Privacy Policy

1.1 Purpose of this privacy policy:
This Privacy Policy describes your privacy rights regarding Squads collection, use, storage, sharing, and protection of your personal data. It aims to give you information on how Squads collects and processes your personal data through your use of our Product and its service offerings, including any data you may provide through our Product when you sign up, purchase a service/feature and/or participate in a promotion/competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.2 Consent
You accept this privacy policy when you access our Product, or use our services, content, features, technologies or functions offered on our Product.

1.3 Data Controller
Squads is the data controller and responsible for your personal data (collectively referred to as (the "Company", "we", "us" or "our" in this privacy policy). Squads is an affiliate of Proton Tech Labs duly registered in the Federal Republic of Nigeria and Proton Tech Labs which is a duly registered company under the laws of Delaware, USA.

1.4 Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 1 November 2021. We may amend this privacy policy at any time by publishing a revised version of our Product. The revised version shall become effective 7 days after publication. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 Third-party links
Our Product may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for and have no control over third-party websites, plug-ins and applications. We do not monitor or review the content of such platforms and the opinions expressed or materials appearing on same are not ours. Please be aware that we are not responsible for the privacy practices, or content of these platforms. We, therefore, encourage you to read the privacy statements of these third-party platforms when you exit our Product. You should evaluate the security and trustworthiness of third-party platforms before disclosing any personal information to them.

2.2 Aggregated data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

2.3 Special Categories of Personal Data
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and/or information about criminal convictions and offences.

2.4 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5.2 Marketing and promotional offers from us
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased any services from us and you have not opted out of receiving that marketing.

5.3 Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. However, please note that we shall share, from time to time, your personal data with Trence Tech Inc. (our affiliate) subject to acceptable standards of data privacy and protection.

5.4 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.5 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging accessing our Product and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

8.1 Some of our external third parties are based outside Nigeria so their processing of your personal data will involve a transfer of data outside Nigeria.

8.2 Whenever we transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring we only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the National Information and Technology Development Agency (NITDA).

8.3 Where we, however, intend to transfer your personal data to countries that are deemed to not have an adequate level of protection of personal data by the NITDA, we shall procure your consent to do so.

8.4 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

9.1 We will always hold your information securely and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. To prevent unauthorised access to your information, we have implemented strong controls and security safeguards at the technical and operational levels.

9.2 Our website uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your Personal Data. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.

9.3 We have also taken measures to comply with global Information Security Management Systems. We, have, therefore, have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.

9.4 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.

9.5 We have put in place procedures to deal with any suspected personal data breach and in the event of a suspected date breach, we shall notify the applicable regulator and/or you where we are legally required to do so.

9.6 If you have created a username, identification code, password or any other piece of information as part of our access security measures, you must treat such information as confidential, and you must not disclose it to any third party. We reserve the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of this privacy policy.

9.7 If you know or suspect that anyone other than you knows your security details, you must promptly notify us.

10.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

10.2 We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

10.3 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.

10.4 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

10.5 In some circumstances you can ask us to delete your data: see your legal rights below for further information.

10.6 In some circumstances, we will anonymise 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.

11.1 Under certain circumstances, you have rights (set out below) under data protection laws in relation to your personal data.

11.2 Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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

11.4 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 to continue 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 local law. 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.

11.5 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 to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

11.6 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:

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

11.7 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.

11.8 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.

11.9 Lodge a complaint at any time to the NITDA, the Nigeria regulator for data protection issues (https://nitda.gov.ng/). We would, however, appreciate the chance to deal with your concerns before you approach the NITDA so please contact us in the first instance.

11.10 If you wish to exercise any of the rights set out above, please contact us.

11.11 No fee usually required
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.

11.12 What we may need from you
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.

11.13 Time limit to respond
We try to respond to all legitimate requests within one (1) 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.

12.1 Meanings to words not specifically defined here shall be as contained in the Nigeria Data Protection Regulation (NDPR) 2019.

12.2 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

12.3 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

12.4 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

12.5 Internal Third Parties means Trence Technologies Inc. acting as a joint data controller or data processor and based in Delaware, USA.

12.6 External Third Parties includes the following:

• Service providers acting as processors based in [SPECIFIC COUNTRIES] who provide IT and system administration services.
• Professional advisers acting as processors including lawyers, financial advisers, bankers, auditors and insurers based in Nigeria and the USA.
• Government agencies, regulators and other authorities acting as processors or joint controllers based in Nigeria and the USA require reporting of processing activities in certain circumstances.