We value your interest in Zenrox Healthcare Ltd, a registered company in Nigeria. The protection of your data is of utmost importance to us. Our website, www.zenroxmed.com, allows you to navigate through our offerings without providing any personal information. However, if you wish to access our specialized services, certain personal data processing may be necessary.
As the controller, Zenrox Healthcare Ltd has implemented extensive technical and organizational measures to provide maximum protection for the personal data processed through our website. However, please note that internet-based data transmissions may have inherent security vulnerabilities, and absolute protection cannot be guaranteed. Therefore, you are free to provide personal data through alternative means, such as telephone communication.
a) Personal Data:
Personal data refers to any information relating to an identified or identifiable natural person (“data subject”). Identifiability may arise from direct or indirect means, such as names, identification numbers, location data, online identifiers, or specific characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of the data subject.
b) Data Subject:
A data subject is an identified or identifiable natural person whose personal data is processed by the controller.
Processing encompasses any operation or series of operations performed on personal data, including collection, organization, storage, adaptation, modification, retrieval, use, disclosure, restriction, erasure, or destruction, whether automated or not.
d) Restriction of Processing:
Restriction of processing involves marking stored personal data to limit its future processing.
Profiling entails automated processing of personal data to evaluate specific aspects related to a natural person, such as job performance, economic situation, health, preferences, interests, behavior, or location.
Pseudonymisation refers to the processing of personal data in a way that no longer attributes it to a specific data subject without additional information, as long as the additional information is kept separate and subject to technical and organizational measures.
The controller is the natural or legal person, public authority, agency, or body that determines the purposes and means of personal data processing. If the purposes and means are determined by Union or national law, specific criteria for the controller’s designation may be provided.
The processor is a natural or legal person, public authority, agency, or other entity that processes personal data on behalf of the controller.
The recipient refers to any natural or legal person, agency, or entity to whom personal data is disclosed, whether or not they are a third party. However, authorities receiving personal data under Union or national law for specific tasks are not considered recipients.
j) Third Party:
A third party is any natural or legal person, public authority, agency, or body other than the data subject, controller, processor, or authorized individuals responsible for processing personal data.
Consent represents a voluntary and informed act of volition by the data subject, expressed through a statement or clear affirmative action.
At Zenrox Healthcare Ltd, we are committed to adhering to Nigerian privacy laws and protecting your personal data. Should you have any questions or require further clarification, please do not hesitate to contact us through the provided contact information on our website.
2. Name and address of the controller
The person responsible within the meaning of the General Data Protection Regulation, other data protection laws in the Member States of the European Union and other provisions of a data protection character is:
Zenrox Healthcare: td
Multipurpose Corporative Society Building,
76 Mobolaji Bank Anthony Way,
Tel.: +234 9083588880 / 9083588881
The Zenrox Healthcare Ltd website utilizes cookies, which are text files stored on a computer system through an Internet browser.
Cookies are commonly used by websites and servers, containing a unique identifier called a cookie ID. This ID allows websites and servers to differentiate a specific Internet browser from others, enabling personalized and user-friendly services on our website.
By using cookies, Zenrox Healthcare Ltd enhances the user experience and provides optimized information and offers. For instance, users won’t need to repeatedly enter their credentials when visiting the website, as the cookie stored on their computer system takes care of it. Additionally, cookies facilitate features like maintaining a virtual shopping cart in an online shop.
Users have the option to prevent the setting of cookies through their Internet browser settings, thereby choosing to disable this functionality. It’s important to note that disabling cookies may limit the full functionality of our website.
4. Collection of General Data and Information
Upon accessing the Zenrox Healthcare Ltd website, both individuals and automated systems contribute to the collection of general data and information. This data is stored in server log files and includes details such as browser types, operating systems, referrers, sub-web pages, access timestamps, IP addresses, and Internet service providers.
The purpose of collecting this general data and information is to ensure the correct delivery and optimization of website content, as well as the smooth operation of our information technology systems. It also aids in the enforcement of Nigerian laws and the protection of personal data. Zenrox Healthcare Ltd evaluates this data anonymously to enhance data protection and security measures.
5. Registration on Our Website
Data subjects have the option to register on the Zenrox Healthcare Ltd website by providing personal data through an input mask. This personal data is collected and stored solely for internal purposes, with the possibility of sharing it with processors who comply with our data protection standards.
Registration involves storing the data subject’s IP address, registration date, and time, serving as safeguards against potential misuse of services and enabling the investigation of committed offenses. Data subjects have the freedom to modify or delete their personal data from our database.
