POLE LAND MANAGEMENT SYSTEM’S PRIVACY POLICY

This Privacy Policy ("Privacy Policy" or "Policy") describes how Pole Land Management Systems Limited (RC 9376052), its affiliates, subsidiaries, successors, assigns, contractors, subprocessors, service providers, professional advisers, and authorized representatives (collectively referred to as "Pole", "Company", "we", "our", or "us") collect, receive, access, record, organize, structure, store, adapt, retrieve, consult, use, disclose, transfer, analyze, combine, archive, secure, anonymize, pseudonymize, erase, destroy, and otherwise process Personal Data through the POLE Land Management Systems ("PLMS", "Platform", or "Services").

The Platform is a land administration, land management, plot allocation, estate management, geospatial visualization, fraud monitoring, revenue monitoring, client management, financial administration, and property information management solution designed for use by estate operators, developers, cooperatives, governmental institutions, land administrators, surveyors, property managers, organizations, and authorized users.

Because the Platform processes information relating to land management, geospatial coordinates, financial transactions, beneficiaries, administrators, users, government records, allocation records, audit logs, and other potentially sensitive information, Pole recognizes the importance of maintaining robust privacy, security, confidentiality, accountability, and governance standards.

This Policy has been developed to comply with:

• (a)the Nigeria Data Protection Act, 2023 ("NDPA");
• (b)regulations, directives, implementation frameworks, and guidance issued by the Nigeria Data Protection Commission ("NDPC");
• (c)applicable cybersecurity legislation;
• (d)applicable anti-money laundering, anti-corruption, and fraud prevention obligations;
• (e)contractual commitments entered into with customers;
• (f)applicable international privacy principles and industry best practices; and
• (g)any other applicable legal, regulatory, or contractual obligations governing the processing of Personal Data.

This Privacy Policy forms part of the contractual framework governing use of the Platform and should be read together with our Terms of Use and other related documents.

By accessing, registering for, subscribing to, integrating with, administering, uploading information to, or otherwise using the Platform, you acknowledge and agree that you have read, understood, and accepted this Privacy Policy.

If you do not agree to this Privacy Policy, you must immediately discontinue all access to and use of the Platform.

Pole is committed to ensuring that Personal Data is processed lawfully, fairly, transparently, securely, and responsibly.

In furtherance of this commitment, Pole endeavors to:

• (a)process Personal Data only where a lawful basis exists;
• (b)collect only information reasonably necessary for legitimate business purposes;
• (c)implement appropriate technical and organizational safeguards;
• (d)maintain accountability for processing activities;
• (e)respect the rights of Data Subjects;
• (f)implement privacy-by-design and privacy-by-default principles;
• (g)conduct risk assessments where appropriate;
• (h)maintain appropriate governance structures relating to data protection and information security;
• (i)promote confidentiality, integrity, availability, and resilience of systems and services; and
• (j)continually review and improve privacy and security controls.

The Parties acknowledge that the role assumed by Pole in relation to Personal Data shall depend upon the nature of the processing activity being undertaken.

In the majority of circumstances, customers utilizing the Platform determine the purposes for which Personal Data is collected, uploaded, stored, maintained, disclosed, and otherwise processed through the Platform.

Accordingly, customers will generally act as Data Controllers in respect of Personal Data submitted to the Platform, while Pole will generally act as a Data Processor providing technology, hosting, administration, analytics, monitoring, support, and related services.

Notwithstanding the foregoing, Pole may act as an independent Data Controller in relation to certain categories of processing undertaken for its own legitimate business purposes, including:

• (a)user account administration;
• (b)identity verification;
• (c)cybersecurity monitoring;
• (d)fraud prevention;
• (e)security investigations;
• (f)audit logging;
• (g)regulatory compliance;
• (h)legal claims management;
• (i)platform analytics;
• (j)service improvement;
• (k)business continuity activities;
• (l)incident response activities.

Where Pole and a customer jointly determine the purposes and means of processing Personal Data, the Parties may be considered Joint Controllers to the extent required by applicable law and may enter into additional arrangements governing their respective responsibilities.

For avoidance of doubt, Pole does not determine:

• (i)which individuals are entered into customer land registries;
• (ii)who owns land;
• (iii)who receives allocations;
• (iv)which ownership records are uploaded;
• (v)the legality or accuracy of customer records;
• (vi)the purposes for which customers maintain land administration records.

