PRIVACY
POLICY
1. INTRODUCTION
Welcome
to Ikoyi Club 1938 (“Ikoyi Club”, “Club” “we”, “us”, “our”). We are committed
to protecting the privacy and security of the personal data of our members,
guests, employees, and visitors. This Privacy Policy (“Policy”) applies to the
website and mobile application(s) (hereinafter referred to as, the “Sites”)
provided by Ikoyi Club 1938, and other products/services of the Club.
This
Privacy Policy sets out how we collect, use, store, share, and protect your
personal and sensitive information in compliance with the Nigeria Data
Protection Act (NDPA) and other applicable Laws. Our goal is to ensure
transparency, accountability, and security in the management of your personal
data, while enabling the Club to provide high-quality services, maintain safety
and security and deliver an exceptional member experience. This Policy applies
to all your personal data collected through membership applications, events,
facilities, digital platforms, and Club operations.
Please
read this Privacy Policy carefully to understand our practices regarding your
information.
2. WHO
WE ARE
Ikoyi
Club 1938 is an elite private members’ club established in 1938 and located in
Ikoyi, Lagos, Nigeria. The Club provides recreational, sporting, social,
hospitality, and event-hosting facilities to its members and their guests. In
the course of carrying out these activities, the Club collects and processes
personal data relating to members, prospective members, guests, employees,
contractors, vendors, and other stakeholders.
For
the purposes of all applicable data protection laws, including the Nigeria Data
Protection Act 2023 (NDPA), Ikoyi Club 1938 acts as a Data Controller,
determining the purposes and means by which personal data is processed. In
certain circumstances, the Club may also engage third-party service providers
who process personal data on its behalf under strict contractual and
confidentiality obligations.
The
Club is committed to upholding the highest standards of privacy, security, and
responsible data governance consistent with its institutional values,
regulatory obligations, and duty of care to its community.
3. SCOPE AND
APPLICATIONS
This
Privacy Policy applies to all personal data collected, processed, stored,
transmitted, or otherwise handled by us in the course of our operations and
governance activities. It governs the processing of personal data relating to
members, prospective members, guests and visitors, spouses and dependants,
employees, job applicants, contractors, vendors, event participants, and users
of the Club’s digital platforms.
This
Policy applies to personal data processed in any format, whether physically or
electronically, and through any channel, including membership applications,
facility access systems, CCTV surveillance, event registrations, financial
transactions, human resource processes, website interactions, and third-party
service arrangements.
It
applies to all officers, committee members, employees, contractors, and service
providers acting on behalf of the Club, who are required to process personal
data in accordance with this Policy and applicable data protection laws.
4. INFORMATION
WE COLLECT
Ikoyi
Club collects only relevant information limited to the specific reasons it is
required. When you apply to be a member or engage any of our Sites, we may
collect the following information from you:
a. Personal Identification: Such as your full
name, date of birth, gender, nationality, dependants information, email,
marital status and means of identification.
b. Employment
Information: This includes your occupation and details of your
employer, such as email address, business address and phone number.
c. Contact Information: This
includes your email address, phone number, as well as residential and business
addresses.
d. Financial Information: Details like
your bank account information, records of transactions with us and any
financial documentation you provide when applying as a member.
e. Login Credentials: Your username,
password, and responses to security questions for accessing our digital banking platforms.
f. Customer Support Data: Information
shared while interacting with our customer service channels,
responding to surveys, or submitting feedback.
g. Biometric clocking data
h. Photographic images and video
footage of Club events and attendees of these
events for marketing and promotional purposes.
i. Usage Information: We may collect
information about how you use our website, mobile applications, and other
services, including IP addresses, device information, and browsing history.
j. Other Information: Any
additional details you provide for purposes such as verifying your identity,
reclaiming a lost account, or fulfilling regulatory requirements.
All
personal data is processed in line with applicable Nigerian data protection
laws and banking regulations. For further information please see
our Privacy Statement .
4.1
Information we collect automatically
When
you access our Sites, we may collect:
a. Information
about how and when you access or use our services. This data may be
stored in log files or other records linked to your activities on the
Sites and may be combined with other information we have about you. This
includes collecting unique online identifiers such as your IP address,
date and time of access, browser type, and actions performed on our
website or mobile applications. We use this information to enhance the
functionality, security, and user experience of our services for you and
all our users.
b. Information
we collect using cookies and similar technologies. Please see
our Cookies Policy for more details.
4.2
Information we obtain from Third Parties
To
verify your identity and assess financial risk, we may collect additional data
from:
a.Credit
bureaus and financial institutions.
b.Regulatory
agencies such as the CBN and anti-fraud agencies.
c.Payment
processors, financial technology partners, and loan service providers.
d.Information
that we receive if you decide to connect to a third-party social network.
e.Information
for advertising and analytics purposes, so we can provide you with better
Services.
5.HOW
WE USE YOUR INFORMATION
Ikoyi
Club process personal data only where there is a lawful basis and
for legitimate operational, regulatory, governance, and security purposes. The
manner in which we use personal information depends on the nature of your
relationship with the Club.
We
may use your personal data for the following purposes:
5.1
Membership Administration and Governance
a.Processing
membership applications, nominations, and approvals
b.Verifying
identity and eligibility, including Biometric clocking data
c.Maintaining
accurate membership records
d.Managing
subscriptions, renewals, suspensions, resignations, or terminations
e.Conducting
internal governance, disciplinary reviews, and compliance with Club rules
f.Communicating
notices, ballots, elections, and committee matters
5.2
Provision of Club Services and Facilities
a.Managing
bookings for sporting, hospitality, dining, and recreational facilities
b.Administering
event registrations and participation
c.Facilitating
access control to Club premises and restricted areas
d.Personalizing
member services and improving user experience
e.Managing
guest access and temporary visitor records
5.3 Financial Management and Accounting
a.Processing
payments, subscriptions, and levies.
b.Maintaining
billing and transaction records.
c.Managing
refunds, disputes, and chargebacks
d.Complying
with financial reporting and audit requirements
e.Preventing
fraud and financial misconduct
5.4
Security and Safety
a.Operating
CCTV systems for crime prevention and asset protection
b.Monitoring
access control systems, including key cards or biometric systems (where
applicable)
c.Investigating
incidents, accidents, or rule violations
d.Protecting
members, guests, staff, and property
e.Supporting
law enforcement or regulatory investigations where required
5.5
Communication and Engagement
a.Sending
operational updates, service notices, and important announcements
b.Circulating
newsletters, event invitations, and Club publications
c.Responding
to inquiries, complaints, or feedback
d.Conducting
surveys to improve Club services
e.Marketing
communications are issued in accordance with applicable laws, and
individuals may opt out where permitted.
6.
EMPLOYMENT AND HUMAN RESOURCE MANAGEMENT
For
employees and job applicants, we use personal data to:
a.Process
recruitment applications
b.Conduct
background and reference checks (where lawful)
c.Manage
payroll, pensions, and benefits
d.Monitor
performance and disciplinary matters
e.Ensure
compliance with employment laws and workplace safety requirements
7.
LEGAL AND REGULATORY COMPLIANCE
a.Complying
with statutory obligations under Nigerian law
b.Meeting
reporting requirements to regulators or government agencies
c.Responding
to lawful requests from courts or enforcement authorities
d.Maintaining
records required for taxation, financial, and corporate governance
purposes.
8.
LEGAL BASIS FOR PROCESSING YOUR DATA
We
or any third party acting on our behalf shall only process your data if at
least one of these conditions is met:
a.Consent: This refers to any freely given,
specific, informed, and unambiguous indication through a statement or a
clear affirmative action that signifies your agreement to the processing
of your Personal Data by us. For data we don’t automatically collect, you
may withdraw consent at any time.
b.Legal
Obligation: We
process personal data to comply with applicable laws, regulatory
requirements and law enforcement obligations.
c.Legitimate
Interests: We
process personal data where necessary for the Club’s legitimate interests,
including security, fraud prevention, internal administration, service
improvement, and operational management.
d.Contractual
Obligation: We
process personal data where necessary to administer membership, provide
Club facilities and services, manage bookings and events and process
payments.
9.WHO
WE SHARE YOUR INFORMATION WITH
We
do not sell, rent, or trade your personal information. However, we may share
your data with:
1.Employees
who deliver our services.
2.Service
Providers and Data Processors
We
may share personal data with trusted third-party service providers who support
our operations, including:
a.IT and
cloud service providers
b.Payment
processors and financial institutions
c.Security
and facility management providers
d.Event
management and competition partners
e.Professional
advisers (legal, audit, tax, compliance)
All
service providers are contractually bound to process personal data only on our
instructions and to maintain appropriate security measures.
3.Regulatory Authorities and Law Enforcement Agencies
We
may disclose personal data where required to comply with applicable laws,
regulatory requirements, court orders, or lawful requests from public
authorities.
10
. HOW WE PROTECT YOUR INFORMATION
We
have implemented industry-standard security measures to safeguard and help
prevent unauthorized access, maintain data security, and correctly use the
personal information collected through the Services we provide.
Specifically,
we implement the following industry-standard security measures:
a.Data
Encryption: To
secure sensitive information.
b.Multi-Factor
Authentication: To
prevent unauthorized access.
c.Regular
Security Audits: To
detect vulnerabilities and enhance cyber security.
d.Access
Control Measures: To
limit employee access based on job responsibilities.
We
take reasonable steps to ensure that applicable third parties take reasonable
precautions to protect your personal information against loss, misuse,
unauthorized disclosure, alteration, and destruction. However, no transmission
of data over the Internet or any wireless network can be guaranteed to be 100%
secure. As a result, while we strive to protect your information, we cannot
guarantee the security of your information and do not assume any responsibility
for the unauthorized use of, or access to your information that is under our
control.
In
case of a data breach, we will promptly notify affected individuals and
regulatory authorities within the notification threshold provided by the
Nigeria Data Protection Commission.
11. YOUR
RIGHTS AS A DATA SUBJECT
You
have the following rights regarding your personal data:
a.Right
to Access: You
have the right at any time to ask us what personal information we hold
about you. To protect your privacy and security we may need to verify your
identity before disclosing your data.
b.Right
to Correction: The
accuracy of your personal data is important to us. You can request
corrections to inaccurate or incomplete data.
c.Right
to Deletion: You
have the right to request the deletion of your personal data no longer
needed for legal or business purposes. If you find any inaccuracy in your
data at any time, we will delete at your request. Proof of identity may be
required in some circumstances.
d.Right
to Object: You
have the right to object to your personal data being processed for
marketing or for research purposes.
e.Right
to Data Portability: You
have the right to request a transfer of your personal data to another
institution.
f.Right
to Withdraw Consent: You
have the right to revoke consent for optional services at any
time.
To
exercise these rights, contact Our Data Protection Officer
at dpo@ikoyiclub1938.org.
12. HOW
LONG WE KEEP YOUR DATA
We
retain personal data only for as long as necessary to fulfil the purposes for
which it was collected, including legal, regulatory, operational, and
contractual requirements.
Membership
data is retained for the duration of membership and for a reasonable period
thereafter. CCTV footage and security records are kept for a limited period
unless required for investigation or legal proceedings. When personal data is
no longer required, it is securely archived, anonymized, or destroyed in line
with our data retention policies and applicable law.
If
you request the deletion of your account and removal of your personal data from
our records, we will retain the necessary information only as required by law.
This retained information will be handled strictly to meet legal
compliance and audit purposes and will not be used for any other purposes.
13.
PRIVACY OF CHILDREN
Ikoyi
Club may process personal data relating to children who are dependants of
members or participants in Club activities. We process children’s personal data
only where necessary and with the consent of a parent or legal guardian, or as
otherwise permitted by applicable law. Such data is limited to what is required
for membership administration, safety, participation in sporting or
recreational activities, and related purposes. The Club maintains a categorical
prohibition against the utilization of minors’ data for marketing or any
secondary purposes. Access to this information is restricted to essential
personnel to ensure the highest standard of confidentiality.
Parents
or guardians may exercise data protection rights on behalf of their children by
contacting the Club’s Data Protection Officer.
14.UPDATES
TO THIS PRIVACY POLICY
We
may update this Privacy Policy from time to time to reflect changes in our
practices or legal requirements. We will notify you of any material changes by
posting the updated Privacy Policy on our website or by sending you a
notification. We encourage you to review this Privacy Policy periodically for
any updates.
The
effective date at the top of this page indicates when the latest version was
published.
15.. GOVERNING
POLICY
This
Privacy Policy is made according to the Nigeria Data Protection Act (NDPA),
2023, Nigeria Data Protection Commission, General Application and
Implementation Directive (NDPC - GAID) 2024 and other relevant laws,
regulations, or international conventions applicable to Nigeria.
By
using our website, you acknowledge that you have read this Privacy Policy and
consent to the collection, use, disclosure, and retention of your information
as described herein.
16.
HOW TO CONTACT US
For
questions, complaints, or to exercise your rights, contact:
Data
Protection Officer
Ikoyi
Club 1938
6,
Ikoyi Club Road, Ikoyi, Lagos
dpo@ikoyiclub1938.org
We
are committed to addressing privacy concerns promptly and in accordance with
regulatory requirements.