Privacy Policy

Capitalised terms appearing in this document shall, unless defined herein, have the same meaning contained in the Nigeria Data Protection Regulation 2019.

Schlau Energy appreciates your interest in this Web site and other related or linked Schlau Energy sites (collectively, “Site”). Your privacy is important to us, and we want you to understand our practices with respect to the gathering and handling of your Personal Data. This Privacy Policy describes those practices.

Schlau Energy provides additional privacy notices for specific uses of certain Personal Data. For example, we provide additional notices to visitors to our facilities, to our suppliers, to job applicants, to users of specific mobile Apps, and to participants of our loyalty programs.

The relevant Schlau Energy affiliates will process the Personal Data in accordance with the privacy notices they provide for such specific uses. When these notices apply to you, we recommend that you read them carefully.

This Privacy Policy sets forth general Personal Data privacy principles that Schlau Energy follows with respect to Personal Data being processed in our business operations. Our data privacy policies may vary among the countries in which we operate to reflect local practices and legal requirements.

Individuals to whom this Privacy Policy is Addressed

This Privacy Policy is addressed to:
  • Visitors of the Site;
  • Recipients of electronic or other communications which contain or refer to this Privacy Policy

Information from Children

Schlau Energy does not seek through the Site to gather Personal Data from or about minors (as this term is defined by applicable law), nor does Schlau Energy share the personal information of minors without affirmative authorization.

 

Schlau Energy’s compliance with data protection Laws

Schlau Energy is committed to collecting and using personal data in a lawful manner. Schlau Energy will ensure that, when it collects or uses personal data, such collection or use is allowed under applicable data protection law, including, for example, the Nigerian Data Protection Regulation, EU General Data Protection Regulation (GDPR) or California Consumer Protection Act, where such laws govern.

 

Individuals may object to the processing of their personal data and we will consider such objections carefully where required by law. For more information about your rights with respect to how we process your personal data, please contact us via info@schlauenergy.com

 

 

Collection of Personal Data

In this table we describe the categories of information that we gather via the Site and in connection with our business relationship with you. We also describe the purpose and legal basis, where applicable, for using and processing the information.
 

When Schlau Energy relies on its legitimate interest as a legal basis to process personal data, Schlau Energy will ensure that these interests do not disproportionately and adversely impact an individual’s rights and freedoms. When Schlau Energy relies on an individual’s consent as a legal basis to process personal data, individuals can withdraw their consent at any time. Visitors wishing to withdraw their consent should notify us at info@schlauenergy.com and we will stop the processing of your personal data as soon as reasonably possible.



Disclosure of Personal Data to External Parties

We contract with other companies and persons to perform functions on our behalf. They have access to personal data needed to perform these business purposes.

For example, Schlau Energy may share your personal data with vendors in order to allow Schlau Energy to fulfill orders and make deliveries, to send postal mail, and e-mail, to manage customer lists, analyze data, provide marketing assistance, host websites, process card payments, and provide and improve customer service. Furthermore, communicating via the Internet and sending information, products, and services to you by other means necessarily involves your personal data passing through or being handled by third-parties.

These service providers have access to your personal data needed to perform our business purposes, but may not use it for other purposes.
 

Before any personal data is shared with service providers, we enter into a written agreement which requires them:

  • not to make any unauthorized disclosures of the personal data;
  • to use the personal data only for the specified purposes and only according to the instructions received from Schlau Energy;
  • to retain the personal data only as long as necessary to protect company interests; and
  • to have in place adequate and appropriate security measures.

In some circumstances, Schlau Energy will disclose personal data to vendors, legal advisors, payment and loyalty card issuers, other contracted parties and competent authorities. These external parties process the personal data on their own behalf, for instance: if required by law, in order to defend Schlau Energy’s rights, or to handle individuals’ complaints and requests. We may also share your information in connection with a transfer of assets, or if we are otherwise involved in a merger or transfer. Only when permitted by applicable law and with your consent as required, will we distribute personal data to vendors, such as Schlau Energy distributors, for the purpose of allowing them to market their products and services to you. Schlau Energy does not, and will not, sell personal information to third parties.

Schlau Energy does permit third parties to collect information through our Sites (for example via cookies) in order to show advertisements for our products and services when the user visits other websites. Where required by law, we will seek your prior consent before such information is collected via our Sites. The third parties may also use the information for interest-based advertisement of other products and services. The advertisements are based on the users’ online activities over time and across different sites, services, and devices (“interest-based advertising”). Our cookie statements provide information about which third parties collect information via the Site for interest-based advertisement purposes. We recommend that you review the privacy policy of those third parties.

