Introduction

White Dove Shipping Company Limited (WDSCL) (“White Dove Shipping” “we” “our” “us”) values the confidentiality of personal data. This document details how White Dove Shipping uses and protects personal data in accordance with the Nigeria Data Protection Regulation 2019 (NDPR) and other applicable privacy and data protection laws in Nigeria.

This Privacy Notice also details how we collect and process your personal data when you interact with us. We have also detailed here what rights you have as a data subject under applicable laws. This Privacy Notice applies to every data subject (clients, vendors, consultants amongst others) who interact with us. Note that this Privacy Notice does not apply to job applicants or to employees.

Please read this document carefully to ensure informed consent. We take your privacy seriously and we will not abuse your trust by disclosing, exporting, or dealing with your personal data in a manner that is contrary to this Privacy Notice, the NDPR or applicable laws.

This Privacy Notice is drafted in accordance with the NDPR, the NDPR Implementation Framework and applicable laws.

About Us

White Dove Shipping operates a fleet of marine vessels ranging from crude oil tankers (Panamax: 60,000–80,000, Aframax: 80,000–120,000, Suezmax: 120,000–200,000, VLCC: 200,000–320,000), patrol boats, crew boats, anchor handling tugs, supply vessels and bunker dumb barges for Oil and Gas operations. For more information, please visit https://whitedove-shipping.com/about/

The Information We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data such as:

  • Identity Data: names, usernames or similar identifiers, Identification card titles, date of birth and gender, professional background, employment history, tax status, job title etc.
  • Contact Data: home address, country of residence, billing address, delivery address, email address and telephone numbers
  • Contract or Business Data: information on type of contract, duration of the contract, contractual obligations and entitlements, complaints and feedback.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.

Information About Other People

If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used and that they have given their consent for you to disclose it to us and for you to allow us, and our outsourced service providers to use it.

Sources We Collect Your Personal Data From

We use different methods to collect personal data from you and they include:

    • Direct interactions:You may give us your personal data by filling a physical or online form, entering visitors’ books or login or by corresponding with us by post, phone, email among others. If you wish to enter into a contract with us or use our services, you will have to provide us with certain personal data of yours.
    • Automated technologies or interactions:We collect these personal data as you interact with our website. These include personal data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details. We also collect your information using closed circuit television hung in our physical office.
    • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources available to us such as social media, public authorities, contractual partners, associations, and credit agencies amongst others

How We Use Your Personal Data

We process your personal information for several purposes, such as:

  • Communicating with you with regards to inquiries and exercise of your rights and also to enable us to contact you as may be required and in case of queries or marketing. Where the purpose of our communication is solely for marketing purposes, you have an absolute right to object to any further communication pertaining to marketing. We will provide you with opt-in and opt-out options in this regard.
  • To comply with the contractual obligation owed to you. We use contract or business data for this purpose. Our legal basis is the performance of the contract.
  • To undertake marketing activities regarding our services or products. We use technical data, communication and contact data. We will obtain your consent before sending you marketing emails. However, in certain circumstances such as where you have transacted with us, we may rely on our legitimate interest to send marketing emails to you without obtaining your prior consent, however, we will provide an option to indicate your desire to receive or not to receive further marketing emails from us.
  • We strive to improve our services and to respond to changing needs. To this end, we use technical data, communication data, customer surveys, and polls to achieve this aim. We may use pseudonymized data for this purpose.
      • To deliver services to clients and make payments to third-party suppliers and service providers. We use identity data, financial data, and communication data for this purpose. We process these personal data based on the contract between us or the entity you represent and on our or third-party’s legitimate interest.
      • To defend and exercise our legal rights and to comply with the provisions of applicable laws and regulations.
      • To perform KYC or due diligence checks on prospective clients, vendors, service providers, investors, etc. we use identity data, contact data, financial data, and communication data to achieve this purpose.

