Privacy Policy

U-CONNECT HR LIMITED PRIVACY POLICY

Effective Date: Last Updated:

1. INTRODUCTION

U-Connect HR Limited (“U-Connect”, “we”, “our” or “us”) is committed to protecting the privacy and personal data of individuals who interact with us through our website, digital platforms and other online services.

This Privacy Policy explains how we collect, use, process, store, disclose and protect personal data obtained through our website, including information submitted through contact forms, job applications, talent registration portals, client enquiries, service requests and other data collection points.

This Policy is designed to comply with the Nigeria Data Protection Act, 2023 (“NDPA”), the Nigeria Data Protection Commission’s applicable regulations, directives and guidance, and other relevant data protection laws where applicable.

By accessing or using our website, you acknowledge that you have read this Privacy Policy. Where consent is required as a lawful basis for processing personal data, we will obtain such consent in accordance with applicable law. Your use of our website does not, by itself, constitute consent to every form of data processing described in this Policy.

2. WHO WE ARE

U-Connect HR Limited is a human resources and workforce solutions company providing recruitment, staffing, outsourcing, background verification and related human resources services to individuals and corporate clients.

For the purposes of applicable data protection laws, U-Connect HR Limited acts as a data controller where it determines the purposes and means of processing personal data. In certain engagements, we may act as a data processor on behalf of our clients, depending on the nature of the services provided and the parties’ respective responsibilities.

This Privacy Policy applies to personal data collected through our website and related online interactions. Additional privacy notices or contractual terms may apply to specific services, employment relationships, recruitment assignments or client engagements.

3. PERSONAL DATA WE COLLECT

Depending on how you interact with our website and services, we may collect the following categories of personal data:

3.1. Identification and Contact Information

This may include:

• Full name and title.
• Email address and telephone number.
• Residential or business address, where provided.
• Company name, job title and other professional contact details.

3.2. Job Application and Talent Registration Information

Where you apply for a vacancy, register in our talent database or submit your profile for employment opportunities, we may collect:

• Curriculum vitae (CV), résumé and cover letter.
• Educational qualifications, certifications and professional memberships. • Employment history, work experience, skills and competencies.
• Career preferences, salary expectations and availability.
• References and other information supplied in support of an application.
• Information required for recruitment, candidate screening and background verification.

We will collect sensitive personal data, such as health information or other specially protected information, only where necessary, permitted by law and subject to the applicable safeguards.

3.3. Contact Forms and General Enquiries

When you contact us through our website, we may collect your name, contact details, organisation, the subject of your enquiry and any other information you voluntarily provide in your message or attachments.

3.4. Client and Business Enquiry Information

Where you enquire about our services or engage with us as a prospective or existing client, we may collect business contact details, organisational information, service requirements and communications relevant to the enquiry or business relationship.

3.5. Technical and Usage Information

When you visit our website, certain technical information may be collected automatically, including:

• Internet Protocol (IP) address.
• Browser type, device information and operating system. • Website pages visited, access times and referral sources.
• Website interaction data, diagnostic information and security logs.
• Cookie identifiers and similar online tracking information, where applicable.

3.6. Other Information

We may collect additional information where it is reasonably necessary for the purposes described in this Policy, provided that such collection is lawful, proportionate and consistent with applicable data protection requirements.

We do not intentionally request personal data that is unnecessary for the relevant purpose.

4. HOW WE COLLECT PERSONAL DATA

We may collect personal data through the following means:

1. Directly from you: When you complete a contact form, submit a job application, register your profile, upload a CV, request information, subscribe to communications or otherwise provide information through our website.
2. Through recruitment and talent platforms: When you register for employment opportunities or participate in recruitment processes managed by U-Conne.
3. From clients and authorised third parties: Where clients, referees, professional references, recruitment partners or other authorised sources provide information necessary for recruitment, staffing, background verification or related services, subject to applicable legal requirements.
4. Automatically through website technologies: Through server logs, cookies and similar technologies used for website functionality, analytics, performance monitoring and security, as applicable.
5. From publicly available sources: Where necessary and lawful, we may obtain professional or business information from publicly available sources for recruitment, verification, compliance or other legitimate business purposes.

