1. Introduction

FBN Insurance Brokers Limited (“FBN Insurance Brokers”, “We”, “Us”, or “Our”) is a wholly owned subsidiary of the FBN Holdings that combines expert broking knowledge and capabilities for risk assessment, analysis, structuring and overall servicing that has resulted in increased insurance portfolios. We have the reputation, expertise and unrivalled experience in Energy Insurance, Oil and Gas, sophisticated/Complex Risk Management and Re-insurance services and these operational and corporate alliances with the international Brokers are geared towards building infrastructure for the industry in terms of capabilities, skills, knowledge update, improved professionalism and best business practice possible.

This Privacy Notice (“Notice”) governs your use of our Website: https://www.fbninsurancebrokers.com/  (“the Website) and your rights regarding our collection, use, storage protection of your data. Your privacy is important to us.  

2. Your personal data that we process

Personal data means any information about an individual from which that person can be directly or indirectly identified. While using the Website, we may ask you to provide us with certain personal data directly to contact or identify you, and some automatically for our Website to function effectively. Personal data include:

• Your name; 
  
• Your email address; 
  
• Contact number; 
  
• Location
  
• The IP address used to connect your device to the internet for identification purpose;
  
• Login email address and password;
  
• Name of the internet service provider (ISP);
  
• Date and time of visit; and
  
• Web pages visited, duration and frequency of visit.

3. Cookies 

We do not use cookies on this website.

4. Principles of processing your data

We process your data using the following principles:

• Personal data will be processed in a fair, lawful and transparent manner;
  
• Personal data will be processed for a specific purpose and not in a way that is incompatible with the purpose with which it is collected;
  
• Processing of personal data is adequate, relevant and limited to what is necessary for the purposes it is processed;
  
• Your personal data will be kept accurate and, where necessary, kept up to date;
  
• Your personal data will be held for no longer than it is required for the purposes for which it is processed;
  

We will take appropriate steps to keep your data secure.
5. Purpose of processing your data and the lawful basis

We collect your data:

6. What constitutes consent?

We will not ask for your data unless we need it to provide services to you. At any point where consent is the appropriate lawful basis for processing your data, we will give you the option to either accept or reject. Whenever we introduce new services and technologies, we will ensure you understand and agree to any new ways in which your information will be processed.

If you have previously given consent to our processing your data, you can freely withdraw such consent at any time. You can do this by emailing us at Fibdpo@fbninsurancebrokers.com.

7. How to withdraw your consent

If after you opt-in, you change your mind, you may withdraw your consent to the continued processing of your data, at any time, by contacting us.

However, we should mention that withdrawal of consent would not affect the lawfulness of any processing carried out before you withdraw your consent.

8. Your rights as a data subject

As a data subject, the law vests you with certain rights—they include the right to: 

1. access personal data we hold about you by requesting a copy of the personal data we hold about you; 
   
2. rectify such information where you believe it to be inaccurate; 
   
3. restrict the processing of your data in certain circumstances; 
   
4. object to the processing of your data where we intend to process such data for marketing purposes; where feasible, receive all personal data you have provided to us—in a structured, commonly used, and machine-readable format—and to transmit the information to another data controller; 
   
5. request the erasure of your data (also known as the right to be forgotten);
   
6. request the portability of your data; and
   
7. lodge a complaint with a relevant authority, where you have reason to believe that we have violated the term(s) of this Privacy Notice. (You may complain or seek redress from us within 30 days from the time you first detected the alleged violation.).
   

You may seek to exercise any of the above rights at any time by sending us an email at Fibdpo@fbninsurancebrokers.com.

The supervisory authority is the National Information Technology Development Agency (NITDA), and the complaint can be sent via email at dpo@nitda.gov.ng 

 9. Who we share your data with

We share your data with the following third parties:

• Google: because we use various Google APIs and services on our Website.
  
• Legal / Regulatory Authority – We may disclose your data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, audit, or to protect the safety of any person, to address fraud, security or technical issues.
  

10. Retention of your data

Your personal data or any other information collected will be stored for as long as necessary to fulfil the purposes described in this Notice. However, we will also retain data subject to relevant provisions of applicable laws, resolve disputes, and enforce our legal agreements and policies. We delete your data for targeted marketing purposes once you unsubscribe from our marketing communications.

Please note that your data may be retained for a more extended period, notwithstanding your request to remove your data, where there is a legal requirement to do so.

11. How your data is stored

We store and process your data on. We protect your data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls, and information access authorisation controls.

Where there is an actual or suspected data breach capable of causing harm to your rights and freedoms, we will notify you without undue delay and use our best effort to remedy the violation within one (1) month from the date we notify you.

12. International transfer of data

To achieve the purposes described in this Notice, we may transfer your data to countries that may not offer an adequate protection level or not considered to have sufficient law by the National Information Technology Development Agency (NITDA). Where personal data is to be transferred to a country outside Nigeria, we shall put adequate measures to ensure data security. 

Our data transfers to the countries that do not offer an adequate protection level are subject to the conditions under the Nigeria Data Protection Regulation (NDPR). We will therefore only transfer Personal Data out of Nigeria on one of the following conditions:

• Your consent has been obtained;
  
• The transfer is necessary for the performance of a contract between Us and you  or implementation of pre-contractual measures taken at your request;
  
• The transfer is necessary to conclude a contract between Us and the third party in your interest;
  
• The transfer is necessary for reason of public interest;
  
• The transfer is for the establishment, exercise or defence of legal claims;
  
• The transfer is essential to protect your vital interests or other persons, where the Data Subject is physically or legally incapable of giving consent.
  

To obtain any relevant information regarding any transfers of your Personal Data to third countries (including the appropriate transfer mechanisms), please contact us.

13. Marketing and communications

We only send marketing communications to you with your consent. You may choose to opt out of our marketing emails by clicking on the ‘unsubscribe button at the bottom of the page. 

14. Security of your data

We are very particular about preserving your privacy and protecting your data. We deploy all reasonable and appropriate technical and organisational measures to keep your data safe. However, we cannot completely guarantee the security of any information you transmit via our Website, as the internet is not an entirely secure place. We are committed to doing our best to protect you.

15. Complaints

If you are concerned about an alleged breach of privacy law or any other regulation by us, you can contact the Data Protection Officer (DPO) via Fibdpo@fbninsurancebrokers.com The DPO will investigate your complaint and provide information about how your complaint is handled.

Please be informed that you may complain to the relevant data protection authority where your complaints are not satisfactorily addressed.

16. Changes to this notice

We update our privacy policy from time to time. We will notify our users when we change it, and visitors will know this by checking the last date of update on this page whenever you visit.

17. Contact Us

If you have any questions relating to this Notice, you can reach us via Fibdpo@fbninsurancebrokers.com