SEA-FAJ CONSULTS PRIVACY POLICY

INTRODUCTION

Sea-Faj Consults values your privacy and is committed to protecting and respecting your personal information and rights. We have taken all required organizational and technical measures to secure the confidentiality and integrity of your personal data and have also adhere to statutory data protection and privacy requirements.

This policy applies to customers and prospective customers, website visitors, employees and job applicants, vendors and service providers, business partners, any other individuals whose personal data we process.

Here is is a summary of how we protect your privacy:

• We only collect what we need to help you with your request or provide you with information that you ask for, personalising it to your interests.
• We would not hang on to your information, if we don’t need it, and you do not want us to keep it, we’ll delete it.
• We want you to understand everything we do with your information, so we would try our best to explain.
• No surprises, you decide what and how you hear from us.

The rest of this privacy policy provides more details of our privacy practices.

1. WHO WE ARE

Sea-Faj Consults Limited (We, us, our) is a firm that offers International Student Recruitment services, outsourcing services and business consultancy. Sea-Faj Consults is the controller of your personal data in respect of personal data processed through our services and platforms, it determines the purposes and means of processing your personal data as provided in this privacy policy (hereinafter referred to as the policy).

2. PURPOSE OF THE POLICY

This Privacy Policy gives a comprehensive detail of how we collect, process, store, share, transfer, protect and delete your personal data and sensitive information when you visit our website, Social Networks or use our services. You acknowledge that you have read, understood and agreed to the practices described in this policy. For the purpose of this policy,

• Personal data or data/information, means any information relating to an identifiable natural person(data subject, you, yours). An identifiable natural person is a person who can be identified directly or indirectly.
• Processing means any set of operation which is performed on a set of personal data.

3. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS

Depending on the nature of our interaction with you, We may collect, process, store and share different categories of your personal data such as:

Personal Information

When you contact us, sign up for services, use our Social media platforms, or submit inquiries, we may collect personal details such as:

• Full legal name(including any aliases used)
• Date of birth, gender, marital status
• Email address, mobile and landline telephone number
• Mailing address and residential and business address including postal codes and province
• Government-issued identity documents including passport, national IDs, Drivers Licences National Identification Number (NIN), biometric data, financial risk profiling information, etc.
• Visa Application data, employment related data, profile data
• Country of residence, nationality, preferred study destination, when you intend to study and how you intend to fund your studies.
• Educational qualifications and employment status and history, occupation
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
• Employment Information (including employer details, job title or business ownership details, salary or income information, work history, working hours, training records and professional membership)
• Financial Information – bank account details, transaction history, financial records, credit information, income and employment information.
• Visual identification such as photographs, facial scans, video KYC Calls

We may also request sensitive information about such as racial or ethnic origin (from your information on your country of origin) and/or your health or medical information.

b. Non-Personal Information

We may also gather non-personal information automatically, including:

• IP address logs (including time zone and location metadata)
• Passwords and security question answers
• Detail of transactions carried out through our website and platforms
• Device identifiers,Browser type and version
• Pages visited, time spent on the site click patterns, navigation paths
• Source of traffic
• Cookies and usage data, analytics data
• Error logs, crash reports and system diagnostics
• Your consent, any permission or preference given to Sea-Faj Consults
• Marketing and communications data such as details about you from emails, and conversations, chats between us and you and social media, your preference in receiving marketing messages from us and any third party companies on our behalf.

C. Communication Records

• Support chats (live or bot-assisted)
• Support emails
• Recorded phone conversations for compliance and quality assurance
• In app support interactions and alerts
• Voice messages and voice mail correspondence
• Feedbacks, complaints, satisfaction surveys and audit trails of response.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

4. HOW WE COLLECT YOUR PERSONAL DATA

We collect your data through the following avenues:

Directly from you

• When you visit our website, social media and use our services
• Sign up to our newsletter
• Participate in our webinars and programs
• Apply for jobs through our platforms
• register for, attend and/or otherwise take part in our events (e.g. at career fairs, school fairs)
• Click our links
• Submission of CV, Resume
• Through voluntary submissions like surveys or feedback forms
• Fill out forms and questionnaires
• Conversations with a member of our customer service teams by phone, social media platforms, emails and chat box
• Contact us for any reason

Automatically via platform use

• Cookies and tracking pixels installed on your browser
• Server logs and analytics tools embedded within dashboards
• Navigation behavior

From Third-party Sources

• Know your Customers service providers
• Affiliate and referral tracking systems
• Regulatory watchlists
• Public records, corporate registries and data vendors.

5. OUR LEGAL BASES FOR PROCESSING YOUR DATA

Depending on the type of personal data in question and the grounds on which we are processing it, should you decline to provide us with such data or ask us to stop processing it, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship or may have to bring that relationship to a close (i.e. because we cannot continue it without personal data about you).

