PRIVACY POLICY

 

1. LEAF NG Distribution Ltd. (LEAF) and your personal data

This is our privacy notice for LEAF NG Distribution Ltd. It explains your statutory rights and how we collect and use your personal data. It describes the processing activities that are carried out by LEAF NG Distribution Ltd. and our franchisees, the purposes for which these activities are performed and the legal bases we rely upon for these processing activities.

This notice applies to personal data we hold about individuals (such as company directors, or contacts on business accounts), including sole traders and partners. It does not apply to information which we hold about companies and other legal organisations.

We may update this privacy notice from time to time to ensure it is always up to date and accurate. Any changes we may make to our privacy notice will be posted on this page.

You can contact LEAF’s data protection officer by writing to The Data Protection Officer, LEAF NG Distribution Ltd., info@leafgas.com.


 

2. Personal data we collect

We collect the following types of personal data:

  • Your contact details: information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your order or query.

  • Information about your job: including job details, pricing and payment information, and dispatch appointment details.

  • Audio and video recordings, and contemporaneous notes: records of site visits by our field operations teams, and recordings of some calls to our contact centres.

  • Exercising your rights: if you exercise any of your statutory rights under data protection law, we will keep a record of this and how we respond.

  • Advertising and direct marketing: information about how you respond, or interact with, any direct marketing or advertising communications directed to you, including any requests for these communications to stop.

You are not required to provide to us any of the personal data described above, however, if you do not do so, you may not be able to purchase our products and services, or we may not able to deliver our services to you.


 

3. What we use your personal data for and why

Where we process your personal data because of our contract

We process these items of your personal data to enter or fulfil the contract between us, including to:


 

Reason or purpose

Personal data used

Provide our services to you

• All personal information that we collect as listed in Section 2

Where we process your personal data because we’re legally obliged to

We process these items of your personal data because we have a legal obligation to, including:

Where we process your personal data because we have a legitimate interest to

We process these items of your personal data because we have a legitimate interest to do so:

Reason or purpose

Personal data used

Assist law enforcement agencies, and other public authorities

 

The personal data processed for this purpose would depend on the scope of the enquiry, and will be limited to what is necessary to achieve the purpose of the request.

 

Reason or purpose

Personal data used

Improve our services

Contact details Information about your job

Audio and video recordings, and contemporaneous notes Exercising your rights

Improve our marketing insight

• Information about your job

Assess which of our products and services may be of interest to you. This includes matching your data with data we obtain from other companies, for example so that we do not advertise to you about a third-party product or service that you already have

• All personal information that we collect as listed in Section 2

Staff training

• All personal information that we collect as listed in Section 2

Develop new products and services

• All personal information that we collect as listed in Section 2

Investigating misuse of the service, fraud and debt collection

• All personal information that we collect as listed in Section 2

Prevention and detection of crime

• All personal information that we collect as listed in Section 2

For the establishment, exercise or defense of legal claims

• All personal information that we collect as listed in Section 2

Maintain accuracy and relevance of your data

• All personal information that we collect as listed in Section 2

Protection of our staff and customers

• All personal information that we collect as listed in Section 2

Assist law enforcement agencies, and other public authorities

The personal data processed for this purpose would depend on the scope of the enquiry, and will be limited to what is necessary to achieve the purpose of the request.

Where we process your personal data because you have allowed us to

We process these items of your personal data because you have provided your consent to the processing. You may revoke your consent at any point:

Where we process your personal data so you can’t be identified any more

We may anonymise and aggregate any of the personal data we hold (so that it does not identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site, apps and developing new products and services.


 

4. Sources we collect your personal data from

We will collect personal data from a number of sources. These include:

  • Directly from you: when you contact us or our franchisees, purchase products or services from us or our franchisees, submit information via our websites or apps, complete forms we provide to you, enter our competitions and promotions, make a claim, make a complaint, exercise your statutory rights, contact us by phone, email or communicate with us directly in some other way.

  • Our website and apps: we collect information about how you use them.

  • Other companies we work with: provide us with information to help us deliver our products and

services to you. These include:

o Companies in the same group of companies as us: who may provide relevant information about the products and services bought from them.

  • Lead generation providers: companies to which you give contact information, where you give permission for them to pass it on to us.

  • Our regulators: provide us with information about the complaints they receive.

  • Social media: information you submit to our social media accounts.

  • Our business customers: provide us with information about their own customers.


 

5. Who we share your personal data with

We share personal data with the following parties:

Reason or purpose

Personal data used

Direct marketing by us and our franchisees

  • Contact details

  • Information about your job

  • Marketing preferences


 

Who

Examples

Our franchisees

Your local LEAF Gas service provider.

Companies in the same group of companies as us

Our parent company, LEAF NG Distribution Ltd.

Our regulators

  • Standards Organisation of Nigeria (SON);

Companies that support our business, IT infrastructure and to further understand our customers

  • Survey Monkey – To answer business questions around customer perception / experience / understanding;

  • Response Tap – To analyse and understand the

performance of our webpages to ensure

consistency within digital channels;

  • Google Analytics – To analyse, understand the

performance of our webpages and users

journey.

 

Data and insight providers

• Experian

Law enforcement agencies and other public authorities

• Police forces • HMRC


 

6. Direct Marketing

Email, SMS, post and telephone: from time to time, we and our franchisees may contact you by email, SMS, post with information about products and services we believe you may be interested in. When you call LEAF, we may also provide you with information about products and services we believe you may be interested in.

If you have not consented to receiving direct marketing, we will only promote them to you when permitted to do so by law, but in all circumstances, we will respect your marketing preferences which you tell us about.

You can let us know at any time that you do not wish to receive marketing messages by sending an email to us at info@leafgas.com. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.


 

7. Advertising on other websites and apps

We work with advertising partners, including social media sites and providers and addressable TV service providers, to show you advertising about our products and services, including those offered by group companies. This takes place on third party websites, applications and services where we or our advertising partners have purchased advertising space.

To provide you with the most appropriate advertising content, this uses information gathered via cookies and similar technologies about the websites, mobile applications, social media content and ads you interact with or view when connected to the Internet, as well as information which we provide (such as a hash of your email address or phone number), to make sure the advertising you see is more relevant to you.

The main third parties we work with are Facebook and Twitter.


 

8. Transferring your personal data internationally

LEAF NG Distribution Ltd. intends to extend its business globally and in common with our sister organisations, we use third parties located in other countries to help us run our aspects of our IT systems. As a result, personal data may be transferred outside the countries where we and our customers are located. This includes countries outside the ECOWAS trade zone and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the requirements for the transfer of personal data outside the EEA, such as the European Commission approved standard contractual clauses.


 

9. How long we keep personal data for

We will keep your personal data for as long as necessary in order to achieve the processing purposes.


 

10. Your rights in relation to your personal data

You may have the following rights in relation to your personal data:

  • the right to be informed about the personal data we collect, how your personal data is being used, and from whom we collect your personal data when we obtain it from other sources;

  • the right to access the personal data we hold about you;

  • the right to request the correction of inaccurate personal data we hold about you;

  • the right to request the blocking or deletion of your personal data in some circumstances;

  • the right to request that we port elements of your data either to you or another service provider;

  • the right to object to us processing your personal data ((1) where we have a legitimate interest to do so, as listed in section 3, but your rights override ours based on your particular situation (which you will need to explain to us), (2) where we are processing it for the purpose of direct marketing, or (3) because we are using automated means to make decisions that have a legal or similarly significant effect); and

  • the right to withdraw your consent to those processing activities which we carry out based on consent, listed in section 3.

You only have the benefits of some of the above rights in limited circumstances, which depend on the legal reason why we collected your personal data.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details below. We may require evidence of your identity before we are able to complete your request.


 

11. Getting in touch

If you have any privacy-related questions or comments, please contact LEAF NG Distribution Ltd.’s data protection officer by writing to The Data Protection Officer to info@leafgas.com.

You can also contact our data protection officer at info@leafgas.com.

If you are unhappy with the way, we are using your personal data you can also complain to your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

 

Version 1. August 2020