Privacy at a glance
Claybarn Fronteira Limited (“Claybarn”, “we”, “us” or “our”) respects your privacy. We collect and use personal data so that we can provide our services, verify identity, prevent fraud, meet our legal and regulatory obligations, communicate with you and protect our systems.
We only use personal data where we have a lawful reason. We may share it with trusted service providers, financial institutions, professional advisers and public authorities where necessary. We use safeguards for international transfers and keep information only for as long as it is needed or legally required.
You have rights over your personal data, including rights to access and correct it and, in appropriate cases, ask for deletion, restrict or object to its use, withdraw consent and challenge certain automated decisions.
Questions or requests can be sent to our Data Protection Officer at dpo@claybarn.ng.
About this notice
This Privacy Notice explains what personal data Claybarn collects, where we get it, why we use it, who we may share it with, how long we keep it and the rights available to you.
Claybarn is responsible for deciding how and why personal data covered by this notice is used. Under the Nigeria Data Protection Act 2023 (“NDPA”), this generally means that Claybarn acts as a data controller.
This notice applies to clients and prospective clients, suppliers and business contacts, people who use our website or digital services, and other individuals whose personal data we process in connection with our business. Separate privacy information may apply to employees and job applicants.
Personal data we may collect
The information we collect depends on your relationship with Claybarn and the services involved. It may include:
- Identity and contact information, such as your name, date of birth, gender, nationality, address, email address, telephone number, photograph, signature and identification document details.
- Financial and transaction information, such as bank account details, payment information, transaction history and other financial information relevant to our services.
- Client and service information, including information about your account, products or services, preferences and communications with us.
- Compliance information used for know-your-customer (KYC), anti-money laundering (AML), sanctions, fraud prevention and other regulatory checks.
- Technical information, such as your IP address, device information, browser information, login or access records and cookies when you use our website or digital services.
- Other information that you provide to us or that we are required or permitted by law to collect.
Some personal data is treated as sensitive under the NDPA. Where we process sensitive personal data, we do so only where the law permits and we apply appropriate safeguards.
Where we get your personal data
We may collect personal data directly from you when you contact us, apply for or use our services, complete forms, provide identification documents or communicate with us.
We may also receive information from authorised representatives, employers or business partners; banks and other financial institutions; identity-verification, KYC, AML, sanctions-screening and fraud-prevention providers; public registers and publicly available sources; and regulators or other public authorities where permitted by law.
Why we use your personal data
We use personal data only where we have a lawful basis under the NDPA. Depending on the circumstances, this may be your consent, the performance of a contract, compliance with a legal obligation, protection of vital interests, a task carried out in the public interest, or our legitimate interests where the legal requirements for relying on those interests are met.
Providing our services
We may use your information to consider applications, open and manage accounts or client relationships, provide services, process payments or transactions, respond to requests and communicate with you. We generally do this because it is necessary to take steps at your request or to perform a contract with you.
Identity checks, fraud prevention and regulatory compliance
We may use personal data to verify identity, carry out KYC and AML checks, screen for sanctions or other financial crime risks, prevent and investigate fraud, and meet legal or regulatory requirements. We generally do this because the law requires it or, where appropriate, because we have a lawful legitimate interest in protecting our clients and business.
Managing our business
We may use business contact and communications information to manage relationships with clients, prospective clients, suppliers and other business contacts, improve our services, maintain appropriate records and protect our legal rights. Where we rely on legitimate interests, we consider the need for the processing and its impact on your rights.
Consent
Where we rely on your consent, we will explain what you are agreeing to. You may withdraw your consent at any time. Withdrawal does not affect processing that was lawful before you withdrew consent, and another lawful basis may still allow or require us to keep or use some information.
Marketing
Where permitted by law, we may send you information about Claybarn’s products, services or features. You may object to direct marketing at any time by using the unsubscribe option in a message or contacting us.
Artificial intelligence and automated processing
Claybarn may use artificial intelligence (AI) and machine-learning tools for purposes described in its existing policy, including fraud detection, customer support, personalised experiences or recommendations, and testing or improving financial technology features.
Claybarn may use anonymised or pseudonymised information where appropriate.
We only use personal data with these tools where we have a lawful basis and apply appropriate privacy and security measures. We limit the information used to what is reasonably necessary for the stated purpose.
Automated decisions
If Claybarn makes a decision about you solely through automated processing, including profiling, and that decision produces legal or similarly significant effects, the NDPA gives you protections. Where applicable, you may have the right to obtain human intervention, give your point of view and contest the decision.
Who we may share your personal data with
We do not share personal data without a proper reason. Where necessary for our services or legal obligations, we may share information with:
- banks, payment providers and other financial service providers;
- identity-verification, KYC, AML, sanctions-screening and fraud-prevention providers;
- IT, cloud, cybersecurity, communications and other technology providers;
- lawyers, auditors, accountants, consultants and other professional advisers;
- companies or business partners involved in providing a service to you, where applicable; and
- the Nigeria Data Protection Commission, other regulators, tax authorities, courts, law-enforcement agencies or other public authorities where required or permitted by law.
Where another organisation processes personal data on our behalf, we require appropriate contractual and security protections.
International transfers
Some service providers or other recipients may be located outside Nigeria or may access personal data from another country.
Where personal data is transferred outside Nigeria, Claybarn will use a transfer basis or safeguard permitted by the NDPA and applicable regulatory requirements. Depending on the circumstances, this may include a transfer to a country or recipient recognised as providing adequate protection, appropriate contractual or organisational safeguards, or another lawful basis permitted by the NDPA.
You may contact our Data Protection Officer for more information about the safeguards that apply to your personal data.
How long we keep personal data
We keep personal data only for as long as it is needed for the purpose for which it was collected or to meet legal, regulatory, tax, accounting, security, dispute-resolution or recordkeeping requirements.
The exact period depends on the type of information and the applicable legal or business requirement. When information is no longer needed, we securely delete or anonymise it unless the law requires or permits us to keep it for longer.
How we protect personal data
We use appropriate technical and organisational measures to protect personal data against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure. These measures may include access controls, encryption, pseudonymisation, monitoring, secure audit trails and restrictions on who can access personal data.
We also review privacy and security risks when introducing new or high-risk processing activities, including relevant AI or profiling activities.
Your rights
Subject to the conditions and exceptions in the NDPA, you may have the right to:
- ask whether we process your personal data and request access to it;
- ask us to correct inaccurate or incomplete personal data;
- ask us to delete personal data in circumstances where the law gives you that right;
- ask us to restrict certain processing;
- object to certain processing, including direct marketing;
- withdraw consent where our processing is based on consent;
- exercise applicable rights relating to data portability; and
- obtain human intervention, express your point of view and contest certain decisions made solely by automated processing.
These rights are not absolute. For example, Claybarn may need to keep information to comply with a legal or regulatory obligation.
To exercise a right, contact our Data Protection Officer at dpo@claybarn.ng. We may ask for information needed to confirm your identity before acting on your request. We will respond within the period required by applicable law.
Complaints
If you are concerned about how we use your personal data, please contact our Data Protection Officer at dpo@claybarn.ng so that we can consider your concern.
You also have the right to make a complaint to the Nigeria Data Protection Commission (NDPC), the data protection regulator in Nigeria.
Changes to this notice
We may update this Privacy Notice when our services, processing activities or legal and regulatory requirements change. The latest version will be published on our website and will show the date it was last updated.
Contact us
Data Protection Officer
Claybarn Fronteira Limited
Address: 8 Lake Chad Crescent, Maitama, Abuja
Email: dpo@claybarn.ng