Legitimate Interest

In the course of providing work-finding services to our clients and work-seekers and also providing international student recruitment services, where SEA-FAJ Consults acts as a Data Controller, it will be necessary, and in our legitimate interest to process personal data, as defined by the NDPA 2023, The NDPA General Application and Implementation Directive (“GAID”) 2025, DPA 2018, and the GDPR 2018. Data processing may also be necessary for legitimate business purposes such as fraud prevention, service improvement, and operational security.

We will process contact data as part of the Refer a Friend schemes on the grounds of legitimate interests. This is where referrals are made on behalf of people who needs our services by members of their social group. Each referral is processed on the basis that there is a legitimate interest in us helping to find work for the referred individual or provide international Student recruitment services.

Establishing, Exercising or Defending Legal claims

Sometimes it will be necessary for us to process personal data and, where appropriate and in accordance with our legal obligations, regulatory requirements and in connection with exercising or defending legal claims.

The relevant data laws and regulations allows this, where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

To Exercise our Rights or Carry out our Employment and Social Security Legal Obligations

For some clients, Temporary Workers and individuals it will sometimes be necessary for us to process your sensitive/special category personal data, for the purpose of ensuring compliance with our legal obligations and regulatory requirements.
For example, we may process your medical data to enable us to provide you with adequate support if you suffer from a health condition or disability, for example by sharing medical information about you with an occupational health specialist, in order to determine prognosis and return to work arrangements, and to assess your working capacity more generally.
The relevant data laws allows us to do this where the processing is “necessary for the purposes of carrying out the obligations and exercising [our or your] specific rights… in the field of employment and social security and social protection law”, as long as this is allowed by law.

Where processing your personal data is necessary for us to carry out our obligations under our Contract with you, to ensure that you are properly fulfilling your obligations to us, and to ensure that we are fulfilling our obligations to others.

The relevant data laws and regulations applies where processing of personal data “is necessary for the performance of a contract to which [you are] party or in order to take steps at [your] request … prior to entering into a contract”.

Where processing your personal data is necessary for us to carry out our Legal Obligations

In relation to the employment or engagement of Temporary Workers directly by us, as well as our obligations to you under our contract, we also have other legal obligations that we need to comply with.
An example of a legal obligation that we need to comply with is our obligation to co-operate with tax authorities.

Contractual Necessity

We process your personal data as may be necessary to provide services requested to you as our customer.

Electronic marketing

Where we send unsolicited electronic marketing to you we may also require either an opt-in consent or opt-out consent.That means we are permitted to market products or services to you which are related to the services we provide to you as long as you do not actively opt-out from these communications.

Consent

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent, or soft opt-in consent. Where processing of personal data is based on consent, Sea-Faj Consults will obtain explicit consent from the you before processing their data.
You have the right to withdraw your consent to these activities. You can do so at any time by contacting info@sea-fajconsults.com

6. HOW WE USE YOUR PERSONAL DATA

The information we collect is used to:

• Provide, operate, and maintain our website and services.
• Respond to inquiries or customer service requests.
• Understand your needs and preferences by communicating through our chat box, conducting brief surveys on our website
• Send periodic updates or newsletters (if subscribed).
• Verification purposes- verify contact information and identity (conducting references, qualification and background checks)
• Marketing and promotional purposes
• Improve our website’s functionality and user experience.
• Ensure compliance with legal and regulatory requirements.
• In appropriate circumstances we may also use candidates data in psychometric assessments
• Share with organizations we recruit for or partner with.
• Other incidental or related recruitment activities.
• Making a decision about your recruitment or appointment.
• Determining the terms on which you work for us or our clients.
• Checking you are legally entitled to work in the UK and EU.
• Administering the contract we have entered into with you.
• Business management and planning, including accounting and auditing.
• Conducting performance reviews, managing performance and determining performance requirements.
• Making decisions about salary reviews and compensation.
• Assessing qualifications for a particular job or task, including decisions about promotions.
• Making decisions about your continued employment or engagement.
• Education, training and development requirements.
• Ascertaining your fitness to work.
• Complying with health and safety obligations.
• To prevent fraud.
• To monitor your use of our information and communication systems to ensure compliance with our IT policies.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To conduct data analytics studies to review and better understand employee retention and attrition rates.
• Equal opportunities monitoring.

We will use or disclose your information for another purpose outside the purpose the data is collected for, only if you have consented, or if you would reasonably expect us to do so or as required by law.

Failure to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. WHO WE SHARE YOUR DATA WITH AND IN WHAT CIRCUMSTANCES

We may disclose your personal information to our partners for the purposes of delivering our services to you and to help run our business. Such as Service Providers, assisting us with website operations or email communication, partnere organizations, employers etc.
Where you use our services such as outsourcing services, International student Recruitment services, business consultancy, apply for a job through us, we may disclose your personal information to overseas recipients such as educational institutions located outside your home country, overseas visa agencies, IELTS test centers, professional bodies and commercial organizations our clients, and regulatory authorities, recruitment agencies, when you have sought out assistance to apply for study at those institutions or where disclosure is required for verification purposes. As such, the location of these overseas recipients would depend on the specific institutions to which you apply or where such verification is required. For events or conferences, we may disclose, with your consent, some of the information that is collected via the online registration form such as your name or your email to sponsors for marketing purposes.
We may hold or transfer the data we collect in or to the following countries (in addition to your home country: UK, US, Canada, Australia, EU and others. Your personal data is stored and accessed only as required to provide or services to you. Where we transfer your data to third parties, we maintain the confidentiality and security of the information being transferred. The data disclosed to overseas recipients consists of any information you have given us to provide the relevant services. By accepting services from us, you consent to us providing and sharing your personal information to the relevant overseas recipient as mentioned above. We take appropriate steps to ensure there are adequate safeguards in place for the transfer of your personal data.
We reserve the right to provide your personal data to third parties if required by law and regulatory Authorities.
We share your data with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive from us is targeted to you.
When you use our outsourcing services, apply for a job through us, we may disclose your data to our clients, overseas reciepents

8. HOW WE STORE AND TRANSFER YOUR PERSONAL DATA AND HOW LONG

We will store process your personal data as long as we have a business relationship with you in a secured computer storage facilities and paper based files and other records. We take the necessary measures to protect the personal data we hold about you from misuse, loss, unauthorized access, modification or disclosure.
If you instruct us to cease using or processing your personal data, we have the right to terminate any existing services to you within a reasonable time or immediately, as determined by the Company.
When we consider that personal data is no longer needed for the purpose for which it was collected, we may remove any details that may identify you or we may securely destroy the records. However, we may need to maintain records for a significant period of time (after you cease to be our client) subject to certain laws that require us to retain a copy of the documents we used in order to comply with our customer due diligence obligations as well as supporting evidence and records of transactions with you and your relationship with us.
For the personal data held in the form of an email, telephone, electronic, in person or otherwise recorded communication, the information will be retained in line with the requirements of our Regulatory Authority.
If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.
We may keep your data for a longer time than the retention period if for legal, regulatory or technical reasons we cannot delete it.
In order to provide you with the best service and to carry out the purposes described in this Privacy Policy; your data will be transferred:

• between and within SEA-FAJ Consults entities globally;
• to third parties (such as advisers or other Suppliers to the SEA-FAJ Consults business);
• to overseas Clients where applicable;
• to Clients within your country, where applicable, who may, in turn, transfer your data internationally;
• to a cloud-based storage

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of Nigeria UK, European Economic Area (EEA) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

• by way of data transfer agreement, for the transfer of personal data by to jurisdictions without adequate data protection laws; or
• transferring your data to a country where there has been a finding of adequacy in respect of that country’s levels of data protection via its legislation; or
• where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract
• where you have consented to the data transfer.

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with, and which respects the law on data protection.
We remain devoted to handling your data in an ethical manner, including:

• Mandating by contract that all sub-processors adhere to data protection legislation requirements;
• Ensuring that any data transfers are encrypted in transit;
• Storing your data on encrypted servers and networks;
• Undergoing yearly security audits;
• We will continue to monitor guidance from authorities and stay closely aligned with these developments including adjusting our practices accordingly.

9. DATA SECURITY AND PROTECTION

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet is 100% secure. We have put in place procedures to deal with any suspected data security breach and will notify you and applicable regulatory agencies of a suspected breach where we are legally required to do so.
If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately by emailing info@sea-fajconsults.com

Data Security is of great importance to SEA-FAJ Consults and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data. We take security measures to protect your information including:

• Limiting access to our buildings to those that we believe are entitled to be there by use of passes;
• Implementing access controls to our information technology;
• We use appropriate procedures and technical security measures (including strict encryption, anonymization and archiving techniques) to safeguard your information across all our computer systems and websites

10. USE OF COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance your experience. Cookies help us understand how you interact with our website and improve its functionality. You can manage your cookie preferences in your browser settings.

11. YOUR RIGHTS AS A DATA SUBJECT

You have the following rights regarding your personal data:

• Right to Access: Request a copy of the information we hold about you.
• Right to Correction: Request corrections to inaccurate data.
• Right to Deletion: Request the deletion of your data (subject to legal obligations).
• Right to Withdrawal of Consent: Withdraw consent to data processing where applicable.
• Right to restrict processing
• Right to rectification
• Right of data portability
• Right to lodge complaint with a supervisory authority

To exercise any of these rights, please contact us at info@sea-fajconsults.com.
Verification may be required before fulfilling certain requests to ensure the security of personal data.

12. THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We recommend reviewing their privacy policies before providing any personal information.

13. CHANGES TO THIS PRIVACY POLICY

We review and update our Privacy Policy periodically. We encourage that you check this page for the updated version of our privacy policy.

DATA BREACH MANAGEMENT

In the event of a data breach that poses a risk to individuals’ rights and freedoms, Sea-Faj Consults will notify the the appropriate authorities and affected individuals where required by law, and implement remedial measures to mitigate risks.

CONTACT US

If you have questions or concerns about this Privacy Policy or the processing of your personal data, please contact us:
Sea-Faj Consults Limted
Email: info@sea-fajconsults.com
Phone: +234 902 671 0818, +234 913 841 1677, +447851321594