Customers remain solely responsible for ensuring that all Personal Data uploaded to the Platform has been lawfully collected, lawfully disclosed, and lawfully processed in accordance with applicable law.

Customers and users represent, warrant, and undertake that:

• (a)they possess all rights, permissions, authorities, notices, approvals, and lawful bases required to upload Personal Data to the Platform;
• (b)all Personal Data submitted to the Platform has been lawfully obtained;
• (c)all required notices have been provided to affected Data Subjects;
• (d)all necessary consents have been obtained where required;
• (e)processing activities carried out through the Platform comply with applicable law;
• (f)uploaded information is accurate, complete, and current.

Pole shall not be responsible for independently verifying the legality, accuracy, ownership, authenticity, or completeness of Personal Data submitted by customers or users.

Customers shall remain solely responsible for the lawfulness of information uploaded to the Platform.

For purposes of this Privacy Policy, the following terms shall have the meanings assigned to them below unless the context otherwise requires.

"Account" means a registered user profile created for the purpose of accessing the Platform.

"Authorized User" means any employee, consultant, contractor, representative, officer, administrator, agent, or individual authorized to access the Platform on behalf of a customer.

"Customer" means any organization, estate operator, estate management company, governmental authority, cooperative society, property developer, institution, or other entity utilizing the Platform.

"Data Subject" means an identified or identifiable natural person whose Personal Data is processed through the Platform.

"Personal Data" means any information relating to an identified or identifiable natural person, whether directly or indirectly identifiable.

"Sensitive Personal Data" means Personal Data requiring enhanced protection under applicable law and may include government-issued identification numbers, financial information, biometric information, precise geolocation data, criminal allegations, authentication credentials, and other categories protected by law.

"Geospatial Data" means information relating to geographic locations, coordinates, boundaries, maps, survey references, satellite references, GIS records, parcel references, and location-based information.

"Land Data" means all information relating to land ownership, occupancy, possession, allocation, reservation, subdivision, transfers, beneficiary rights, title records, plot records, and associated administrative information.

"Processing" means any operation performed upon Personal Data including collection, recording, storage, retrieval, consultation, use, disclosure, analysis, transmission, transfer, modification, deletion, destruction, or any other operation performed upon Personal Data.

"Platform" means the POLE Land Management System, including all websites, software applications, databases, APIs, analytics engines, fraud detection systems, client portals, administrative dashboards, and associated services.

Depending upon the nature of the services provided and the manner in which the Platform is utilized, Pole may process various categories of Personal Data.

The categories described below are illustrative and not exhaustive.

We may process information including:

• (a)full names;
• (b)maiden names;
• (c)aliases;
• (d)dates of birth;
• (e)gender information;
• (f)photographs;
• (g)signatures;
• (h)profile images;
• (i)employee identification information;
• (j)customer reference numbers.

Where necessary and lawful, we may process:

• (a)National Identification Numbers (NIN);
• (b)Tax Identification Numbers (TIN);
• (c)passport information;
• (d)driver's licence information;
• (e)voter identification information;
• (f)governmental registration numbers;
• (g)other government-issued identifiers.

Such information shall be processed only where reasonably necessary and lawful.

We may process:

• (a)residential addresses;
• (b)business addresses;
• (c)postal addresses;
• (d)telephone numbers;
• (e)mobile numbers;
• (f)email addresses;
• (g)emergency contact details;
• (h)next-of-kin information.

The Platform may process information concerning:

• (a)plot ownership;
• (b)co-ownership arrangements;
• (c)beneficiaries;
• (d)nominees;
• (e)allottees;
• (f)estate members;
• (g)legal representatives;
• (h)next-of-kin;
• (i)transferees;
• (j)assignors;
• (k)assignees.

We may process:

• (a)plot records;
• (b)allocation records;
• (c)reservation records;
• (d)transfer records;
• (e)ownership histories;
• (f)estate membership records;
• (g)title references;
• (h)survey references;
• (i)development records;
• (j)occupancy records.

The Platform may process:

• (a)Eastings;
• (b)Northings;
• (c)GPS coordinates;
• (d)GIS references;
• (e)boundary references;
• (f)cadastral references;
• (g)survey coordinates;
• (h)geolocation information;
• (i)mapping overlays;
• (j)parcel boundaries.

