Privacy Policy

About Our Privacy Policy

As part of our operations, DutiPro ("DutiPro", "the Company", "We", "Us" or "Our") collects and processes your personal data. DutiPro is firmly committed to protecting your personal data and complying with applicable data protection laws, regulations, rules and principles to ensure security of personal data handled by us.

This Privacy Policy ("Policy") explains the data processing practices of DutiPro, the minimum standards that must be strictly adhered to regarding the collection, use and disclosure of your personal data and describes your rights as a user of our DutiPro Application (App), web portal, website or any other individual whom DutiPro communicates or deals with, jointly and/or severally. The Policy describes the information we collect, how we collect, use, store, secure and share the information.

Legal Basis For Processing Of Personal Data

In line with the provisions of the NDPR (Nigeria Data Protection Regulation), DutiPro will process your personal data based on any of the following:

• Where you give us your consent to process your personal data for one or more specific purposes. A user who has provided consent to processing of their personal data can withdraw such consent at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data if no other legal basis can be relied upon;
• Where the processing is necessary for the performance of a contract concluded between you and DutiPro;
• Where processing is necessary for DutiPro to comply with a legal obligation, to which DutiPro is subjected to;
• Where it is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in DutiPro; and
• Where the processing is necessary in order to protect your vital interests or the vital interests of another natural person.

Where DutiPro processes your personal data based on consent, DutiPro will ensure:

• that the specific purpose of collection is made known to you and the consent is requested in a clear and plain language;
• that the consent is freely given and obtained without fraud, coercion or undue influence;
• that the consent is sufficiently distinct from other matters to which you agreed;
• that the consent is explicitly provided in an affirmative manner;
• that consent is obtained for each purpose of personal data collection and processing; and
• that it is clearly communicated to and understood by you that you can update, manage or withdraw your consent at any time.
• that services are not offered directly to minors (under the age of 18), under no circumstances.

Purpose Limitation

DutiPro limits Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. DutiPro will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized data must be used.

Data Minimization

DutiPro limits Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. DutiPro will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized data must be used.

Information We Collect About You

The following are data collected and processed by DutiPro:

When a user creates a DutiPro account, either as an employer using the DutiPro platform for task and employee management, or as an employee working for an employer using DutiPro, or provides personal data through the web portal or admin panel, or otherwise provides DutiPro with personal information through the App, web portal, website or by any other means, the personal information DutiPro collects may include:

• Name, phone number and email address
• Home and/or work address
• User profile data including gender and date of birth
• Payment information and transaction details, which is processed through a third party. Please note that DutiPro does not keep or store debit or credit card details of users.
• Location data, we use to track tasks and assist with navigation
• Usage data
• Transaction information
• Information relating to customer support
• Employee records and task management data
• Employer business details and subscription information
• Analytics and performance reports

Purpose of Collection

• We collect Employer and Employee profile data and contact details to establish and maintain accounts; verify user identity; communicate with users about their accounts, tasks, and subscriptions; and enable users to make payments.
• We use location data to track tasks and assist with navigation to enhance task management and delivery services.
• We use usage data, to maintain, optimize, and enhance DutiPro services, including to connect employers with employees and manage task assignments.
• Information relating to customer support is used to resolve disputes and queries.
• We use payment information and transaction details, which is processed through a third party service provider, to process users' payment for our services.

Who We Share Your Information With

DutiPro may engage the services of third parties in order to process your personal data. The processing by such third parties shall be governed by a written contract with DutiPro to ensure adequate protection and security measures are put in place by the third party for the protection of personal data in accordance with the terms of this Policy and the NDPR.

User contact information such as name, phone number, and location is shared with employers, employees, and our staff for the purpose of fulfilling task assignments and consummating transactions through the platform.

DutiPro may also share personal data with law enforcement agencies regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. DutiPro may also share information with public health authorities where required or permitted by law.

Transfer of Personal Data to Foreign Country

Where personal data is to be transferred to a country outside Nigeria, DutiPro shall put adequate measures in place to ensure the security of such personal data. In particular, DutiPro shall, among other things, conduct a detailed assessment of whether the said country is on the National Information Technology Development Agency (NITDA) White List of Countries with adequate data protection laws.

Transfer of personal data out of Nigeria would be in accordance with the provisions of the NDPR. DutiPro will therefore only transfer Personal Data out of Nigeria on one of the following conditions:

• The consent of the customer or user has been obtained;
• The transfer is necessary for the performance of a contract between DutiPro and the customer or user or implementation of pre-contractual measures taken at the customer or user's request;
• The transfer is necessary to conclude a contract between DutiPro and a third party in the interest of the customer or user;
• The transfer is necessary for reason of public interest;
• The transfer is for the establishment, exercise or defense of legal claims;
• The transfer is necessary in order to protect the vital interests of the customer or user or other persons, where the customer or user is physically or legally incapable of giving consent.

Provided, in all circumstances, that the customer or user has been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where the customer or user is answerable in duly established legal action for any civil or criminal claim in a third country.

DutiPro will take all necessary steps to ensure that your personal data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Nigeria shall be provided to you upon request.

Where the recipient country is not on the White List and none of the conditions stipulated in this Policy is met, DutiPro will engage with NITDA and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer.

Personal Data Retention and Deletion

All personal information shall be retained, stored and destroyed by DutiPro in line with legislative and regulatory guidelines. DutiPro retains user data for as long as necessary for the purposes described. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data. To the extent permitted by applicable laws and without prejudice to DutiPro's Document Retention Policy, the length of storage of personal data shall, amongst other things, be determined by:

• the contract terms agreed between you and DutiPro or users or as long as it is needed for the purpose for which it was obtained; or
• whether the transaction or relationship has statutory implication or a required retention period; or
• whether there is an express request for deletion of personal data from you provided that such request will only be treated where you are not under any investigation which may require DutiPro to retain such personal data or there is no subsisting contractual arrangement with you that would require the processing of the personal data; or
• whether DutiPro has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

Notwithstanding the foregoing and pursuant to the NDPR, DutiPro shall be entitled to retain and process personal data for archiving, scientific research, historical research or statistical purposes for public interest.

DutiPro would forthwith delete personal data in DutiPro's possession where such personal data is no longer required by DutiPro or in line with DutiPro's Retention Policy, provided no law or regulation being in force requires DutiPro to retain such personal data.

Your personal data will be stored for as long your accounts are active. However, you may request deletion of your account at any time through the Settings in the DutiPro App, or web portal or through DutiPro's website. Following an account deletion request, DutiPro deletes your account and data; otherwise, the personal data would be retained in line with legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user's account such as an unresolved claim or dispute.

Please note that the de-installation of DutiPro App in your device does not cause the deletion of your personal data.

Data required for accounting purposes/business records will be stored for at least 6 years from the date of collection in accordance with the Section 375(2) of the Companies and Allied Matters Act (CAMA).

Data Accuracy and Correction

DutiPro is committed to keeping your personal data accurate and up-to-date. In this regard, DutiPro shall:

• ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to you;
• make efforts to keep personal data updated where reasonable and applicable; and
• make timely efforts to correct or erase personal data when inaccuracies are discovered.

You can access and update or correct your personal data via our App or web portal as applicable.

Lawfulness, Fairness and Transparency

Personal Data must be processed lawfully, fairly and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of DutiPro must be in accordance with the specific, legitimate and lawful purpose consented to by you, save where the processing is otherwise allowed by law or within other legal grounds recognized in the NDPR.

Integrity and Confidentiality

DutiPro shall establish adequate controls in order to protect the integrity and confidentiality of Personal Data to prevent personal data from being accidentally or deliberately compromised. Personal data would be protected from unauthorized viewing or access and from unauthorized changes to ensure that it is reliable and correct.

Employees may have access to Personal Data only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Data for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.

Personal Data Security

DutiPro will ensure that appropriate measures are employed against unauthorized access, accidental loss, damage and destruction to your personal data. This includes the use of password encrypted databases for digital storage.

To ensure security of personal data, DutiPro will, among other things, implement the following appropriate technical controls:

• Industry-accepted hardening standards, for workstations, servers, and databases.
• Full disk software encryption on all corporate workstation/laptops operating systems drives storing personal data.
• Encryption at rest including key management of key databases.
• Enable Security Audit Logging across all systems managing personal data.
• Restrict the use of removable media such as USB flash disk drives.
• Anonymization techniques on testing environments;
• Physical access control where personal data are stored in hardcopy.

Direct Marketing

We will only send you direct marketing messages via email or phone number, App, web portal or website as applicable.

Marketing opt-outs: You may opt out of receiving promotional emails from DutiPro. You may also opt out of receiving emails and other messages from DutiPro by following the unsubscribe instructions on messages on our App or web portal. We will however, send you non-promotional communications, such as receipts for transactions or information about their account.

Data Subject Rights

All individuals who are the subject of personal data held by DutiPro are entitled to the following rights:

• Right to information on their personal data collected and stored;
• Right to request for and access their personal data collected and stored. Right to receive data in a common electronic format, where such data is held electronically in a structured form, such as in a Database,
• Right to objection or request for restriction;
• Right to object to automated decision making;
• Right to request rectification and modification of their data which DutiPro keeps;
• Right to request for deletion of their data, except as restricted by law or DutiPro's statutory obligations;
• Right to request the movement of data from DutiPro to a Third Party; this is the right to the portability of data; and
• Right to object to, and to request that DutiPro restricts the processing of their information except as required by law or DutiPro's statutory obligations.

You can exercise any of your rights by sending an email to the Data Protection Officer of the Company at the contact information provided in the "Contact Us" section below.

Changes to the Policy

DutiPro reserves the right to change, amend or alter this Policy at any point in time. If we amend this Policy, we will provide you with the updated version.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, or to exercise any of your data subject rights, please contact us:

General Information