Internal Transfers of Personal Data

Transfers between affiliates

The relevant Schlau Energy affiliate who is the Data Controller may make personal data available to other Schlau Energy affiliates and may transfer some or all of the personal data to Schlau Energy servers located worldwide in accordance with applicable law.

The transfer of personal data from Nigeria to recipients located outside the country is subject to restrictions. Schlau Energy has taken steps so that personal data receives an adequate level of data protection at all Schlau Energy locations. These steps include Schlau Energy affiliates entering into inter affiliate agreements containing the NDPR “Standard Contracting Clauses”. The Standard Contracting Clauses will be approved by NITDA as offering adequate protection for transfers of personal data outside Nigeria.

 

Transfers to third parties When transferring personal data

Schlau Energy puts in place safeguards to ensure that the recipient adequately protects the personal data. With respect to the transfer of personal data from Nigeria to outside the country, Schlau Energy relies on
 

  • NDPR “Standard Contracting Clauses”;
  • contractual safeguards imposed on the recipient which is contracted by Schlau Energy affiliates outside of Nigeria; and
  • protections available under local law for the recipient established in a country deemed adequate by NITDA. Where permitted, and as applicable, we will rely on the individual’s consent.

 

For more information about specific transfer mechanisms, including information on existing safeguards implemented by Schlau Energy, please contact us at info@schlauenergy.com

Accuracy of Personal Data Schlau Energy endeavors to keep personal data that it collects accurate and complete. Schlau Energy relies on the individuals to maintain the accuracy and completeness of the personal data. Please inform Schlau Energy if your personal details change, including the context in which the personal data was provided, e.g. in connection with a specific product or service.

 

Individual’s Right

Applicable law may give you certain rights with respect to your personal data. In consumers may have the right to delete their data, to access and port personal data collected, used, or disclosed by Schlau Energy, and to exercise these rights freely from discrimination.

In order to submit a verifiable consumer request to exercise your right to know about, or delete, your personal information, please visit Schlau Energy’s privacy program landing page where you may submit your request via email, web form or via phone.

Under data privacy laws in Nigeria, applicable law gives consumers the right to:

  • access their personal data; have inaccurate or incomplete personal data rectified;
  • restrict the processing of their personal data, under certain circumstances;
  • object to the processing operations, having regard to the given circumstances and for reasons related to their particular situation; or have personal data erased when such data is no longer necessary for the purposes for which it has been collected, in accordance with applicable law.

In some circumstances, you also have a right to request a portable extract of your personal data, which will allow you to reuse your personal data for your own purposes. You also have a right to lodge a complaint to the data protection supervisory authority in your country. For more information about the specific mechanisms available to exercise these rights, please contact us at info@schlauenergy.com

To facilitate our efforts to address your request, please let us know the circumstances in which you initially provided Schlau Energy with your personal data, e.g. in connection with a specific product or service.

 

 

Do-Not-Track Signals and Similar Mechanisms

Some mobile web browsers transmit "do-not-track" signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

 

Automated Decision Making
  • Schlau Energy does not use automated decision-making unless it is
    necessary for entering into, or performance of, a contract between the Individual and Schlau Energy and its affiliates;
    permitted or required by law; or
    based on the Individual’s explicit consent. Automated decision-making refers to decisions that produce legal effects concerning an Individual or significantly affect the Individual and which are based solely on automated processing (i.e. no human intervention) of personal data
     

Schlau Energy shall implement suitable measures to safeguard the Individual’s rights and freedoms and legitimate interests when automated decision-making is used.

Records Retention

Schlau Energy retains personal data as long as necessary to meet the purposes for which the data was collected, to exercise its legal rights and to ensure compliance with applicable law.

Questions and Complaints

Schlau Energy is committed to protecting your personal data as described in this Privacy Policy and as required by applicable laws. If you have any questions about this notice or our handling of your personal data, or if you would like additional information, please contact us at info@schlauenergy.com We will ensure all data protection complaints are resolved in a timely manner as set out in the applicable Data Privacy laws and the Data Subject is informed when appropriate.



Schlau Energy and Affiliates

“Schlau Energy” and/or “Schlau Energy affiliates” mean

  • Schlau Energy
  • any company or partnership in which Schlau Energy or any parent of Schlau Energy now or hereafter, directly or indirectly owns or controls, more than fifty per cent (50%) of the ownership interest having the right to vote or appoint its directors or functional equivalents (“Affiliated Company”)
  • any joint venture in which Schlau Energy, any parent of Schlau Energy or an Affiliated Company has day to day operational control.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time without notice. When we make material changes to this Privacy Policy, we will post the changes on this page and update the revision date at the top of the Privacy Policy. We encourage you to review our Privacy Policy regularly for updates.