Menu
1. INTRODUCTION
This website, https://kennapartners.com/ (“Platform”), is operated by Kenna Partners (hereinafter referred to as “we”, “our”, “us” or “Kenna Partners”).
Kenna Partners is dedicated to safeguarding the privacy of our website visitors and strive to handle information shared with the Firm with the highest level of care and professionalism and in compliance with the Nigerian Data Protection Act, 2024 as well as other extant data protection laws and regulations. For the purpose of this Act, the data controller for this Website is Kenna Partners, located at No 8 Ogunyemi Road, Oniru, Victoria Island, Lagos.
If you have questions or require more information regarding this Privacy Policy, please contact us at counsel@kennapartners.ng
2. PURPOSE
The Privacy Policy is designed to inform visitors to our website and other third parties with regards to the information that they shared and/or collect in Kenna Partners how we collect, use, disclose, and protect the personal information you provided to us through our website.
This Privacy Policy is based on the privacy and data protection principles as outlined in the laws and regulations guiding data privacy in Nigeria. This Statement is intended to summarise the firm’s data protection practices generally.
This Statement is also specifically addressed to parties outside the firm who provide Personal Information to the firm or who visit or use the firm’s websites, our social media sites, as well as email messages that we send to you that contain a link to this Statement (collectively, the “Internet Services”). We aim to be transparent about our practices to ensure you feel confident and secure when interacting with our site and services.
3. DEFINITIONS
Consent: any freely given, specific, and unambiguous indication, whether by a written or oral statement or an affirmative action, of an individual’s agreement to the processing of personal data relating to him or to another individual on whose behalf he has the permission to provide such consent
Data Protection Legislation: means the Nigeria Data Protection Act 2023 and other applicable data protection laws and all other application legislation relating to privacy or data protection.
Data Subject: an individual to whom personal data relates.
Data Controller: an individual, private entity, public Commission, agency or any other body who, alone or jointly with others, determines the purposes and means of processing of personal data
Data Processor: an individual, private entity, public authority, or any other body, who processes personal data on behalf of or at the direction of a data controller or another data processor.
Personal Information: information relating to an individual, who can be identified or is identifiable, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, psychological, cultural, social, or economic identity of that individual.
Processing: any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction and does not include the mere transit of data originating outside Nigeria.
4. COLLECTION AND USE OF PERSONAL INFORMATION
The firm collects Personal Information in the course of providing legal services to clients and as provided by visitors to its website or users of Internet Services. We may also collect Personal Information about you when you interact with us on social media sites and from other third parties and may also automatically collect information that may contain Personal Information as described below in the cookie policy.
We may collect or receive your personal data in a number of different ways:
Where you provide it to us directly, for example by corresponding with us by email, or via other direct interactions with us such as completing a form on our website or registering for and using one of our online tools;
Where we monitor use of, or interactions with, our websites, any marketing we may send to you, or other email communications sent from or received by Kenna Partners;
Publicly available sources – we may, for example, use such sources to help us keep the contact details we already hold for you accurate and up to date or for professional networking purposes, e.g. LinkedIn.
Registration details: we may collect or obtain your Personal Data when you use, or register to use, any of our services.
Third Party information: we may obtain relevant personal data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities, etc.) or from any third-party content or advertising on a site or in an App, you choose to interact with.
5. CONSENT OF DATA SUBJECTS
In order to process the data we obtain from you, your consent is required. It may be provided orally, in writing or via electronic means. You also have a right to withdraw the consent which you had earlier given at any point in time. However, the withdrawal of your consent shall not affect the lawfulness of the data processing that occurred before you withdrew your consent.
6. DATA OF CHILDREN (UNDER 18)
Anyone who is below the age of 18 (eighteen) is considered a person who lacks legal capacity. In that instance, we endeavour to obtain the consent of the parent or legal guardian of the child and verify the information as well as the consent provided. We encourage parents and guardians to observe, participate in, and/or monitor and guide their wards online activities.
Kenna Partners does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
7. CATEGORIES OF PERSONAL DATA WE MAY COLLECT:
We may collect the following categories of Personal Data about you:
• Personal and Contact details including names(s), preferred name, photograph, gender; date of birth/age, nationality, salutation, title and language preferences, passport or national identity number, utility provider details, bank statements, correspondence address, telephone number, email address; and details of your public social media profile(s).
• Special categories of data: where you have provided us with such information as it is necessary for a specific service, we are providing to you: religious or other beliefs, racial or ethnic origin, sexual orientation, health data and details of trade union membership.
• Details of the matter as it relates to individuals instructing Kenna Partners, Personal Data included in correspondence, transaction documents, evidence or other materials that we process in the course of providing services and legal advice.
• Registration data: Newsletter and article requests, event/seminar registrations, subscriptions, downloads, and username/passwords.
• Marketing Data: Data about individual participation in conferences and in-person seminars, credentials organized by or on behalf of Kenna Partners that you have attended.
• Consent records: records of any consent you may have given, together with the date and time, means of consent and any related information.
• Job applicant data: Data provided by job applicants or others on our Sites or offline means in connection with employment opportunities.
• Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.
• Internal communication records: information concerning the use of, and Personal Data transmitted through, internal IT systems {e.g., emails, telephone records); and work-related social media accounts.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
• Device data: we may also be privy to your Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data). and collect same for record purposes.
8. CREATION OF PERSONAL DATA:
We may create Personal Data about you: records of your interactions and communications with us, or interviews in the course of applying for a job with us.
9. PURPOSES AND LEGAL BASIS FOR PROCESSING
We may use that Personal Information for the following purposes:
• To provide legal and other services to you – to administer and perform our services consistent with our terms of engagement.
• To facilitate the use of our websites and to ensure content is relevant– to respond to requests enquiries from visitors to our websites and to ensure that content from our websites is relevant and updated.
• For marketing and business development purposes – to provide you with details of new services, legal updates and invites to seminars and events where you have chosen to receive these.
• For research and development purposes – analysis in order to better understand your and our clients’ services and marketing requirements and to better understand our business.
• For recruitment purposes – to enable us to process applications for employment submitted via the Careers section of our website and to assess your suitability for any position for which you may apply at Kenna Partners.
• To fulfil our legal, regulatory, or risk management obligations – to comply with our legal obligations for the prevention of fraud and/or other relevant background checks as may be required by applicable law and regulation and best practice at any given time.
• To inform you of changes – to notify you about changes to our services or our Standard Terms of Engagement for legal services or this Privacy notice.
9. COMMUNICATIONS (INCLUDING MARKETING)
We use your information for marketing purposes and to send you relevant communications about our qualifications, our products and services and any other relevant events. We may use your contact details to send you information or to notify you of any updates and changes to our services.
You will have the right to withdraw your consent for these at all times, and we will make this process as easy as possible.
We also use your information for custom audience social media campaigns, such as information about relevant recruitment opportunities. This allows us to present you with the most relevant information to yourself across all our channels.
We will not pass your information on to other marketing providers, and we will not sell your information to any third party.
10. CONFIDENTIALITY, SECURITY, AND RETENTION OF PERSONAL INFORMATION
Consistent with our professional obligations, it has always been the policy of the firm to exercise the utmost discretion regarding the information our clients entrust to us.
We implement and maintain a range of reasonable and appropriate, physical, technical, electronic and procedural safeguards intended to maintain the confidentiality of Personal Information, including that provided by a visitor to this website and provided while using other Internet Services to help protect them from unauthorised access, use, disclosure, alteration or destruction in accordance with data protection law requirements. Information that you provide to us is stored on our or our service providers’ secure servers and accessed and used subject to our security policies and standards, or those agreed with our service providers.
We do not accept responsibility for sites controlled by third parties. Please ensure to review these other sites’ privacy policies, we do not accept any responsibility for their use of your personal information.
We require third-party service providers s to maintain data protections consistent with reasonable and appropriate obligations of data processors, including, where applicable, data protection laws and regulations in Nigeria.
11. DISCLOSURE OF PERSONAL INFORMATION
We do not disclose any Personal Information to unrelated parties outside of the firm and its affiliates except in limited circumstances. Such circumstances include disclosures to our agents or data processors or other contractors acting on our behalf and at our direction, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party, or where we believe it necessary to provide a service which you have requested, or as permitted or required by law, or as otherwise authorized or directed by you.
If you provide us with Personal Data relating to other persons (such as family members, work colleagues, employees, etc.), you are responsible for ensuring the relevant individuals are made aware of the terms of this Privacy Policy and that you are legally entitled to provide us with their Personal Data. You are also responsible for ensuring that their Personal Data is accurate and up-to-date.
