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Privacy Policy Privacy Notice

1. About us

Kaduna State Enterprise Development Agency (“KADEDA”) is an agency created by the Kaduna
State Government dedicated to facilitating the establishment, development, growth and promotion of
Kaduna MSMEs by building their capacities to be stronger, sustainable and have access to both
indigenous and global opportunities. Kaduna Digital Enterprise Platform (“KADDEP”) is a technology
initiative designed to enhance transparency in the deployment of MSME-focused Access to Finance
(A2F) and Access to Market (A2M) programmes and interventions deployed by KADEDA in Kaduna
state.

KADEDA has its of ce address at 2nd Floor, Mohammed Namadi Sambo Complex, Ali Akilu Way,
Kaduna State.

KADEDA is committed to safeguarding the privacy of bene ciaries of economic intervention

programmes, our employees, clients, partners, visitors, and other users of our website, product, and
services.

When this privacy policy mentions “we,” “us,” or “our,” it refers to KADEDA, which is the controller of
your personal data warehoused on the KADDEP. This notice governs your use of the KADDEP
platform accessed through www.kadeda.kdsg.gov.ng (http://www.kadeda.kdsg.gov.ng) and your
rights regarding our collection, use, storage, and protection of your data. Your privacy is our priority.

2. What personal information do we collect?

Personal information is any information about you that may be used to directly or indirectly identify
you.

In connection with the services we render and the programmes we undertake, we will collect
information from you while you use our services or partake in our programmes, and/or visit our
website. Most of this collection occurs during registration and signing up for our programmes and
while using our platform.

This personal information can include but is not limited to your name, contact details (such as
mobile/telephone numbers, e-mail addresses), date of birth, gender, home address, identi cation
document (National Identi cation Number [NIN], Voters card etc.), passport photograph, bank
veri cation number (BVN), and business details.

3. Principles of data processing

The principles below guide our use of your personal data:

1. Your personal data will be processed in a lawful, fair, and transparent manner;
2. Your personal data will be processed for a speci c purpose and not in a way that is
incompatible with the purpose for which it is collected;
3. Processing of your personal data will be adequate, relevant, and limited to what is necessary
for the purposes it is processed;
4. Your personal data will be kept accurate and, where necessary, kept up to date;
5. Your personal data will be held for no longer than it is required for the purposes for which it is
processed;
6. Your personal data will be kept secure.

4. Cookies

Cookies are tools that we use to automatically collect information from you when you visit our
website. Cookies help make our website work and provide information to us about how users interact
with our platform. We use this information for the improvement of the user experience on our
website. The cookies we use help provide us with anonymised, aggregated technical information.
Information about their usage is speci ed in our Cookies Notice

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5. Why we collect your personal data and the lawful bases

We collect your data to:

Purpose of processing

1. enumerate / create a personal pro le of potential bene ciaries on the KADDEP website.
2. carry out the veri cation process of potential bene ciaries of the programme
3. disburse to selected MSME-bene ciaries of our programme
4. enable us to send targeted advertisements of programmes to you
5. process statistical data to improve our programme
6. enhance data security
7. identify your device when you interact with our platforms
8. accept cookies on your device
9. communicate with you
10. provide our services
11. notify you of any changes to our service, solving issues via live chat support, phone, or email,
including any bug xing.
12. enable registered users to log in to our platform
13. we may also process your data to ful l legal requirements where needed.

Lawful Bases

Processing your data is necessary for our legitimate interests or the legitimate interests of
a third party, provided your rights and interests do not outweigh those interests.

You have given explicit consent for us to process your data for a speci c purpose.

If your data processing is necessary for a contract you have with us or because you have
asked us to take speci c steps before entering into that contract.

If the processing of your data is necessary where there is a statutory obligation on us.

6. Consent

Whenever we process your personal data based on consent, we will give you the option to accept or
reject such processing. When you give your consent:

7. Withdrawal of consent

You have the right to withdraw your consent at any time, and we will cease to process your personal
data for the purposes for which we processed them. You can withdraw your consent at any time by
sending an email to us

However, when you withdraw your consent, it does not affect the validity of the processing done
before the withdrawal.

8. Your rights

As a data subject, the law provides you with certain rights concerning the processing of your
personal data—they include the right to:

1. con rm whether or not your personal data is being processed, where so, access the personal
data we hold about you by requesting a copy of the personal data we hold about you;
2. rectify and complete your personal data where you believe it to be inaccurate and incomplete,
respectively;
3. restrict the processing of your personal data in certain circumstances;
4. object to the processing of your data where we intend to process such data for marketing
purposes;
5. where feasible, receive all personal data you have provided to us—in a structured, commonly
used, and machine-readable format—and transmit the information to another data controller;
6. request the erasure of your personal data (also known as the right to be forgotten); 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 by sending an email to dpo@ndpb.gov.ng
(mailto:dpo@ndpb.gov.ng). (You may complain or seek redress from us within 30 days from the
time you rst detected the alleged violation.)

To exercise any of the above rights, send an email to us at kadeda@kdsg.gov.ng

(mailto:kadeda@kdsg.gov.ng) or call us at 07005233372. You may also visit our of ce at 2nd Floor,
Mohammed Namadi Sambo Complex, Ali Akilu Way- Kaduna State, Nigeria.

9. Who we share your personal data with

1. Technical and/or Technology Partners

2. Banking Partners

Note that we may disclose your data to legal or regulatory authorities 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. Marketing and communications

Prior to sending direct marketing communications to you, we will seek your consent. You may choose
to opt-out of our marketing emails by clicking on the “unsubscribe” button at the bottom of the page.

11. Retention of your data

Your personal data or any other information collected will be stored for as long as necessary to ful l
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.

12. How do we store your personal data?

The personal information is collected through the KADDEP database, stored within Google Cloud
Storage, and processed using an encrypted bank veri cation process. We protect your data using
physical, technical, and administrative security measures to reduce the risks of loss, misuse,
unauthorised access, disclosure, and alteration. Some of the safeguards we use are rewalls and
data encryption, physical access controls, and information access authorisation controls.

In the event of 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.

13. International transfer of data

To achieve the purposes described in this notice, we may transfer your data to countries that are not
considered to have suf cient laws by the Nigeria Data Protection Bureau (NDPB). Where personal
data is to be transferred to a country outside Nigeria, we shall put in place adequate measures to
ensure data security.

Our data transfers to countries that do not offer an adequate level of protection are subject to the
conditions under the Nigeria Data Protection Regulation (NDPR). We will therefore only transfer
Personal Data out of Nigeria under 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 a 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-party
countries (including the appropriate transfer mechanisms), please contact us.

14. Contact us

We are hopeful that you will not have a reason to be dissatis ed with how we manage your data.
However, in the unlikely event that you have a concern over how your information is being managed,
processed, or where it is missing, you can reach our Data Protection Of cer (DPO) at
kadeda@kdsg.gov.ng (mailto:kadeda@kdsg.gov.ng) or call 07005233372.

15. Changes to the privacy policy

We may change this notice from time to time by updating this page. We do not undertake to send a
written noti cation of changes to this notice. Whenever you visit our website, do check the last date
of an update.

16. Governing Law

This privacy notice is made pursuant to the Nigeria Data Protection Regulation 2019 and other
relevant Nigerian laws, regulations, or international conventions applicable to Nigeria. Where any
provision of this Policy is deemed inconsistent with a law, regulation, or convention, such provision
shall be subject to the overriding law, regulation, or convention.

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This Privacy Notice was last updated on 15 November 2022

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