Where we obtain personal data indirectly, we will provide relevant privacy information as required by applicable law, subject to any lawful exceptions.

5. PURPOSES OF PROCESSING PERSONAL DATA

We process personal data for specific, legitimate and lawful purposes, including:

1. Responding to enquiries, complaints, feedback and requests submitted through our website.
2. Receiving and reviewing job applications and identifying suitable candidates for employment opportunities.
3. Registering and maintaining candidate profiles in our talent database.
4. Matching candidates with vacancies and communicating relevant employment opportunities.
5. Conducting recruitment, screening, reference checks and background verification where applicable and lawfully authorised.
6. Providing recruitment, staffing, outsourcing and other human resources services to clients.
7. Managing business relationships and communicating with prospective and existing clients.
8. Improving website functionality, accessibility, performance and user experience.
9. Protecting our website, systems and business against fraud, unauthorised access, cyber threats and other security risks.
10. Complying with applicable legal, regulatory, contractual and reporting obligations. 11. Establishing, exercising or defending legal claims.
11. Sending marketing communications, newsletters or promotional information where permitted by law and, where required, with your consent.

We will not process personal data in a manner incompatible with the purposes for which it was collected unless a further lawful basis exists and any required information or consent has been provided.

6. LAWFUL BASIS FOR PROCESSING

U-Connect will process personal data only where an appropriate lawful basis exists under the NDPA and other applicable data protection laws.

Depending on the circumstances, our lawful bases may include:

1. Consent: Where you have freely and expressly agreed to a specified processing activity, such as receiving certain marketing communications or the use of non-essential cookies where consent is required.
2. b. Contractual necessity: Where processing is necessary to take steps at your request before entering into a contract or to perform a contract to which you are a part
3. c. Legal obligation: Where processing is necessary to comply with applicable legal or regulatory obligation
4. d. Legitimate interests: Where processing is necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your fundamental rights and freedoms. Examples may include website security, managing business enquiries and certain recruitment administration activities.
5. e. Vital interests or public interest: Where applicable, processing may be necessary to protect vital interests or to perform a task carried out in the public interest or under an official authorit

Where we rely on consent, you may withdraw it at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal. We will assess and document the appropriate lawful basis for each relevant processing activity.

7. JOB APPLICATIONS AND TALENT REGISTRATION

U-Connect may maintain a database of candidates and prospective employees for recruitment, talent management and placement purposes.

When you submit your CV, register your profile or apply for a vacancy, we may use your personal data to assess your suitability for a role, contact you about opportunities, conduct interviews, verify qualifications and references, and share relevant information with prospective employers or clients where appropriate and lawful.

Registration in our talent database does not guarantee employment, placement or an interview.

Where your information is retained for consideration for future opportunities, we will inform you of the relevant purposes and retention arrangements. Where consent is the appropriate lawful basis, we will obtain it before processing on that basis.

If you no longer wish to be considered for future opportunities, you may contact us to request the removal or deletion of your profile, subject to applicable legal obligations and other lawful grounds for retention.

Background checks, reference checks and other verification activities will be conducted only where appropriate to the recruitment or service purpose and in accordance with applicable law. We will implement additional safeguards where the information involved is sensitive or otherwise subject to enhanced protection.

8. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies to support essential website functions, maintain security, remember user preferences, analyse website performance and improve the user experience.

Cookies may be classified as:

• Strictly necessary cookies: Required for the website to function properly or securely. • Functional cookies: Used to remember preferences and improve usability.
• Analytics cookies: Used to understand website traffic, usage patterns and performance. • Marketing cookies: Used, where applicable, to support advertising or measure the

effectiveness of marketing activities.