Users acknowledge that geospatial information may, in certain circumstances, constitute Personal Data where such information is capable of identifying an individual or revealing ownership relationships.

The Platform may process:

• (a)payment references;
• (b)receipt records;
• (c)invoices;
• (d)billing information;
• (e)transaction histories;
• (f)subscription information;
• (g)outstanding balances;
• (h)payment obligations;
• (i)financial summaries.

We may automatically collect:

• (a)IP addresses;
• (b)browser information;
• (c)operating system information;
• (d)device identifiers;
• (e)session identifiers;
• (f)access timestamps;
• (g)usage analytics;
• (h)authentication information;
• (i)network information;
• (j)system interaction records.

For security, compliance, forensic, operational, investigative, and accountability purposes, we may collect:

• (a)login histories;
• (b)logout histories;
• (c)user activity logs;
• (d)approval records;
• (e)modification histories;
• (f)allocation histories;
• (g)deletion records;
• (h)administrator activities;
• (i)failed login attempts;
• (j)access control records;
• (k)audit trails;
• (l)system-generated alerts.

We may process:

• (a)customer support requests;
• (b)complaints;
• (c)enquiries;
• (d)correspondence;
• (e)communications through the Platform;
• (f)feedback submissions;
• (g)service-related communications.

Where lawful and necessary, the Platform may process information attracting enhanced legal protection, including:

• (a)government-issued identifiers;
• (b)precise location information;
• (c)biometric information where implemented;
• (d)information relating to fraud investigations;
• (e)information required for legal compliance.

Such information shall be subject to enhanced security and governance controls.

Personal Data processed through the Platform may originate from a variety of sources.

Such sources may include:

• (a)Data Subjects themselves;
• (b)customers;
• (c)estate operators;
• (d)estate administrators;
• (e)developers;
• (f)cooperative societies;
• (g)governmental agencies;
• (h)land registries;
• (i)surveyors;
• (j)legal practitioners;
• (k)financial institutions;
• (l)payment service providers;
• (m)publicly available records;
• (n)third-party integrations;
• (o)identity verification providers;
• (p)authorized representatives of customers.

Where Personal Data is provided by third parties, the provider represents and warrants that it possesses lawful authority to provide such information.

Pole endeavors to integrate privacy considerations into the design, development, implementation, deployment, maintenance, and operation of the Platform.

Where reasonably practicable, Pole shall seek to ensure that:

• (a)Personal Data collection is limited to what is necessary;
• (b)access controls are appropriately configured;
• (c)retention periods are properly managed;
• (d)security controls are integrated into system architecture;
• (e)processing activities are documented;
• (f)risks to Data Subjects are considered during product development.

Privacy considerations shall be incorporated into business processes, technical systems, operational workflows, and governance structures where appropriate.

Pole processes Personal Data solely for legitimate, lawful, specified, explicit, and documented purposes.

Personal Data shall not be processed in a manner incompatible with the purposes for which it was collected except where such processing is otherwise authorized by applicable law.

Depending on the nature of the services provided, Personal Data may be processed for the following purposes.

Personal Data may be processed to:

• (a)create and administer user accounts;
• (b)authenticate users;
• (c)grant and manage permissions;
• (d)facilitate access to Platform functionality;
• (e)maintain customer profiles;
• (f)administer subscriptions;
• (g)provide technical support;
• (h)deliver requested services;
• (i)maintain operational continuity;
• (j)ensure proper functionality of the Platform.

Personal Data may be processed to:

• (a)manage estates;
• (b)administer plot records;
• (c)maintain ownership records;
• (d)process plot allocations;
• (e)process reservations;
• (f)maintain registries;
• (g)manage beneficiaries;
• (h)manage ownership transfers;
• (i)facilitate estate administration;
• (j)administer development records;
• (k)manage land inventory systems.

Personal Data and Geospatial Data may be processed to:

• (a)generate maps;
• (b)visualize estates;
• (c)display parcel information;
• (d)manage boundary information;
• (e)process coordinates;
• (f)support geospatial reporting;
• (g)facilitate land administration functions.

Users acknowledge that geospatial processing is an integral component of the Platform's functionality.

The Platform may process Personal Data to:

• (a)detect duplicate allocations;
• (b)identify suspicious ownership changes;
• (c)identify conflicting ownership records;
• (d)detect unusual user activity;
• (e)identify potentially fraudulent transactions;
• (f)investigate suspicious conduct;
• (g)prevent unauthorized access;
• (h)maintain system security;
• (i)prevent abuse of Platform services;
• (j)investigate security incidents.

Personal Data may be processed to:

• (a)maintain transaction records;
• (b)reconcile financial information;
• (c)generate invoices;
• (d)administer subscriptions;
• (e)track payment obligations;
• (f)manage outstanding balances;
• (g)produce financial reports;
• (h)administer customer accounts.

Personal Data may be processed to:

• (a)respond to inquiries;
• (b)investigate complaints;
• (c)resolve disputes;
• (d)provide technical support;
• (e)communicate service updates;
• (f)provide notifications;
• (g)administer customer relationships.

Personal Data may be processed to:

• (a)comply with legal obligations;
• (b)satisfy regulatory requirements;
• (c)respond to governmental requests;
• (d)comply with court orders;
• (e)establish legal claims;
• (f)defend legal claims;
• (g)enforce contractual rights;
• (h)satisfy audit requirements;
• (i)investigate misconduct.

Personal Data may be processed to:

• (a)improve Platform performance;
• (b)improve security controls;
• (c)improve user experience;
• (d)conduct analytics;
• (e)develop new features;
• (f)conduct research;
• (g)improve fraud detection systems;
• (h)improve geospatial services.

Personal Data may be processed for:

• (a)backup management;
• (b)disaster recovery planning;
• (c)business continuity measures;
• (d)system restoration activities;
• (e)resilience testing.

Pole shall only process Personal Data where a lawful basis exists under applicable law.

Personal Data may be processed where necessary for:

• (a)entering into contracts;
• (b)performing contractual obligations;
• (c)providing Platform services;
• (d)administering customer accounts;
• (e)fulfilling service requests.

Failure to provide required Personal Data may limit the Company's ability to provide certain services.

Personal Data may be processed where necessary to comply with:

• (a)statutory obligations;
• (b)regulatory requirements;
• (c)judicial directives;
• (d)court orders;
• (e)lawful governmental requests;
• (f)law enforcement requests;
• (g)tax obligations;
• (h)anti-money laundering obligations.

Personal Data may be processed where necessary for legitimate interests pursued by Pole, including:

• (a)fraud prevention;
• (b)cybersecurity;
• (c)service improvement;
• (d)operational management;
• (e)business administration;
• (f)legal risk management;
• (g)dispute resolution;
• (h)protection of assets;
• (i)protection of intellectual property;
• (j)enforcement of contractual rights.

Where processing is based upon legitimate interests, Pole shall seek to balance its interests against the rights and freedoms of affected individuals.

Where required by law, Pole may process Personal Data based upon consent.

Consent may be obtained through:

• (a)registration processes;
• (b)electronic acceptance mechanisms;
• (c)consent forms;
• (d)Platform settings.

Data Subjects may withdraw consent at any time, subject to legal and contractual limitations.

Withdrawal of consent shall not affect the lawfulness of processing undertaken before such withdrawal.

Personal Data may be processed where necessary to protect the vital interests of a Data Subject or another individual.

The Platform may utilize artificial intelligence technologies, machine learning systems, predictive analytics tools, automated monitoring systems, anomaly detection engines, and fraud detection algorithms.

Such technologies may be used to:

• (a)identify suspicious activities;
• (b)detect duplicate allocations;
• (c)identify anomalies;
• (d)assess operational risks;
• (e)improve security;
• (f)improve service delivery;
• (g)generate alerts;
• (h)support decision-making processes.

Users acknowledge that outputs generated by automated systems:

• (a)are informational in nature;
• (b)are probabilistic;
• (c)may contain inaccuracies;
• (d)are not legal determinations;
• (e)do not constitute professional advice;
• (f)do not establish wrongdoing.

Users shall not rely solely upon automated outputs when making decisions involving:

• (a)ownership rights;
• (b)legal rights;
• (c)property transfers;
• (d)disciplinary actions;
• (e)investigations;
• (f)financial determinations.

Independent human review should always be conducted.

Pole does not sell Personal Data.

However, Personal Data may be disclosed in the circumstances described below.

Personal Data may be disclosed to service providers assisting with:

• (a)cloud hosting;
• (b)infrastructure management;
• (c)cybersecurity services;
• (d)backup services;
• (e)analytics services;
• (f)communications services;
• (g)payment processing services.

