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Privacy Policy

Privacy Policy

Updated at May 2025

Tenece is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by Tenece.

This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Services”). By accessing or using this website, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

This Privacy Policy explains how Tenece collects and processes your personal information that we collect and the measures we have in place to ensure confidentiality of your personal information.

Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictly defined as:

  • Cookie: a small amount of data generated by a website and saved by your web browser on your Device. It is used to identify your browser, provide analytics, and remember information about you such as your language preference or login information.
  • Company: When this policy mentions “Company” “we”, “us” or “our” it refers to Tenece Professional Services Limited (Tenece) that is responsible for your information under this Privacy Policy.
  • Contact Data: includes [billing address, delivery address, email address and telephone numbers].
  • Country: where Tenece is based and carrying out business
  • Customer: refers to the company, organization, or person that signs up to use the Tenece website to manage the relationships with your consumers or service users.
  • Data Subject: any person, who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural, or social identity.
  • Device: any internet-connected device such as a phone, tablet, computer, or any other device that can be used to visit Tenece and use the services.
  • Identity Data: includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
  • IP address: Every device connected to the internet is assigned a number known as an Internet Protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the internet.
  • NDPC: Nigeria Data Protection Commission
  • Personnel: refers to individuals employed by Tenece or are under contract to perform a service on behalf of Tenece.
  • Personal Data: any information that directly, indirectly, or in connection with other information ‚ allows for the identification or identifiability of a natural person. It includes name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, psychological, cultural, social, or economic identity of that individual;
  • Service: refers to the services provided by Tenece as described in the relative terms (if available) and on this platform.
  • Technical Data: includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform].
  • Website: Tenece’s website, which can be accessed via this URL: tenece.com
  • You: a person or entity that is registered with Tenece to use the Services.

Who We Are and How to Contact Us

Tenece Holdings Limited (with business address at 161 Sinari Daranijo St, Victoria Island, Lagos) and its Affiliates (Tenece Group) are made up of different legal entities, This Privacy Policy is issued on behalf of the Tenece Group so when we mention Tenece “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Tenece Group responsible for processing your Tenece Group.

[Tenece Professional Services Limited] is the controller and responsible for your Personal Data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact the DPO using the information set out below:

Email address: [legal@tenece.com]

Telephone number: +234 816 744 9095

What Personal Data Do We Collect?

We collect Personal Data from you when you visit our website, fill out a contact form, subscribe to our newsletter, respond to a survey or fill out a form. The Personal Data collected includes your name, email address and country/city.

Where we need to collect Personal Data, and you fail to provide that data when requested or fail to update your details with us, we may not be able to provide you with our Services. In this case, we may have to cancel the Service you have with us but we will notify you if this is the case at the time.

What is our Legal Basis for Processing Your Personal Data?

The legal basis for collecting your Personal Data are as follows:

  1. Consent: We rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose, for example if you subscribe to an email newsletter.
  2. Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
  3. Legal obligation: We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis
  4. Vital Interest: We may use your Personal Data to protect your vital interest or that of another person.

How Do We Use the Personal Data We Collect?

The Personal Data we collect from you may be used in one of the following ways:

  • To personalize your experience (your information helps us to better respond to your individual needs).
  • To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you).
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs).
  • To administer a survey or other site feature
  • To send periodic emails.

How Do We Use Your Email Address?

By submitting your email address on this Website, you agree to receive emails from us. You can cancel your participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do. By submitting your email address, you also agree to allow us to use your email address for customer audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us. 

Email addresses submitted only through the contact page will be used for the sole purpose of sending you information and updates pertaining to your request. If, however, you have provided the same email to us through another method, we may use it for any of the purposes stated in this Privacy Policy. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

Do we share the information we collect with third parties?

We may engage trusted third-party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the website, database storage and management, e-mail management and customer service We will likely share your Personal Data, and possibly some non-Personal Data, with these third parties to enable them to perform these services for us and for you.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the Website in a shared location, and type of the device used to visit the Website. They may aggregate information about our advertising and what you see on the Website and then provide auditing, research, and reporting services for us.

We may also disclose Personal Data and non-Personal Data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules, and regulations.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Where and when is information collected from customers and end users?

  1. Direct interactions. You may give us your Identity Data and Contact Data by completing forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you :
  1. create an account on our Website;
  1. subscribe to our service or marketing communications;
  1. enter a competition, promotion or survey; or
  1. give us feedback or contact us.
  1. Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies [, server logs] and other similar technologies. Please see our cookie policy LINK for further details.
  1. Third parties or publicly available sources. We will receive Personal Data about you from various third parties [and public sources] as set out below 
  1. Technical Data from the following parties:
  • analytics providers [such as Google];
  • advertising networks; and
  • search information providers.2
  • Contact Data, from providers of technical services.
  1. Identity Data and Contact Data from data brokers or aggregators.
  2. Identity Data and Contact Data from publicly available sources 

How Long Do We Keep Your Information?

We keep your information only so long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements This is also the case for anyone that we share your information with and who carries out services on our behalf. 

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your Personal Data: see [What are Your Rights?] below for further information.

In some circumstances, we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we either remove it from our systems or depersonalize it so that we cannot identify you.

What are Your Legal Rights

 Under certain circumstances, you have rights under Data Protection Laws in relation to your Personal Data. 

You have the right to:

Request access to your Personal Data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected, though we may need to verify the accuracy of the new Personal Data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with applicable laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate basis to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: 

  1. If you want us to establish the data’s accuracy.
  2. Where our use of the Personal Data is unlawful but you do not want us to erase it.
  3. Where you need us to hold the Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  4. You have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate basis to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

How Can You Exercise Your Data Privacy Rights?

If you wish to exercise any of the rights set out above, please contact us via our DPO in the following ways –

Email address: legal@tenece.com

Telephone number: +234 816 744 9094

Data Subject Request Form: Visit this link 

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What Are Your Available Remedies in the Case of a Breach?

In the case of a breach of any of the obligations with respect to your Personal Data, a data breach procedure is established and maintained in order to deal with incidents concerning Personal Data or privacy practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed. On notification of such breach, Tenece will investigate to determine if an actual breach has occurred, and Tenece will take the actions required to manage such breach. 

In the event you believe we have breached any applicable law or this Privacy Policy, you have the right to file a complaint with the Nigeria Data Protection Commission. You may however contact our Data Protection Officer to enable us to rectify such breach as soon as possible. 

How Do We Protect Your Information?

We implement a variety of security measures to maintain the safety of your Personal Data when you enter, submit, or access your personal information. We offer the use of a secure server. All supplied Personal Data is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. 

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and the NDPC of the occurrence of a Personal Data Breach where we are legally required to do so.

We cannot, however, ensure or warrant the absolute security of any information you transmit to Tenece or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

Could my information be transferred to other countries?

Information collected via our website, through direct interactions with you, or from the use of our help services may be transferred from time to time to our offices or personnel or to third parties located throughout the world and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. 

Whenever we transfer your Personal Data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by NDPC. 
  2. We will only transfer your Personal Data in compliance with Data Protection Laws

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out Nigeria.

Is the Personal Data collected through the Website secure?

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

Can I update or correct my information?

You have the right to request the restriction of certain uses and disclosures of Personal Data as follows. You can contact us in order to (1) update or correct your Personal Data, and (2) change your preferences with respect to communications and other information you receive from us. Such updates, corrections, changes, and deletions will have no effect on other information that we maintain or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change, or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed, or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

If you are an end-user and wish to update, delete, or receive any information we have about you, you may do so by contacting Tenece.

Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by, or is under common control with Tenece, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

By using Tenece or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

. The Rights You Have 

Links to Other Websites

This Privacy Policy applies only to this website. The website may contain links to other websites not operated or controlled by Tenece. We are not responsible for the content, accuracy, or opinions expressed in such websites, and such websites are not investigated, monitored, or checked for accuracy or completeness by us. Please remember that when you use a link to go from this website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website, its rules, and policies. Such third parties may use their own cookies or other methods to collect information about you.

Cookies

Tenece uses “cookies” to identify the areas of our website that you have visited. A “cookie” is a small piece of data stored on your computer or mobile device by your web browser. We use cookies to enhance the performance and functionality of our website but are non-essential to their use. For instance, our Website may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Website. In all cases in which we use cookies, we will not collect Personal Data except with your permission or use information gathered for tracking purposes. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personal Data in Cookies.

For more information about the cookies we use and how to change your cookie preferences, please see Link to Cookies Policy Page

Blocking and disabling cookies and similar technologies

Wherever you are located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features and services. Different browsers make different controls available to you. Disabling a cookie or category of cookies does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser’s help menu for more information.

Changes To Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. If you continue to use the Service after any change to our Privacy Policy, you will be bound by the updated Privacy Policy.

Third-Party Services

We may display, include or make available third-party content (including data, information, applications and other product services) or provide links to third-party websites or services (“Third-Party Services”).

You acknowledge and agree that Tenece shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality, or any other aspect thereof. Tenece does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties terms and conditions. 

Complaints

You have the right to make a complaint at any time to the NDPC. We would, however, appreciate the chance to deal with your concerns before you approach the NDPC so please contact us in the first instance.

Contact Us

Do not hesitate to contact us if you have any questions. – `Via this Link:  Contact Us