Where required by law, we will obtain your consent before placing or accessing non-essential cookies or using similar tracking technologies. You may manage your preferences through any cookie settings tool provided on the website and through your browser settings.

Disabling certain cookies may affect the availability or functionality of some website features.

Details of the cookies used, their purposes, providers and retention periods should be made available through an appropriate cookie notice or cookie settings tool where applicable.

9. DISCLOSURE AND SHARING OF PERSONAL DATA

U-Connect does not sell personal data to third parties. However, we may disclose or share personal data where necessary, lawful and consistent with the purposes described in this Policy.

Recipients may include:

1. Clients and prospective employers: Candidate information may be shared with relevant clients or prospective employers for recruitment, screening and placement purposes, subject to appropriate authorisation and applicable legal requirements.
2. b. Service providers and data processors: We may engage website hosting providers, cloud storage providers, information technology support providers, recruitment platforms, analytics providers and other service providers to support our operations. Such providers will be required to process personal data in accordance with applicable law and appropriate contractual safeguards.
3. c. Professional advisers: Lawyers, auditors, consultants, insurers and other professional advisers may receive relevant information where necessary for professional, legal, insurance or compliance purposes.
4. d. Regulatory and law enforcement authorities: We may disclose information where required or authorised by law, pursuant to a lawful request, or where reasonably necessary to establish, exercise or defend legal claims.
5. e. Corporate transactions: Personal data may be disclosed in connection with a proposed or completed merger, restructuring, acquisition or transfer of business assets, subject to applicable confidentiality and data protection requirements.
6. Other authorised recipients: We may share information with other recipients where you have authorised the disclosure or another lawful basis permits it.

We will limit disclosures to information reasonably necessary for the relevant purpose and apply appropriate safeguards to protect personal data.

10. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Some of our service providers or technology platforms may store or process personal data outside Nigeria.

Where personal data is transferred to another country, U-Connect will ensure that the transfer complies with the NDPA and applicable regulations governing cross-border transfers. Depending on the circumstances, this may require an assessment of the destination country’s level of data protection, appropriate safeguards, contractual protections or another legally recognised transfer mechanism.

We will take reasonable steps to ensure that personal data transferred internationally remains protected and that the transfer is limited to what is necessary for the relevant purpose.

11. DATA RETENTION

U-Connect will retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including recruitment, talent management, service delivery, legal compliance, dispute resolution and the protection of our legitimate business interests.

Retention periods will depend on the nature of the information and the applicable purpose. For example:

• Contact and enquiry records: Retained for the period necessary to respond to and manage the enquiry and any related follow-up.
• Job applications and candidate profiles: Retained for the duration of the relevant recruitment process and, where appropriate, for a defined period for future opportunities.
• Client and business records: Retained for the duration of the business relationship and any additional period required by law or reasonably necessary for legitimate business purposes.
• Technical and security logs: Retained for a period proportionate to security, diagnostic and operational requirements.
• Consent and compliance records: Retained as necessary to demonstrate compliance with applicable legal obligations.

When personal data is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with our data retention and disposal procedures, unless continued retention is required or permitted by law.

U-Connect should maintain and periodically review an internal data retention schedule specifying applicable retention periods for each category of personal data.

12. DATA SECURITY

We take appropriate technical and organisational measures to protect personal data against unauthorised access, unlawful processing, accidental loss, destruction, alteration, disclosure and other security risks.

Depending on the nature of the processing and the risks involved, these measures may include:

• Access controls and role-based permissions.
• Password protection and appropriate authentication measures.
• Secure hosting, encryption and other technical safeguards where appropriate. • Staff confidentiality obligations and data protection training.
• System monitoring, backups and security assessments. • Vendor and service-provider oversight.
• Secure data disposal and incident response procedures.

We regularly review our safeguards in light of applicable requirements and identified risks.

However, no method of transmitting or storing information electronically is entirely secure. While we take reasonable measures to protect personal data, we cannot guarantee absolute security.

13. PERSONAL DATA BREACHES

Where a personal data breach occurs, U-Connect will investigate the incident, take appropriate steps to contain and mitigate its effects, assess the risks to affected individuals and maintain relevant incident records.

We will notify the Nigeria Data Protection Commission and affected data subjects where required by the NDPA and applicable regulations, within the applicable statutory timelines and subject to the relevant legal requirements.

We will also take reasonable steps to prevent similar incidents from recurring.

14. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and any relevant limitations or exemptions, you may have the right to:

1. Be informed: Receive information about how your personal data is collected and processed.
2. Access: Request confirmation of whether we process your personal data and obtain access to it.
3. Rectification: Request the correction of inaccurate or incomplete personal data.
4. Erasure: Request the deletion of personal data where the applicable legal conditions are satisfied.
5. Restriction: Request that processing be restricted in circumstances permitted by law.
6. Data portability: Request a copy of certain personal data in a structured, commonly used and machine-readable format, where the legal requirements are met.
7. Object: Object to certain processing activities, including processing based on legitimate interests, where applicable.
8. Withdraw consent: Withdraw consent where processing is based on consent.
9. Marketing opt-out: Object to or opt out of direct marketing at any time, as applicable. 10. Automated decision-making: Benefit from applicable protections concerning decisions based solely on automated processing that produce legal or similarly significant effects.

11. Lodge a complaint: Submit a complaint to the Nigeria Data Protection Commission if you believe your personal data has been processed in violation of applicable data protection law.

These rights are subject to applicable statutory conditions and exceptions. For example, we may need to retain certain information to comply with a legal obligation or establish, exercise or defend a legal claim.

To exercise any of these rights, please contact us using the details provided in Section 19 of this Policy. We may request reasonable information to verify your identity before acting on your request.

We will respond within the time prescribed by applicable law and inform you where a request cannot be fulfilled, including the reasons where required.

15. THIRD-PARTY WEBSITES AND PLATFORMS

Our website may contain links to third-party websites, social media platforms, recruitment portals or other external services.

These third-party websites and services may operate under their own privacy policies and data handling practices. U-Connect is not responsible for the privacy practices of independent third parties merely because their services are linked to our website.

We encourage you to review the privacy policies of any third-party websites or platforms you visit before submitting personal data to them.

16. CHILDREN’S PERSONAL DATA

Our website and services are primarily intended for adults, including job seekers, professionals, business representatives and corporate clients.

We do not knowingly collect children’s personal data through our website unless such collection is lawful, necessary for a specified purpose and subject to the safeguards required by applicable law.

Where processing involves a child or another person entitled to enhanced protection, U-Connect will apply the relevant legal requirements, including any applicable parental or legal guardian authorisation and additional safeguards.

If you believe that a child has provided personal data to us unlawfully, please contact us so that we can assess the circumstances and take appropriate action.

17. DIRECT MARKETING AND COMMUNICATIONS

We may use your contact information to send service-related communications, recruitment updates, relevant employment opportunities or other information connected with your interactions with U-Connect.

We will send promotional communications only where permitted by applicable law and will obtain consent where required.

You may opt out of marketing communications at any time by using the unsubscribe facility provided in the communication, where available, or by contacting us directly.

Opting out of marketing communications will not prevent us from sending necessary administrative, contractual, security-related or other non-marketing communications.

18. CHANGES TO THIS PRIVACY POLICY

U-Connect may amend or update this Privacy Policy from time to time to reflect changes in our business operations, website functionality, technology, legal obligations or data protection practices.

The updated version will be published on our website with the revised “Last Updated” date.

Where required by law, we will provide additional notice or obtain consent before implementing changes that materially affect the processing of personal data.

We encourage you to review this Policy periodically to remain informed about how we protect personal data.

19. CONTACT US

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how your personal data is processed, you may contact U-Connect through the following channels:

U-Connect HR Limited Email: info@u-connect-ng.com

Office Address: 5 Ogbunike Street, Off Admiralty way, Lekki Phase 1, Lagos Telephone: