Who We Are?
C & I Leasing Plc, a Nigerian publicly listed company and Nigeria’s largest integrated leasing and
business services conglomerate founded in 1990, serves its clients through four business lines;
Fleet Management, Outsourcing, Marine Services and Citracks (Telematics) with two subsidiaries
in Ghana (Leasafric) and the United Arab Emirates (EPIC International FZE).
Personal Data?
Under the Nigeria Data Protection Act /Act (NDPA) personal data is defined as:
“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
How We Use Your Information?
This Privacy Policy tells you how we, C&I Leasing, will collect and use your personal data for relationship management, business analytics/development, communication, registration, cookies, and all-round efficient service delivery.
How Will C&I Leasing Use the Personal Data It Collects About Me?
We will process (collect, use and store) the information you provide in a manner that complies with the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Act/Act (NDPA). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. C&I Leasing is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. The retention period for certain kinds of personal data may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
What Personal Data Do We Need?
The personal data we would collect and process, depending on the particular processing requirement, are under the following categories:
| Personal Data Type | Sources |
| Name | Provided by the user during registration or inquiry |
| Phone number | Provided by the user during registration or communication |
| Email address | Collected through user sign-up, inquiries, or subscriptions |
| Cookie Identifier | Captured automatically via website or app interactions |
| Advertising identifier of your phone | Collected through mobile device settings or app usage |
| Employment Details | Collected during job applications or onboarding |
Why Do We Need the Data?
We need to collect your personal data in order for us to provide you with our services. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose(s) only, and will in no way invade your privacy. If there is a need to use your personal data for marketing purpose, C&I Leasing will ensure to seek additional consent from you. C&I Leasing shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:
| Purpose of Processing |
Lawful Basis of Processing |
| To register you as a new user on the site or Apps |
We need to process this information to meet our contractual obligations. |
| To allow you to use our products |
We need to process this information to meet our contractual obligations and to comply with our legal and regulatory obligations |
| To communicate with you about any new update on our site, products and any changes to our terms and conditions or Privacy Policy | We need to process this data to meet our contractual obligations; to comply with our legal obligations; and it is our legitimate interest to keep accurate records. |
| To receive feedback from you about our products | We need to process this data to meet our contractual obligations and it is our legitimate business interest to understand how we can improve our products and services. |
| To provide customer support services | It is in our legitimate business interests to respond to any communications we receive from you. If you do not provide us with this information, we would not be able to identify you as our customer. |
| Payment of staff salaries | We need to process this information to meet contractual obligation we both agreed on. |
Where Legitimate Interest is considered the legal basis for processing personal data, C&I Leasing shall follow the steps below in carrying out a Legitimate Interest Assessment.
1. Determine the Purpose for Processing
In carrying out the purpose test, C&I Leasing must establish the exact reason for the processing and how it benefits the organisation. Answers to the following shall be provided to determine the exact purpose for processing:
• Description of the processing objective
• The likelihood of meeting the objective and how to determine if the objective was met
• The benefit of the processing and the significance to the organisation
• Description of the possible impact of not processing and any other issues that might be relevant
2. Determine the Necessity of the Processing
C&I Leasing must establish why the processing must take place, how the processing relates to the expected benefits, and any other alternatives and why there were not considered.
3. Balance the identified interest with the Privacy Interest of the Data Subjects
The following questions will be addressed under the balance test:
• Who are the data subjects (category)?
• What is the relationship between C&I Leasing and the data subject?
• What personal data is to be processed?
• How will the processing impact the data subject?
• How will the data subject react to the processing?
C&I Leasing records this information in line with this policy, data protection impact assessment, and data inventory.
Consent
C&I Leasing requires your explicit consent to process collected personal data. And by consenting to this privacy policy, you are giving us the permission to use/process your personal data specifically for the purpose identified before collection.
If, for any reason, C&I Leasing is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.
You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the C&I Leasing Withdrawal of Consent Procedure.
Disclosure: Will C&I Leasing Share My Personal Data with Anyone Else?
C&I Leasing may pass your personal data to third-party service providers contracted by us. Any third parties that we may share your personal data with is under an obligation to secure your details, and use them only to fulfil the service for which they were contracted. When they no longer need your details to fulfil this service, the data will be disposed in line with the C&I Leasing’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are required to do otherwise, legally.
Where there is a need for a third party to process the personal data of data subjects, C&I Leasing will enter into a Data Processing Agreement with the third party and be satisfied that the third party has adequate measures in place to protect the data against accidental or unauthorised access, use, disclosure, loss, or destruction.
In a case where the disclosure is to third parties outside the jurisdiction of the GDPR and NDPA, C&I Leasing will ensure that the third party meets the core regulatory standards prior to the transfer. This may include transferring the personal data to the third party where C&I Leasing has satisfied that:
• the country of the recipient has adequate data protection controls established by legal or self-regulatory regime
• C&I Leasing has a contract in place that uses existing or approved data protection clauses to ensure adequate protection
• C&I Leasing is making the transfer under approved binding corporate rules
• C&I Leasing is relying on approved codes of conduct or certification mechanisms, together with binding and enforceable commitments in the foreign country or international organisation to apply the appropriate safeguards in relation to data subject rights
• Provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority
Retention Of Records
In line with the NDPA data retention policy, C&I Leasing will process and retain your personal data only for the period necessary to fulfill its intended purpose, except where specific legal or regulatory requirements mandate a defined duration.
This retention period is established to ensure that personal data is used solely for legitimate and necessary purposes, in full compliance with legal and regulatory obligations. Once the data is no longer required, it will be securely deleted from our systems and records.
Data Subject Rights
Can I Find Out the Personal Data That C&I Leasing Holds About Me?
C&I Leasing, at your request, can confirm what information we hold about you and how it is processed. If we do hold your personal data, you have the right to request the following information:
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• Information about interests, if the processing is based on the legitimate interests of C&I Leasing or a third party.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• Information about how we intend to securely transfer the personal data to a third party or international organisation. The Attorney General of the Federation will approve sending personal data to some countries because they meet a minimum standard of data
protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if you didn’t provide it directly.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
Data Security
All information you provide to us is stored on our secure server.
We implement appropriate, generally accepted technical and organisational measures to protect your personal data such as (firewalls, password access and encryption methods) against unauthorised or unlawful Processing, accidental loss, destruction, or damage.
Unfortunately, the transmission of information via the Internet is not completely secure. We will do our best to protect your personal information, but we cannot guarantee 100% security of your data transmitted to our servers using the internet and any transmission is at your own risk.
Under what circumstances will the C&I Leasing contact me? We do not intend to be intrusive, and we will not ask irrelevant or unnecessary questions. Moreover, we will subject the information you provide to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Complaints
| Supervisory Authority | ||
| Contact Name: | Nigerian Data Potection Commission | |
| Address: | Abuja, Nigeria. | |
| Email: | info@ndpc.gov.ng | |
| Telephone: | +234 (0) 9160615551 |
If for any reason you wish to make a complaint about how C&I Leasing (or any of our third parties) processes your personal data, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and the Data Protection Officer of C&I Leasing.
Below are the details for each of these contacts:
