Carolus Services Ltd. (“Carolus Services,” “we,” “us,” or “our”) is committed to protecting the privacy of visitors to www.carolusservices.com (the “Site”) and clients who engage our compliance and data analysis consultancy services (the “Services”). This Privacy Policy explains how we collect, use, disclose, and protect Personal Data, and your rights under the Nigeria Data Protection Act 2023 (“NDPA”) and applicable regulations issued by the Nigeria Data Protection Commission (“NDPC”).
Carolus Services Ltd. is the data controller responsible for Personal Data collected through the Site and in the course of client engagements, unless otherwise specified in a client-specific data processing agreement.
We process Personal Data on one or more of the following bases under the NDPA: your consent; performance of a contract with you or your organisation; compliance with a legal obligation; or our legitimate interests in operating and promoting our business, provided these interests are not overridden by your rights and freedoms.
The Site may use cookies and similar technologies to support functionality and analyse traffic. You can control cookies through your browser settings; disabling cookies may affect some features of the Site.
We do not sell Personal Data. We may share Personal Data with:
Where Personal Data is transferred outside Nigeria (for example, to cloud service providers), we take steps required under the NDPA to ensure an adequate level of protection, including contractual safeguards, before making such transfers. Where we transfer Personal Data originating from the EEA, UK, or Switzerland to a country not deemed adequate by the relevant authority, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses or the UK International Data Transfer Addendum, as applicable.
We retain Personal Data only for as long as necessary to fulfil the purposes described in this Policy, including to satisfy legal, accounting, or reporting requirements, after which it is securely deleted or anonymised.
We implement appropriate technical and organisational measures to protect Personal Data against unauthorised access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
Subject to applicable law, you may have the right to:
To exercise these rights, contact us using the details in Section 15.
Where we process Personal Data of individuals located in the European Economic Area or the United Kingdom, we do so in accordance with the EU General Data Protection Regulation (“GDPR”) and/or the UK GDPR, as applicable, in addition to the NDPA.
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), gives you additional rights over Personal Data (referred to under that law as “personal information”).
To exercise these rights, contact us using the details in Section 15. We will verify your request using information reasonably necessary to confirm your identity before responding.
The Site and Services are not directed at children, and we do not knowingly collect Personal Data from individuals under the age of 18 without appropriate consent as required by the NDPA.
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on the Site with a revised Effective Date.
If you have questions about this Privacy Policy or wish to exercise your data protection rights, contact:
Carolus Services Ltd.
Abuja, Nigeria
NDPC Registration: [would insert registration category and number, e.g., Data Controller/Processor of Major Importance / DPCO registration no. [insert]]
Data Protection Contact / DPO: [would insert name/title and email, if a DPO has been appointed]
Email: support@carolusservices.com
Website: www.carolusservices.com