12 CROSS-BORDER DATA TRANSFER
Subject to your consent, we may also transfer your personal data cross-border where in your interest, in the interest of the public, or for legal claims. We may transfer your data only where the recipient of your personal data is subject to a law, binding corporate rules, contractual clauses, code of conduct, or mechanism that affords an adequate level of protection which is in accordance with the NDPA 2023.
13. THIRD PARTY SITES
Our websites contain links to other sites which are controlled by third parties. If you click on these links, Kenna Partners is not to be held responsible for your data and privacy protection. Visiting those websites is not governed by this privacy policy agreement. You should review these other sites’ privacy policies. We do not accept any responsibility for their use of your personal information.
14. RETENTION OF YOUR PERSONAL DATA
We will retain your personal data in line with the laws and regulations guiding data protection in Nigeria. The data will be retained to fulfil the purpose for which it was collected and any other legally permitted purpose (for example certain transaction details and correspondence related to any legal services we provide may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data).
How long will my Data be held for?
We will retain your details for as long as they are needed for the relevant purposes listed in the section “Purposes and Legal basis for Processing” above. We may also retain certain records for other legitimate reasons (including after your relationship with us has ended), for example to resolve any potential disputes and to comply with other reporting and retention obligations.
How we protect your personal data
We implement a range of commercially reasonable physical, technical and procedural measures to help protect personal data from unauthorised access, use, disclosure, alteration or destruction in accordance with data protection law requirements.
Information that you provide to us is stored on our or our service providers’ secure servers and accessed and used subject to our security policies and standards, or those agreed with our service providers.
Any third-party service providers we may engage that process personal data on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of personal data.
15. RIGHTS IN RELATION TO YOUR PERSONAL DATA
If you have any questions about our use of your personal data, you should first contact us via the details provided below. Under certain circumstances and in accordance with the applicable data protection laws, you may have the right to require us to:
• provide you with further details on the use we make of your information
• provide you with a copy of information that we hold about you;
• update any inaccuracies in the personal data we hold;
• delete any personal data that we no longer have a lawful ground to use;
• where processing is based on consent, to withdraw your consent at any given time so that we stop that particular processing;
• object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
• restrict how we use your information whilst a complaint is being investigated.
You also have the following Rights:
1. Right to lodge a complaint with the Nigerian Data Protection Commission in accordance with the provision of the Nigerian Data Protection Act 2023.
2. Right to object to and challenge data processing either by us or third parties to whom we share your data to.
3. Right to inform you of any personal data breach that is likely to result in a high risk to your rights and freedoms in plain and clear language, including advice about measures you can take to mitigate effectively the possible adverse effects of the data breach.
4. Right to confirm as to whether we or a third-party data processor operating on your behalf, are storing or otherwise processing your personal data
5. Right to request from us, rectification or erasure of your personal data, or restriction of processing of your personal data or to object to such processing.
6. Right to know the recipients or categories of recipient to whom your personal data have been or will be disclosed, particularly recipients in third countries or international organisations.
7. Right to know the period for which your personal data will be stored, or, if not possible, the criteria used to determine that period.
8. The right to be forgotten
9. Right to have a copy of your personal data in a commonly used electronic format, except to the extent that providing such data would impose unreasonable costs on us, in which case we may require you to bear some or all of such costs.
10. Right to the correction or, if correction is not feasible or suitable, deletion of your personal data that is inaccurate, out of date, incomplete, or misleading.
11. Right to restrict data processing pending – the resolution of a request, or an objection by you under the NDPA 2023, or the establishment, exercise, or defense of legal claims.
12. Where personal data is processed for direct marketing purposes, you shall have the right to object, at any time, to the processing of your personal data, which includes profiling to the extent that it is related to such direct marketing.
13. Right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal or similar significant effects concerning you.
You have the right to also ask us not to process your personal data for marketing purposes. We will inform you if we intend to disclose your information to any third-party service provider for this purpose. As indicated above, you can exercise your right to prevent such processing at any time by using an unsubscribe facility or contacting us at counsel@kennapartners.ng.
We are also required to take reasonable steps to ensure that your personal data remains accurate. In order to assist us with this, please let us know of any changes to the personal data that you have provided to us by contacting us at counsel@kennapartners.ng.
While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.
If you contact us to exercise any of these rights, we will check your entitlement and respond in most cases within two weeks.
16. MONITORING AND REVIEW
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.
<Date of last revision – August 2024>