Zenrox Healthcare Ltd provides information regarding stored personal data upon request, allowing data subjects to correct or delete their information, subject to statutory storage requirements. Our contact information is available for all data subjects to reach out for assistance.
6. Subscription to Our Newsletter
On the Zenrox Healthcare Ltd website, users can subscribe to our company newsletter. The subscription process involves providing personal data via an input mask.
The newsletter informs customers and partners about our company’s offerings. Subscription requires a valid email address and registration, with a confirmation email sent using the double-opt-in procedure to verify the data subject’s consent.
The personal data collected during newsletter registration is used exclusively for sending the newsletter. Zenrox Healthcare Ltd does not disclose this data to third parties. Subscribers have the right to unsubscribe at any time, either through the provided link in each newsletter or by contacting us directly. Newsletter-Tracking
7. Newsletter Tracking
Zenrox Healthcare Ltd newsletters incorporate counting pixels, small embedded graphics in HTML emails that enable log file recording and analysis.
Counting pixels allow statistical evaluation of the success or failure of online marketing campaigns. They help determine if and when an email is opened and which links within the email are clicked by data subjects.
Collected personal data via counting pixels is stored and evaluated by Zenrox Healthcare Ltd to optimize newsletter delivery and tailor future content to the interests of data subjects. This personal data remains confidential and is not disclosed to third parties. Data subjects can withdraw their consent at any time.
8. Contact via the Website
Zenrox Healthcare Ltd provides contact information on our website to facilitate direct communication. When an individual contacts us via email or a contact form, the provided personal data is automatically stored and used for processing and communication purposes. This personal data is not disclosed to third parties.
9. Routine Deletion and Blocking of Personal Data
Zenrox Healthcare Ltd retains personal data only for as long as necessary to achieve the intended purpose of storage, in accordance with Nigerian laws and regulations. Once the storage purpose is no longer applicable or the prescribed storage period elapses, personal data is routinely blocked or deleted.
10. Submission of Reviews
With your consent, Zenrox Healthcare Ltd offers the opportunity to submit product reviews following a purchase. An email containing a link is sent to the customer’s registered email address, allowing the submission of an anonymous review. Revoking consent is possible at any time by contacting us via email.
External processors involved in enabling the submission of purchase evaluations comply with Article 28 of the Nigerian Data Protection Regulation. If consent to receive purchase evaluation emails is revoked, the corresponding email address will be blocked from further distribution. After six months, the data will be deleted from the email distribution lists.
For any further inquiries or assistance, please refer to our contact information provided.
11. Rights of the Concerned Subject
a) Right to Verification
Every individual has the privilege, as granted by Nigerian Laws, to request Zenrox Healthcare Ltd, a company registered in Nigeria, to confirm whether their personal data is being processed. If you wish to exercise this right, feel free to contact our dedicated team member at any time.
b) Right to Information
Any individual affected by the processing of personal data has the right, as granted by Nigerian Laws, to obtain free-of-charge information from Zenrox Healthcare Ltd regarding the personal data stored about them, as well as a copy of that information. Additionally, we provide the following details, as required by the Nigerian legislator and regulatory authority:
12. The purpose of processing
Categories of personal data being processed
Recipients or categories of recipients to whom the personal data has been or will be disclosed, including third parties or international organizations
If possible, the planned duration of personal data storage or the criteria used to determine the duration
The right to rectify or erase personal data, restrict processing, or object to processing
The right to lodge a complaint with a supervisory authority
If personal data is not collected directly from the data subject, information about its source
The existence of automated decision-making, including profiling, and meaningful information about the logic involved and its potential impact on the data subject
The right to know if personal data has been transferred to a third country or international organization, and if so, the appropriate safeguards in place
Should you wish to exercise your right to information, please don’t hesitate to reach out to our dedicated team member.
Right to Rectification
Any individual affected by the processing of personal data has the right, as granted by Nigerian Laws, to request the immediate correction of inaccurate personal data concerning them. Furthermore, the data subject has the right to have incomplete personal data completed, taking into account the purposes of processing. To exercise the right to rectification, kindly contact our dedicated team member.
Right to Erasure (Right to be Forgotten)
Any individual affected by the processing of personal data has the right, as granted by Nigerian Laws, to request the erasure of their personal data without undue delay under certain circumstances, including:
- The personal data is no longer necessary for the purposes it was collected or processed
- The data subject withdraws their consent and there is no other legal basis for processing
- The data subject objects to the processing and there are no overriding legitimate grounds
- The personal data has been unlawfully processed
- The erasure is necessary to comply with a legal obligation
- The personal data has been collected in relation to the offer of information society services to a child
To initiate the erasure of personal data stored by Zenrox Healthcare Ltd, please contact our dedicated team member. If the personal data has been made public, we will take appropriate measures, including technical ones, to inform other data controllers who process the data about the data subject’s request for erasure.
Right to Restriction of Processing
Any individual affected by the processing of personal data has the right, as granted by Nigerian Laws, to request the restriction of processing under certain circumstances, including:
The accuracy of the personal data is contested by the data subject, allowing the controller to verify its accuracy
The processing is unlawful, but the data subject opposes erasure and requests restriction instead
The controller no longer needs the personal data for processing, but the data subject requires it for the establishment, exercise, or defense of legal claims
The data subject has objected to the processing, pending verification of whether the legitimate grounds of the controller override those of the data subject
To request the restriction of personal data processed by Zenrox Healthcare Ltd, please contact our dedicated team member.
Right to Data Portability
Any individual affected by the processing of personal data has the right, as granted by Nigerian Laws, to receive the personal data concerning them, which they have provided to Zenrox Healthcare Ltd, in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance, provided that the processing is based on consent or a contract and carried out by automated means. To exercise the right to data portability, please contact our dedicated team member.
Right to object
At any time, you possess the right to object to the processing of your personal data pursuant to Article 6 (1) (e) or (f) of the Nigerian Data Protection Regulation (NDPR). This right extends to any profiling based on these provisions.
Upon receiving your objection, Zenrox Healthcare Ltd will cease processing your personal data, unless we can demonstrate compelling legitimate reasons that outweigh your interests, rights, and freedoms, or if the processing is essential for the establishment, exercise, or defense of legal claims.
Should we utilize your personal data for direct marketing purposes, you possess the right to object to such processing at any time, including profiling associated with direct mail. Once you object to processing for direct marketing, we will no longer process your personal data for this purpose.
Moreover, if you have specific reasons arising from your particular situation, you can object to the processing of your personal data for scientific, historical, research, or statistical purposes as stated in Art. 89 (1) NDPR, unless such processing is necessary for a public interest task.
To exercise your right to object, you may directly contact any employee of Zenrox Healthcare Ltd or use automated procedures through technical specifications within the context of information society services.
Automated decisions in individual cases including profiling
As per the Nigerian legislature, you have the right not to be subject to a decision based solely on automated processing, including profiling, if it has legal effects on you or significantly affects you in a similar manner. However, exceptions apply if the decision is necessary for the performance of a contract, allowed by Nigerian Laws, or made with your explicit consent.
In cases where such decisions are necessary for a contract or made with your consent, Zenrox Healthcare Ltd will ensure that appropriate measures are taken to safeguard your rights and legitimate interests. This includes your right to obtain human intervention, express your position, and challenge the decision.
To claim your rights regarding automated decision-making, you can always contact an employee of Zenrox Healthcare Ltd.
Right to revoke a data protection consent
As an individual affected by the processing of personal data, you have the right to withdraw your consent to the processing of your personal data at any time, in accordance with the Nigerian directive and regulatory authority.
If you wish to assert your right to withdraw consent, feel free to contact any employee of Zenrox Healthcare Ltd.
Legal basis of processing
Zenrox Healthcare Ltd relies on different legal bases for processing operations:
When we obtain your consent for a specific processing purpose, Art. 6 (1) lit. A NDPR serves as the legal basis.
If processing your personal data is necessary for the performance of a contract in which you are a party, Art. 6 (1) lit. B NDPR serves as the legal basis. This includes processing operations necessary for the supply of goods or provision of services.
In cases of pre-contractual measures, such as inquiries regarding our products or services, processing is based on Art. 6 (1) lit. B NDPR.
If we are under a legal obligation that requires the processing of personal data, such as tax obligations, the legal basis is Art. 6 (1) lit. C NDPR.
Rarely, personal data may need processing to protect vital interests, for example, when a visitor is injured on our premises and their data must be shared with a healthcare provider. In such cases, processing is based on Art. 6 (1) lit. D NDPR.
Please note that these rights are subject to certain conditions and limitations as stipulated by Nigerian Laws. At Zenrox Healthcare Ltd, we are committed to protecting your privacy and ensuring your rights are respected. If you have any concerns or queries regarding your personal data, please don’t hesitate to reach out to our dedicated team member who will be happy to assist you.