
We will process personal data only where permitted by applicable Nigerian data protection law. Depending on the circumstances, the lawful basis for processing may include:
i. Where the Participant has given consent to the processing of their personal data for one or more specific purposes, where consent is required or relied upon as the lawful basis for the processing.
ii. Where processing is necessary for the administration of the Event or to take steps at the Participant’s request in connection with their participation in the Event.
iii. Where processing is necessary for compliance with a legal or regulatory obligation applicable to the Organiser.
iv. Where processing is necessary for the legitimate interests pursued by the Organiser or an authorised Event service provider, provided that such interests are not overridden by the rights and freedoms of the individual.
v. Where processing is necessary to protect the vital interests of the Participant or another person, where applicable.
vi. Where we rely on consent, such consent will be obtained in a manner that is clear, specific, informed and capable of being withdrawn. Where consent is optional, refusal to provide consent will not prevent a Participant from registering for or participating in the Event where the relevant processing is not otherwise necessary for participation.
vii. Where consent is withdrawn, this will not affect the lawfulness of processing carried out before the withdrawal.
7.0 CHILDREN’S PERSONAL DATA
The Competition is intended for secondary school students and may involve participants under the age of 18. We recognize that children’s personal data requires particular care and appropriate safeguards.
Participating schools may register their teams through an authorized school representative. Where required by applicable law or the Event’s registration process, the parent or legal guardian of each participant under 18 may also be required to provide individual consent or other appropriate authorization for the participant’s participation and the relevant processing of their personal data.
Where personal data relating to a child is collected, we will take reasonable steps to ensure that the relevant consent, authorization and safeguarding requirements have been satisfied.
We will only use children’s personal data for specified and lawful purpose connected with the Event and Competition including administration, safeguarding, publicity where appropriately authorized, and other purposes described in this Privacy Notice and the applicable Competition Terms & Conditions.
8.0 SPECIAL CATEGORIES OF PERSONAL DATA
We do not ordinarily require special-category personal data for Event registration or Competition participation. Where such information becomes necessary for a specific Event-related purpose, it will only be collected and processed where permitted by applicable law and subject to appropriate safeguards.
9.0 PHOTOGRAPHY, VIDEO AND PUBLICITY
Photography, video and audio recording may take place during the Event for Event documentation, publicity, advertising, promotional and related communication purposes.
Where required, the appropriate consent will be obtained before personal images or recordings are used for the relevant purpose, particularly where children are involved.
Subject to applicable law and required consents, Organizer may use Event photographs, recordings, Competition highlights, participating school names and related Event content in marketing materials, digital channels, social media, websites, websites, presentations, reports and other promotional communications without additional compensation.
Where an individual does not provide consent for optional publicity use requiring consent, this will not affect their ability to register for or participate in the Event, subject to any necessary Event photography or general venue recording arrangements disclosed at the Event.
10.0 CONSENT AND WITHDRAWAL OF CONSENT
Where consent is required, the relevant consent will be presented separately from other terms and conditions and will be capable of being provided for or withheld without unnecessary consequences.
The Event registration process will distinguish between mandatory acknowledgements/consents necessary for Event administration and optional consent for future marketing communications.
For participants under 18, parental or legal guardian consent will be obtained where required.
An individual may withdraw consent at any time where processing is based on consent. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.
Where an individual withdraws consent, we will stop the relevant consent-based processing unless another lawful basis permits or requires us to continue processing the information.
11.0 AUTOMATED DECISION-MAKING AND PROFILING
Organizer does not intend to make decisions producing legal or similarly significant effects on individuals solely through automated decision-making or profiling in connection with the Event or Competition.
If this position changes and automated decision-making or profiling is introduced in a manner that is subject to applicable legal requirements, appropriate information and safeguards will be provided.
12.0 WHEN DO WE SHARE PERSONAL DATA?
We may share personal data where necessary and lawful for the purposes described in this Privacy Notice. This may include sharing with:
i. The Organizer and its affiliates, authorized representatives and where applicable, relevant group entities involved in the planning, organization and administration of the Event. Whenever we need to share your Personal Data, we do so strictly on a need-to-know basis and only with selected team members, to the extent necessary, for them to carry out their responsibilities
ii. Authorized Event personnel and Service Providers where engaged to support registration, Event administration and Competition management.
iii. Event Service Providers including Venue Operators, security Providers, technology and registration providers, production teams, photographers, media and other service providers engaged to support the Event.
iv. Competition Judges and officials, where information is necessary for judging or Competition administration.
v. Prize fulfilment providers where necessary to verify eligibility and administer or facilitate the fulfilment of prizes.
vi. Professional advisers, including auditors, insurers or legal advisers, where reasonably necessary for the provision of professional services or the protection of the Organizer’s legal rights and interests.
vii. Regulators, law enforcement agencies, courts or other authorities where disclosure is required or permitted by applicable law or is necessary for the prevention or detection of unlawful activity.
viii. Third parties that process personal data on our behalf will be required to implement appropriate confidentiality, security and data protection measures and to process personal data only for authorized purposes.
13.0 THIRD-PARTY SERVICE PROVIDERS
We may engage third-party service providers to support the Event, including providers of website hosting, registration technology, data storage, communications, analytics, security, photography, media, event management and prize fulfilment services.
Where a third-party processes personal data on behalf of Organizer, appropriate contractual and organizational safeguards will be implemented to protect the information and limit processing to authorized purposes.
14.0 WHERE DO WE STORE AND PROCESS PERSONAL DATA?
Personal data may be stored or processed using systems and service providers located in Nigeria or, where applicable, in other countries. Where personal data is transferred or made accessible outside Nigeria, the Organizer will take appropriate steps to ensure that the transfer or access is lawful and that the personal data is adequately protected in accordance with the Nigeria Data Protection Act, 2023 (“NDPA”), the General Application and Implementation Directive (“GAID”) and other applicable data protection laws.
15.0 HOW DO WE SECURE PERSONAL DATA?
We take the security of your Personal Data very seriously and implements strong appropriate technical and organizational measures to protect it.
We make sure that any Personal Data we hold about you:
• Can only be accessed, altered, disclosed or deleted by those who are authorized to do so, in accordance with the principle of least privilege.
• Is accurate, up to date and contains only information needed for our purposes outlined in this Policy
• Remains accessible and usable only by authorized individuals, ensuring business continuity and the proper functioning of our services.
In addition, Organizer regularly reviews its data security practices, provides training to staff, and requires third party providers to meet equivalent security standards through contractual obligations.
Further, if we are required to provide you with notice of a Data Breach, or do so voluntarily, you agree that we may do so via reasonable electronic notice, including by sending notice to any email address we have on file to you, at our discretion. In any case, where Data Breach occurs and its reporting is required by law, we will follow the local legal provisions
16.0 HOW LONG DO WE KEEP PERSONAL DATA?
We will retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including Event administration, Competition administration, prize fulfilment, legal, regulatory, accounting and record-keeping requirements, and the establishment, exercise or defence of legal claims.
Where a specific retention period has been approved for the Event, personal data will be retained in accordance with that period. Where no fixed period is specified, the retention period will be determined by considering the purpose for which the information was collected, its nature and sensitivity, applicable legal requirements, limitation periods, potential disputes, and whether the purpose can be achieved without retaining identifiable personal data.
When personal data is no longer required, it will be securely deleted, destroyed or anonymized, as appropriate in accordance with applicable data protection requirements and our retention policies.
17.0 TRANSFER OF PERSONAL DATA
Where personal data is transferred to or accessed by a recipient outside Nigeria, the Organiser will implement appropriate safeguards to ensure that such transfer is carried out in accordance with the Nigeria Data Protection Act, 2023 (“NDPA”), the General Application and Implementation Directive (“GAID”), and any other applicable data protection laws.
Depending on the circumstances, appropriate safeguards may include entering into appropriate data protection or data transfer agreements with the relevant recipient, implementing contractual or other safeguards required by applicable law, and ensuring that the personal data is transferred and handled in a secure manner.
Where required by applicable law, the Organiser will obtain the appropriate consent or take any other required measures before transferring personal data to a recipient in a jurisdiction that does not provide an adequate level of data protection.
We will take reasonable steps to ensure that any international transfer of personal data is limited to what is necessary for the relevant purpose and that appropriate technical, organisational and contractual safeguards are in place to protect the personal data.
18.0 HOW TO EXERCISE YOUR RIGHTS OR CONTACT US
If you have questions about this Privacy Notice, wish to exercise data protection right, or have a concern about how your personal data is being processed, please contact:
Data Protection Officer / Privacy Contact: Chinelo Anosike
Email: chinelo.Anosike@bicworld.com
Address:1, Sylvia Crescent Anthony Village Lagos
We may request information that is reasonably necessary to verify the identity of the person making a request before providing access to or changing personal data. This is intended to prevent personal data from being disclosed to an unauthorized person.
19.0 MARKETING COMMUNICATIONS
Where the Organizer wishes to use personal data to send future marketing or promotional communications, the relevant marketing consent will be presented separately from the mandatory Event registration terms.
Providing marketing consent is optional and is not a condition of Event registration or participation.
Individuals who have provided marketing consent may withdraw it at any time using the unsubscribed mechanism provided in the relevant communication or by contacting the privacy contact identified in this Privacy Notice.
20.0 COOKIES AND SIMILAR TECHNOLOGIES
The Event registration website or microsite may use cookies and similar technologies to enable website functionality, maintain security, remember preferences and, where applicable, understand how visitors interact with the website.
Where cookies or similar technologies are used, information about their purpose and how they may be managed will be made available through the relevant website or cookie notice.
Where required by applicable law, consent will be obtained before non-essential cookies or similar technologies are used.
21.0 LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT
The Event registration microsite or Event-related communications may contain links to websites or platforms operated by third parties.
This Privacy Notice applies only to personal data processed by or on behalf of Organizer in connection with the Event. Where an individual accesses a third-party website or platform, the privacy practices of that third party will apply. Individuals are encouraged to review the relevant third party’s privacy notice before providing personal data. Organizer is not responsible for the privacy practices or content of third-party websites or platforms unless otherwise stated.
22.0 COMPLAINTS
We encourage individuals to contact the Organizer’s Privacy Contact or Data Protection Officer first so that concerns can be considered and addressed where possible.
Individuals may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) where they believe their personal data has been processed in breach of applicable data protection law.
23.0 CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time to reflect changes to the Event, our processing activities, applicable law or our privacy practices.
The latest version will be made available through the Event registration microsite or other appropriate Event communication channels. Where changes are material, we may provide additional notice where required.
24.0 IMPORTANT INFORMATION FOR REGISTRATION
The Privacy Notice and the Competition Terms & Conditions will be made available to individuals on the Event registration page before registration is completed. Individuals will be able to access and read the relevant documents before providing any required acknowledgement or consent.
The registration process will distinguish between:
i. Mandatory acknowledgements and consents required for Event registration and participation; and
ii. Optional consent to receive future BIC marketing and promotional communications.
For under-18 Competition participants, the registration and consent process will also provide for the required parental or legal guardian consent.