1. Introduction/Scope
This document is prepared in accordance with the provisions of the Nigeria Data Protection Act (NDPA), and by extension, the EU General Data Protection Regulation (GDPR). It sets out how BIT BENDER PRODUCTIONS LTD applies and complies with the data privacy principles in processing the personal data of customers, staff, vendors, visitors, and even third parties that interact with the COMPANY. For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed, in compliance with the NDPA. This privacy policy describes why and how we collect and use personal information about our customers, clients, vendors, and visitors (data subjects). It also highlights with whom we might share Personal Information and how long we keep such information. It also makes data subjects aware of their rights under the regulation.

2. Roles/Responsibilities
BIT BENDER PRODUCTIONS LTD Data Protection Officer (DPO) is responsible for ensuring that this document is correct and up-to-date. The DPO also ensures that data subjects are duly notified prior to the collection and processing of their personal data by the Company, including data collected via the Company’s website. All BIT BENDER PRODUCTIONS LTD employees/staff who interact with personal data must also ensure to follow the provisions in this policy document.

3. Policy Statement
BIT BENDER PRODUCTIONS LTD is committed to protecting the privacy and security of our personal data. We are responsible for determining how we hold and use personal information about our data subjects. According to the Nigeria Data Protection Act (NDPA), BIT BENDER PRODUCTIONS LTD is required to notify data subjects of the information contained in this document.

1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities
under the NDPA.

NDPA requires that personal data shall be:
a. Processed lawfully, fairly and in a transparent manner in relation to individuals.
b. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes, further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
c. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
d. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
e. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and privacy measures required by the NDPA in order to safeguard the rights and freedoms of individuals; and
f. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or necessary measures.

2. General provisions
a. This policy applies to all personal data processed by the Company
b. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The Company shall register with the National Data Protection Commission as a data controller that processes personal data, when it enters the threshold of a Major Data Processing-Ordinary High Level (MDP-OHL).

3. Data Subject Rights
At any point while BIT BENDER PRODUCTIONS LTD is in possession of or processing personal data, the data subject, has the right to: Request a copy of the information that the Company holds about them, Correct the data that is inaccurate or incomplete, Ask for their data to be erased from the Company’s systems/records, Restrict processing of their personal data where certain conditions apply.

4. Lawful purposes
a. All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
b. The Company shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt- in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.

5. Data minimization
The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. b. Purpose of Processing Data; Client’s record creation, identity verification and maintenance of records, Contract Vendor validation/information processing, Employment Contract.

6. Accuracy
a. The Company shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security
a. The Company shall ensure that personal data is stored securely using modern software and filing system that is kept up to date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
c. When personal data is deleted, this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.

9. Withdrawal of Consent
Withdrawal of Consent Irrespective of initial consent given, an individual can withdraw their consent at any time by making a withdrawal of consent request. The Company demonstrates the data subject (customer, client, visitor, vendor, staff, or third-party) has withdrawn consent to the processing of his or her personal data with a written instruction from the data subject. For child consent, the Company shall demonstrate that the holder of parental responsibility over the specified child has withdrawn consent via a written instruction from the parent. The Company will also demonstrate that reasonable efforts have been made to establish the authenticity of the parental responsibility, when withdrawing consent for the specified child, considering available technology. Where applicable, the Data Protection Officer will inform the relevant process owner of this change, and the processing activities that relied upon the consent is stopped immediately, in accordance with the relevant process

10. Use of Cookies
The Company’s website also uses cookies provided by trusted third parties, such as Google Analytics, to help us understand and improve users experience on the website. Company may use the information obtained from use of our cookies to: Recognize a computer when a user visits the Company’s website Track whoever navigates the website Improve the website’s usability (including Live Chat application to answer questions a user may have in real time and Analyze the use of its website – such as how many people visit it each day, and Manage the website. Users can disable cookies and prevent the setting of cookies by adjusting the settings on their browser. However, this is not recommended, as disabling cookies may also disable certain functionality and features of the site.

11. Disclosure to Third Parties
Aside situations where the Company may be required to disclose personal data of individuals in accordance with a legal obligation in response to requests by government authorities or law courts on matters involving national security or law enforcement requirements, the Company will not pass on its data subjects’ personal data to third parties without first obtaining consent. In situations where the processing of personal data will involve investigation of potential violations of the Company’s Terms of Service, security issues, management and the preservation of the rights and freedom of staff, customers, and clients, the Company shall establish an appropriate legal ground for such data transfers.