Privacy Policy

Effective Date: 1st April, 2025
Last Updated: 7th April 2025

Welcome to Sivar Enterprises Ltd. ("Sivar", "we", "our", or "us"). This Privacy Policy outlines how we collect, use, process, disclose, and protect your information. This applies across all platforms and services operated by Sivar, including our websites, web applications, mobile apps, and software platforms like NasaraERP and the School Management Portal.

1. Scope and Applicability

This policy is designed to comply with:

The Nigeria Data Protection Regulation (NDPR)
The General Data Protection Regulation (GDPR – EU 2016/679)
International best practices in data privacy and information security

It applies to all users, clients, vendors, employees, and affiliates who interact with us or use our services.

2. Information We Collect

a. Personal Information

Full Name, Email Address, Phone Number
Business Information (Company name, contact persons, job titles)
Billing and financial information (e.g., bank details, transaction history)
Usernames, login credentials, and user account preferences
Uploaded files and documents

b. Technical and Usage Data

Device and browser type
IP address, location data
Operating system, system configuration, language preference
Log data including time and duration of access

c. Sensitive Information

Where required and with your explicit consent, we may collect sensitive data (e.g., biometric, medical, or institutional records) strictly for the purposes of service delivery.

3. How We Use Your Information

To provide and manage access to our platforms and services
To verify identity and onboard corporate clients
To issue invoices, process transactions, and manage billing
To offer customer service and respond to inquiries
To improve user experience, conduct analytics, and diagnose issues
To comply with legal, tax, regulatory, or contractual obligations
To prevent fraud and enhance cybersecurity
To send legally permitted marketing or service-related emails

4. Legal Grounds for Processing

We rely on lawful bases under applicable data protection laws, including:

Consent – where you have granted permission for processing
Contractual necessity – where processing is required to fulfill an agreement with you
Legal compliance – where data is needed to meet legal obligations
Legitimate interest – for legitimate operational needs balanced against your rights

5. Data Retention

We retain data for as long as necessary for the purposes outlined above. Retention periods vary by data type and use case, but no data is kept longer than required. We may archive data securely for backup, audit, or legal defense purposes.

6. Data Security

We use industry-standard security technologies and organizational measures including but not limited to:

Encryption (at rest and in transit)
Firewall and anti-malware protection
Access control and two-factor authentication
Regular backups and secure data storage
Internal security protocols and staff confidentiality agreements

7. International Data Transfers

Where data is transferred outside Nigeria or your jurisdiction, we ensure an adequate level of protection using recognized safeguards such as Standard Contractual Clauses (SCCs), adequacy decisions, or binding agreements with third-party providers.

8. Sharing and Disclosure

We may share your data with:

Authorized service providers under confidentiality obligations
Regulators or legal authorities when required
Partners and subcontractors involved in service fulfillment

We never sell your personal data. Any third-party data processing is governed by strict compliance agreements.

9. Your Rights

You are entitled to the following rights:

Access to your personal data
Correction or deletion of incorrect or outdated data
Withdrawal of previously given consent
Restriction or objection to processing where applicable
Data portability where technically feasible
Right to lodge complaints with data protection authorities

10. Cookies and Tracking

We use cookies to personalize content, analyze traffic, and improve security. You can disable cookies through your browser settings, though this may impact some features of our services.

11. Children's Privacy

We do not knowingly collect or solicit data from individuals under the age of 16 without appropriate parental or guardian consent.

12. External Links

Our platforms may contain links to third-party websites. We are not responsible for the privacy practices or content of external sites. Please review their privacy policies independently.

13. Policy Updates

We may revise this Privacy Policy from time to time. Material changes will be communicated on our website or via email. Continued use of our services after updates constitutes acceptance of the revised terms.

14. Contact Us

If you have any questions or requests regarding your data, please contact our Data Protection Officer:

Sivar Enterprises Ltd.
Data Protection Officer (DPO)
Email: [Insert email]
Phone: [Insert phone]
Address: [Insert physical address]

15. Governing Law

This Privacy Policy is governed by the laws of the Federal Republic of Nigeria. Disputes shall be resolved within Nigerian courts unless otherwise agreed by both parties in writing. This policy also respects international laws including GDPR where applicable.