All such providers shall be required to implement appropriate confidentiality and security measures.

Personal Data may be disclosed to:

• (a)lawyers;
• (b)auditors;
• (c)accountants;
• (d)insurers;
• (e)consultants;

where reasonably necessary.

Personal Data may be disclosed to customers, administrators, estate operators, and authorized users where necessary for operation of the Platform.

The Company may disclose Personal Data where required by:

• (a)regulators;
• (b)governmental agencies;
• (c)supervisory authorities;
• (d)law enforcement agencies;
• (e)courts;
• (f)tribunals.

Personal Data may be disclosed where reasonably necessary to:

• (a)protect rights;
• (b)investigate misconduct;
• (c)establish legal claims;
• (d)defend legal claims;
• (e)enforce agreements;
• (f)prevent fraud.

Pole shall retain Personal Data only for as long as reasonably necessary to fulfill legitimate business, contractual, legal, regulatory, operational, security, audit, dispute resolution, and compliance purposes.

Retention periods may vary depending upon the nature of the information, applicable legal obligations, customer requirements, risk considerations, and operational necessities.

In determining retention periods, Pole may consider:

• (a)legal obligations;
• (b)regulatory requirements;
• (c)contractual obligations;
• (d)dispute resolution requirements;
• (e)fraud investigation requirements;
• (f)audit requirements;
• (g)cybersecurity obligations;
• (h)operational requirements.

Subject to applicable legal requirements, the following retention periods may apply:

Account Information:Retained for a minimum of three(3) years.

Financial Records:Retained for a minimum of seven (7) years or such longer period as may be required by law.

Audit Logs:Retained for minimum of seven (7) years or for periods reasonably necessary for security, investigations, compliance, and dispute resolution.

Security Logs:Retained five (5) years from date of incident

Land Administration Records:Retained for as long as active and seven (7) years post termination.

Fraud Investigation Records:Retained for the duration of investigations and any related proceedings. It will also be retained for 7 years post event.

Pole reserves the right to suspend routine deletion schedules where information may be relevant to:

• (a)litigation;
• (b)arbitration;
• (c)investigations;
• (d)audits;
• (e)regulatory proceedings;
• (f)law enforcement inquiries;
• (g)governmental requests.

Users acknowledge that residual copies of information may remain in:

• (a)backup systems;
• (b)disaster recovery systems;
• (c)archival repositories;
• (d)security repositories;
• (e)audit systems.

Such copies may remain for operational, security, legal, and compliance purposes.

Pole maintains a risk-based information security program designed to protect the confidentiality, integrity, availability, resilience, and recoverability of information processed through the Platform.

Security measures may be reviewed, updated, strengthened, modified, supplemented, or replaced from time to time in response to evolving risks, technological developments, legal requirements, and operational needs.

Pole may implement technical safeguards including:

• (a)encryption technologies;
• (b)authentication controls;
• (c)role-based access controls;
• (d)logging systems;
• (e)intrusion detection systems;
• (f)monitoring technologies;
• (g)network security controls;
• (h)endpoint security controls;
• (i)vulnerability management controls;
• (j)backup systems.

Note: Users remain responsible for maintaining the confidentiality of authentication credentials.

The Platform may continuously monitor activities, transactions, user behavior, access attempts, network events, and system interactions for purposes including:

• (a)threat detection;
• (b)fraud prevention;
• (c)abuse prevention;
• (d)system security;
• (e)vulnerability identification;
• (f)incident investigation.

Users acknowledge and consent to such monitoring to the extent permitted by law.

Pole maintains procedures intended to identify, assess, contain, investigate, remediate, and respond to actual or suspected security incidents.

Response activities may include:

• (a)incident detection;
• (b)investigation;
• (c)containment;
• (d)eradication;
• (e)recovery;
• (f)remediation;
• (g)documentation;
• (h)post-incident review.

Where required by applicable law, Pole may notify relevant regulatory authorities regarding qualifying personal data breaches.

Where required by law and where applicable risk thresholds are met, Pole may notify affected individuals regarding qualifying breaches.

Any notification provided by Pole concerning a security incident or data breach shall not constitute an admission of fault, negligence, wrongdoing, liability, or legal responsibility.

Subject to applicable law, Data Subjects may possess certain rights concerning their Personal Data.

Such rights may be exercised subject to identity verification requirements, legal restrictions, competing legal obligations, and applicable exemptions.

Data Subjects may request access to Personal Data processed by Pole.

Data Subjects may request correction of inaccurate or incomplete Personal Data.

Data Subjects may request deletion of Personal Data where applicable legal requirements permit.

Pole may refuse deletion requests where retention is required by law, contractual obligations, dispute resolution needs, fraud investigations, regulatory obligations, or legitimate business purposes.

Data Subjects may request restriction of certain processing activities in circumstances recognized by law.

Data Subjects may object to certain processing activities where permitted by law.

Where applicable, Data Subjects may request transfer of eligible Personal Data.

Where processing is based upon consent, consent may be withdrawn at any time.

Data Subjects may lodge complaints with relevant supervisory authorities.

Requests concerning Personal Data may be submitted to Pole's Data Protection Officer.

Pole reserves the right to:

• (a)verify identity;
• (b)request supporting documentation;
• (c)decline fraudulent requests;
• (d)refuse requests where legally permitted;
• (e)charge reasonable administrative fees where permitted by law.

Pole endeavors to maintain appropriate governance structures designed to support compliance with privacy and data protection obligations.

Such governance measures may include:

• (a)appointment of responsible personnel;
• (b)privacy training;
• (c)compliance monitoring;
• (d)policy management;
• (e)privacy reviews;
• (f)risk assessments;
• (g)governance reporting.

Where processing activities are likely to result in elevated risks to individuals, Pole may conduct Data Protection Impact Assessments (DPIAs) or similar assessments.

Such assessments may consider:

• (a)privacy risks;
• (b)security risks;
• (c)proportionality;
• (d)necessity;
• (e)mitigation measures.

Pole may engage vendors, contractors, service providers, subprocessors, consultants, and third parties to support the provision of services.

Pole endeavors to implement reasonable due diligence procedures before engaging such parties.

Such procedures may include assessment of:

• (a)security controls;
• (b)privacy controls;
• (c)compliance capabilities;
• (d)contractual safeguards;
• (e)operational capabilities.

Pole may require such parties to maintain appropriate confidentiality, privacy, and security obligations.

The Platform is not intended for use by persons under eighteen (18) years of age.

Pole does not knowingly collect Personal Data directly from children unless authorized by applicable law.

Where Pole becomes aware that information has been collected unlawfully from a child, Pole may take reasonable steps to delete such information.

The Platform may integrate with third-party systems, applications, services, databases, payment providers, governmental systems, mapping services, analytics tools, identity verification services, and other technologies.

Pole does not control the privacy practices of independent third parties.

Users are encouraged to review the privacy policies of such third parties.

While Pole endeavors to implement reasonable technical and organizational measures designed to protect Personal Data, no software platform, network, cloud infrastructure, database, communication channel, or electronic system can be guaranteed to be completely secure.

To the fullest extent permitted by applicable law, Pole shall not be liable for unauthorized access, disclosure, loss, corruption, destruction, alteration, interception, delay, unavailability, or compromise of information arising from:

• (a)cyberattacks;
• (b)force majeure events;
• (c)internet failures;
• (d)telecommunications failures;
• (e)third-party failures;
• (f)customer actions;
• (g)user misconduct;
• (h)governmental actions;
• (i)events beyond Pole's reasonable control.

Nothing in this section shall exclude liability where such exclusion is prohibited by law.

Pole reserves the right to amend, modify, update, supplement, replace, or revise this Privacy Policy from time to time.

Updated versions shall become effective upon publication unless otherwise specified.

Continued use of the Platform after publication of revised versions constitutes acceptance of such revisions and the User(s) can choose whether or not to opt out.

Data Protection Officer

POLE Land Management Systems

Email: goodluck@poleapp.io

Support Email: support@poleapp.io

Website: poleapp.io

Business Address: House 328, Dantata Estate, Abuja, Federal Capital Territory, Nigeria.

Individuals who have concerns regarding privacy, data protection, security, or the exercise of privacy rights may contact Pole using the details above.

Where a Data Subject believes that Personal Data has been processed unlawfully, the individual may contact Pole for resolution.

Nothing in this Privacy Policy shall prevent a Data Subject from lodging a complaint with the relevant supervisory authority, including the Nigeria Data Protection Commission, where applicable.