1. Scope of this notice
This notice applies to personal data collected through https://penduluminsurancebrokers.com, by email, telephone, WhatsApp, in person at our offices, and during insurance-broking, risk-advisory, policy-placement, renewal and claims-support activities.
It does not govern an insurer’s independent use of personal data. Insurers, healthcare providers, loss adjusters and other independent organisations may provide their own privacy notices.
2. Personal data we collect
Depending on your interaction with us, we may collect:
- identity and contact details, including name, telephone number, email and address;
- organisation, occupation or employment information;
- enquiry details, preferred contact channel and correspondence with us;
- insurance needs, existing policy information, insured assets, claims information and supporting documents;
- payment, transaction or premium-related records where relevant;
- information required by insurers for quotation, underwriting, placement, renewal or claims assessment; and
- technical information generated by hosting or security systems, such as IP address, browser type, device information, timestamps and website activity.
Some insurance services may require sensitive personal data, including health information. Please do not send health details, identity numbers, payment-card information or policy documents through the initial website enquiry form. We will explain an appropriate collection method if that information becomes necessary.
We generally obtain information directly from you, but may also receive it from an authorised representative, employer, insurer, healthcare provider, loss adjuster, professional adviser, public record or another party involved in an insurance transaction.
3. How we use personal data
We may process personal data to:
- respond to enquiries and arrange consultations;
- understand risks and provide insurance or risk-advisory services;
- obtain quotations and present risks to appropriate insurers;
- arrange, administer and review policies;
- support renewals, endorsements, complaints and claims;
- communicate service information and maintain client relationships;
- meet legal, regulatory, accounting, audit and record-keeping obligations;
- prevent fraud, misuse, money laundering and other unlawful conduct;
- protect our website, systems, staff, clients and business; and
- improve our services and website performance.
We will use personal data for direct marketing only where permitted by law. You may opt out of marketing at any time without affecting service-related communications.
4. Lawful bases for processing
Under the Nigeria Data Protection Act 2023, we process personal data where necessary to take steps at your request or perform a contract; comply with a legal obligation; protect vital interests; carry out a task in the public interest; pursue a legitimate interest that is not overridden by your rights; or where you have given valid consent.
Where consent is the basis, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before withdrawal or processing supported by another lawful basis.
6. International transfers
Some insurers, reinsurers or service providers may process information outside Nigeria. Where a cross-border transfer occurs, we will take steps required by applicable law, which may include confirming an adequate level of protection, using appropriate contractual safeguards or obtaining consent where required.
7. How long we keep personal data
We retain personal data only for as long as reasonably necessary for the purpose collected, including service delivery, policy administration, claims, legal or regulatory requirements, dispute resolution and fraud prevention.
Retention periods depend on the type of record, the insurance relationship, applicable limitation periods and instructions or requirements from regulators and insurers. When information is no longer required, we will securely delete, destroy or anonymise it.
8. How we protect personal data
We use proportionate administrative, physical and technical safeguards intended to protect personal data from accidental loss, unauthorised access, alteration, disclosure or destruction. Access is limited to people and providers who need the information for an authorised purpose.
No internet transmission or storage system is completely secure. If a personal-data breach occurs, we will investigate and notify affected persons or the Nigeria Data Protection Commission where applicable law requires it.
9. Your data-protection rights
Subject to applicable conditions and exemptions, you may have the right to:
- receive information about how your personal data is processed;
- request access to personal data we hold about you;
- request correction of inaccurate or incomplete information;
- request deletion where there is no lawful reason to retain the data;
- request restriction of certain processing;
- object to processing, including direct marketing;
- withdraw consent where processing relies on consent;
- request data portability where applicable;
- not be subject to certain solely automated decisions with significant effects; and
- lodge a complaint with the Nigeria Data Protection Commission.
To exercise a right, contact us using the details below and describe your request. We may ask for information needed to confirm identity and authority. Rights are not absolute, and we will explain if a request cannot be fulfilled in whole or in part.
11. Children’s privacy
This website is not directed to children, and children should not submit personal data without the involvement of a parent or legal guardian. Where an insurance product concerns a child, we will collect and process relevant information through an authorised adult and apply the safeguards required by law.
12. Third-party links and changes to this notice
Links to third-party websites or platforms are provided for convenience. Their privacy practices are governed by their own notices, and we encourage you to review them.
We may update this notice to reflect changes in our services, practices or legal obligations. The revised version will be published here with an updated date. Material changes may also be communicated through an appropriate additional channel.
13. Contact and complaints
For privacy questions, rights requests or complaints, email info@penduluminsurancebrokers.com, call 0706 802 8720, or write to our Head Office at 1 Idito Street, Poly–Eleyele, Ibadan State, Nigeria.
We will try to resolve privacy concerns directly. You also have the right to complain to the Nigeria Data Protection Commission.