Further Purpose

We will only process your personal data for the particular purposes for which we collected it. We will notify you and obtain your consent before using it for any further purpose that is not compatible with the original purpose. Please note that we may process your personal data in compliance with the above rules subject to the provisions of the NDPR and applicable laws

Legal Bases for Processing Your Personal Data

We may process your personal data on one or more lawful grounds depending on the specific purpose for which we are using your personal data. Kindly contact us if you need further details or clarity about the specific legal ground, we are relying on to process your personal data where more than one ground has been stated. We will rely on any of the legal bases listed below depending on the processing activities:

    • We will ask you for your consent in certain processing activities that involve sensitive personal data or marketing mailing. Where we obtain your consent, kindly note that you can withdraw the consent at any time and we will comply.
    • We may process your personal data based on the contract you have entered with us or take pre-contractual steps at your instruction.
    • We may process your personal data in order to perform legal obligations imposed on us by law.
    • We may also process your personal data for public interest or in the exercise of official public mandate vested in us.
    • We may also process your personal data for the protection of your vital interest or that of another natural person.

What Constitutes Consent

We rely on consent to process some of your personal data. Where we require your consent, ticking a yes/no box, endorsing your signature in a form or document, and clicking “accept button” on our website will constitute consent.

Cookies

We use cookies and other tracking technologies on our website. Cookies are small pieces of text that are saved on your Internet browser when you use our website. The cookies are sent back to our computer each time you visit our website. Cookies make it easier for us to give you a better experience online. You can stop your browser from accepting cookies, but if you do, some parts of our website or online services may not function appropriately. Please read our comprehensive cookies policy for more information.

Whom Do We Share Your Personal Data With?

    • Vendors, consultants, and other service providers:
      We may share your Personal data with third-party vendors, consultants, and other service providers we engage to provide services or perform certain tasks. These include our payment processing service providers, website analytics companies (e.g., Google Analytics), tools used to prevent spam and other security risks related to the use of abusive automated software (e.g., Google reCAPTCHA), service feedback or help desk software providers (e.g., Salesforce), CRM service providers (e.g., Salesforce), email service providers and others. We may also share your personal data with other subsidiaries of White Dove Shipping, a court of law, and government agencies subject to provisions of applicable laws.
    • Disclosures for national security or law enforcement
      Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, court of law and government agencies for the purpose of national security or to meet enforcement requirements, or in compliance with other legal obligations.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    Principles of Data Protection

    We are obligated to comply with data protection principles whenever we process your personal data and to inform you about these principles. These principles include:

    • We will inform you about the personal data we have about you, and the lawful basis for processing it.
    • We must use your personal data in a way you reasonably expect and in a manner that ensures transparency, lawfulness, and fairness.
    • We will not use your personal data for any other reason that is not compatible with the reason we collected it except we have informed you and relied on an appropriate lawful basis.
    • We will only collect personal data about you that is only necessary to meet the required purpose and nothing more.
    • We will only use your correct personal data in the course of our processing activities.
        • We will not store or keep your personal data in our custody beyond the period necessary to fulfil the purpose for which it is collected.
        • We will ensure that your personal data in our custody is protected from unauthorised use, alteration or corruption.
        • We will take measures to ensure and demonstrate compliance with these principles.

    Your Legal Rights

    You have certain rights under the law which we respect and comply with and which can be exercised by you anytime. However, note that these rights are not absolute and apply in certain circumstances.

      • right to access your personal data
      • right to request correction of your personal
      • right to request the erasure of your personal data
      • right to object to the processing of your personal data
      • right to request the restriction of processing of your personal data
      • right to request transfer of your personal data
      • right to withdraw consent

    Updating Personal Data About You

    Inform us at DPO@whitedove-shipping.com or whitedovecompliance@whitedove-shipping.com whenever there is a need for an update or alteration of the information you made available to us.

    Right of Complaint

    Kindly note that you have the right to make a complaint at any time to the Nigeria Data Protection Bureau (NDPB) (https://ndpb.gov.ng/) or to approach a court of law to enforce your data protection rights. We would, however, appreciate the chance to deal with your concerns before you approach the NDPB so please contact us in the first instance DPO@whitedove-shipping.com or send a letter to our office @ Nestoil Tower, 13th Floor 41/42, Akin Adesola Street, Victoria Island, Nigeria.

    Changes to Our Privacy Notice

    This privacy notice will be updated from time to time and we will notify you when this happens.

    Contact Details

    Please address questions, comments and requests regarding this Notice to our Privacy Team, DPO@whitedove-shipping.com or send a letter to our office @ Nestoil Tower, 13th Floor 41/42, Akin Adesola Street, Victoria Island, Nigeria.