Privacy Policy


of Smart Stewards Advisory Limited














Version 1.0

Contents

1.    Introduction    3

2.    Personal data we collect    3

2.1.    Registration and Subscription    3

3.    How we use personal data    3

4.    Sharing    4

5.    Storage    5

6.    Security    5

7.    Cookies    5

8.    Links    6

9.    Surveys & Contests    6

10.    Notification of Changes    6

11.    Contact Details    6



  1. Introduction

This privacy policy discloses the privacy practices for Smart Stewards Advisory Limited (‘’Smart Stewards’’ or the ‘’Company’’) and on any of our interfaces including our websites, applications and groups on online or offline platform. (“Platforms”)This Policy describes how Smart Stewards (“we”, “us”, “our”) collects, uses, shares, stores and secures the Personal Information of the Users (“you”, “your”). This privacy notice applies solely to information collected on this Platform, except where stated otherwise. Platforms in this policy refers to our website, apps or any of our platforms on third party websites or apps where you interact with us. It will notify you of the following:




  1. Personal data we collect

Smart Stewards collects data from you, through our interactions with you and through our services. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our services. The data we collect depends on the context of your interactions with Smart Stewards and the choices you make, including your privacy settings and the services and features you use. We also obtain data about you from third parties.


You have choices when it comes the data you share. When we ask you to provide personal data, you can decline. Many of our services require some personal data to provide you with a service. If you choose not to provide the data required to provide you with our service, you cannot use that service. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing service you are using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.


It is compulsory to provide the information required on the registration in order to access our services, if you choose not to provide this information, we may be unable to provide you with the services or you may only have limited access to our services., By giving us this information, you agree to this information being collected, used and disclosed as described in this privacy policy.


  1. Registration and Subscription

In order to use this Platform, we request information from you on our application form. To subscribe or make payment to our services, you must provide contact information (like name, phone number, address) and financial information (like credit card number, expiration date). This information is used for billing purposes and to manage your orders, payments and inventory. If we have trouble processing an order, we will use this information to contact you.

Also, this information may be used to contact you about the services on our Platform in which you have expressed interest. At your option, you may also provide demographic information (such as gender or age) about yourself, but it is not required.


  1. How we use personal data

Smart Stewards uses the data we collect to provide you with rich, interactive experiences. We use data to:


In carrying out these purposes, we combine data we collect from different contexts or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.


Our processing of personal data for these purposes includes both automated and manual (human) methods of processing.


  1. Sharing

Ensuring your privacy is important to us. We may be required to share or disclose personal information about you to both internally within Smart Stewards, and externally with third parties as part of providing our services, management and operation. Such third parties include (a) third party service providers (b) business partners (c) affiliated companies within our corporate structure (d) law enforcement agencies (e) government agencies and (f) as needed for legal purposes. These third parties are contractually bound to use the personal information only to perform the services that we engage them to provide.

We may also share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person. If you prefer that we do not share your demographic information, please tick □ No.



We use a credit/debit card processing company to bill users for services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond filling your order.


We partner with another party to provide specific services. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.


Your information may, for example, be transferred or transmitted to, or stored and processed in Nigeria or other countries outside for the purposes as described in this policy. We will transfer it out of Nigeria or other countries with your consent or to perform a contract with you. We will apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this policy. By providing your personal information to us, you are consenting to the transfer, storing, and processing of your personal information outside of the Nigeria or other countries. We shall take reasonable steps to ensure that any such overseas entities are contractually bound not to use your personal information for any reason other than to provide the services they are contracted by us to provide and to adequately safeguard your personal information


  1. Storage

Data received from Smart Stewards are automatically synced and saved in a very secured environment with redundancy implementation applied, the security of the storage includes firewall policies, password policies to prevent unauthorized access. We take every precaution to protect your data against accidental loss and from unauthorized access, use, alteration, and disclosure.

Despite our best efforts, transmission of data of any kind is never 100% secure. Although, we endeavor to protect your Personal Data, we cannot guarantee with absolute certainty the security of your Personal Data.


We store data until it is no longer necessary to provide our services, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.


  1. Security

We take precautions to protect your information. When you submit sensitive information via the Platform, your information is protected both online and offline.


Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser or looking for "https" at the beginning of the address of the web page.


We restrict access to your data to the employees of the Company who need to know that information to provide services to you. We train those employees about the importance of confidentiality and maintaining the privacy and security of your information. Service Providers and vendors have access to data to perform their functions but may not use it for other purposes.


However, despite our efforts, no security controls are 100% effective, and we cannot ensure or warrant the security of the data you provide to us. There is no guarantee that the data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.


Smart Stewards shall not be liable for any claims whether direct, consequential, incidental, special, exemplary or punitive damages of any nature including loss of data, revenue, anticipated profit or intangible losses (even if Smart Stewards has been advised of the possibility of such damages).


The services may, from time to time, contain links to other websites. If you follow a link to any of these websites, please note that they may have their own privacy policies and that we do not accept any responsibility or liability for these policies or websites. Please check these privacy policies before you submit any data. This policy applies only to information collected by the services and by us and not to other websites that you may link to from here.


  1. Cookies

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices.

Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this policy, we refer to all of these technologies as “cookies.”


We use cookies if you have an account, use our services, including our Platform, or visit other websites and apps that are linked to Smart Stewards’ Platform. Cookies enable Smart Stewards to offer the Company’s services to you and to understand the information we receive about you, including information about your use of other websites, whether or not you are registered or logged in.


Why do we use cookies?

  1. Authentication.

  2. Security, site and service integrity

  3. Performance.


Where do we use cookies?

We may place cookies on your computer or device, and receive information stored in cookies, when you use or visit:



  1. Links

This site and applications contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.



  1. Surveys & Contests

From time-to-time our site requests information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information. Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.



  1. Notification of Changes

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will provide notice on our Platform, and we may notify you by e-mail address specified in your account, prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy policy practices. If you continue to use the services after those changes are in effect, you agree to the revised policy.



  1. Contact Details

If you have any need to contact the data privacy team/data controller, you can do so by sending a mail to (enter email address of data protection team/data controller) and your request will be handled immediately. Our data protection officer can also be contacted through this email, (enter email address of data protection officer).


Please use the contact details provided above if you wish to: