Privacy Policy

REAL Recruitment Employment Agency Limited

Financial Support for Working Nigerians

REAL Recruitment Employment Agency Limited is committed to protecting your privacy and ensuring the security of your
personal data.
This Privacy Policy explains how we collect, use, store, and protect your
information in compliance with the Nigeria Data Protection Regulation (NDPR) 2019 and
other applicable data protection laws.
By using our website (www.reallending.ng), services, or providing us with your personal
information, you consent to the practices described in this Privacy Policy.

Information We Collect

Personal Information

We collect personal information that you voluntarily provide when you Register as a

  • job seeker or employer
  • Apply for employment-linked loans
  • Subscribe to our newsletter
  • Contact us via phone, email, or website forms
  • Use our payroll and HR services

Personal information may include

  • Full name
  • Date of birth
  • Gender
  • Contact information (phone number, email address, physical address)
  • National Identification Number (NIN) or other government-issued ID
  • Bank account details (for loan disbursement and payroll)
  • Employment history and references
  • Educational qualifications and certifications
  • Professional registration details (e.g., NMC, COREN)
    Passport information (for international placements)
  • Biometric data (for identity verification, if applicable)
  • Financial information (income, credit history for loan applications)
  • Next of kin and emergency contact information

Information from Third Parties

We may receive information about you from

  • Employers and recruitment partners
    Training providers (Flexebee, Greater Step)
  • Financial institutions (for loan processing)
  • UK partner (Alwayz Positive Limited) for international placements
  • Credit bureaus (for
    loan eligibility assessment)
  • Government agencies (NIMC, SCUML, FIRS, PFA)

Automatically Collected Information

When you visit our website, we may automatically collect

  • IP address
  • Browser type and version
  • Device information (type, operating system)
  • Pages visited and time spent on site
  • Referring website
  • Cookies and similar tracking technologies

How We Use Your Information

Primary Purposes

We use your personal information to:

  • Recruitment Services: – Match you with suitable job opportunities – Facilitate job
  • Applications and interviews – Conduct background checks and reference verification
  • Communicate with employers on your behalf – Provide CV review and interview
  • Coaching – Facilitate international placements (UK sponsorship)
  • Employment-Linked Loans: – Process loan applications – Assess creditworthiness and Eligibility – Disburse approved loans – Manage repayment schedules – Communicate loan status and updates
  • Payroll and HR Services: – Process monthly payroll for client companies – Calculate and remit PAYE, pension contributions, and other statutory deductions – Generate and distribute payslips – Maintain employee records – Ensure compliance with Nigerian tax and labor laws
  • General Business Operations: – Respond to inquiries and provide customer support
    Send service updates, newsletters, and promotional materials – Improve our website
    and services – Conduct research and analysis – Comply with legal and regulatory
    requirements

Legal Basis for Processing

We process your personal data based on

  •  Consent: You have given explicit consent for
    specific purposes
  • Contract: Processing is necessary to fulfill our contractual obligations
    to you
  • Legal obligation: We must process data to comply with Nigerian laws (NDPR,
    tax laws, labor laws)
  • Legitimate interests: Processing is necessary for our legitimate
    business interests (fraud prevention, service improvement)

Data Sharing and Disclosure

When We Share Your Information

We may share your personal information with:

  • Employers and Clients: – Your CV and application materials (with your consent)
  • Employment verification and references – Payroll and HR data (for client companies using our services)
  • Partners and Service Providers: – UK partner (Alwayz Positive Limited) for international placements
  • Training providers (Flexebee, Greater Step) for skills development
    Microfinance banks and loan partners (INVESSA, others) for loan funding
  • Payment processors (Paystack, Remita) for secure transactions
  • IT service providers (hosting, CRM, email services)
  • Legal and professional advisors Government and Regulatory Authorities
  • Nigeria Immigration Service (for international
    placements)
  • UK Home Office (for visa sponsorship)
  • Federal Inland Revenue Service (FIRS) for tax compliance
  • Pension Fund Administrators (PFA) – Special Control Unit Against Money Laundering (SCUML) – National Identity

International Data Transfers

  • For international placements, we transfer your personal data to: – United Kingdom
  • Alwayz Positive Limited (our UK partner) for Certificate of Sponsorship and visa processing
  • Other countries: As necessary for job placements outside Nigeria
  • We ensure adequate safeguards are in place for international transfers, including:
  • Standard contractual clauses
  • Data processing agreements – Compliance with UK GDPR
    and Nigerian NDPR

When We Do NOT Share Your Information

  • We will NEVER: Sell your personal data to third parties
  • Share your information for marketing purposes without your consent
  • Disclose sensitive information without legal justification

Data Security

Data Breach Notification

  • In the event of a data breach that poses a risk to your rights and freedoms, we will:
  • Notify the Nigeria Data Protection Bureau (NDPB) within 72 hours – Notify affected
  • individuals without undue delay – Provide information about the breach, potential impact, and remedial actions

Security Measures

We implement robust security measures to protect your personal data

 

  • Technical Safeguards: – SSL/TLS encryption for website and data transmission
  • Secure servers with firewall protection
  • Regular security audits and vulnerability assessments
  • Access controls and authentication protocols
  • Encrypted storage for sensitive data (passwords, financial information)
  • Regular backups and disaster recovery procedures
  • Organizational Safeguards: – Staff training on data protection and confidentiality
  • Confidentiality agreements with employees and partners – Role-based access controls (need-to-know basis)
  • Incident response and breach notification procedures
  • Regularreview and update of security policies

Data Retention

Retention Periods

  • After retention periods expire
  • we will: – Securely delete personal data
  • Anonymize data for statistical analysis (where applicable)
  • Ensure data is irretrievable

Retention Periods

 We retain your personal data only as long as necessary for the purposes outlined in this
Privacy Policy:

  • Job Seekers: – Active candidates: Data retained while you remain registered (up to 3 years of inactivity)
  • Placed candidates: Employment records retained for 7 years (tax
    and labor law compliance)
  • Loan Applicants: – Approved loans: Records retained for 7 years after loan repayment
  • (financial regulations) – Declined applications: Data deleted after 1 year
  • Payroll Clients: – Employee payroll records:
  • Retained for 7 years (tax and pension compliance)
  • After contract termination: Data retained for 7 years, then securely
    deleted
  • Website Visitors: – Cookies and analytics data: Retained for 2 years – Newsletter subscribers: Until you unsubscribe

Your Rights

Under the Nigeria Data Protection Regulation (NDPR), you have the following rights

  • Right to Access

    You can request a copy of the personal data we hold about you.

  • Right to Rectification

    You can request correction of inaccurate or incomplete personal data.

  • Right to Erasure (“Right to be Forgotten”)

    You can request deletion of your personal data in certain circumstances
    -Data is no longer necessary for the purposes collected
    - You withdraw consent (where consent was the legal basis)
    - Data was unlawfully processed
    - Legal obligation requires deletion
    Exceptions: We may retain data if required by law (e.g., tax records for 7 years).

  • Right to Restrict Processing

    - You can request restriction of processing in certain circumstances
    - You contest the accuracy of data (during verification)
    - Processing is unlawful, but you prefer restriction over deletion
    - We no longer need the data, but you need it for legal claims

  • Right to Data Portability

    You can request your personal data in a structured, commonly used, machine-readable
    format and transfer it to another service provider.

  • Right to Object

    You can object to processing based on legitimate interests or for direct marketing
    purposes.

  • Right to Withdraw Consent

    Where processing is based on consent, you can withdraw consent at any time (does not
    affect lawfulness of processing before withdrawal).

  • How to Exercise Your Rights

    To exercise any of these rights, contact us:
    Email: admin@reallending.ng
    Phone: +234 904 342 0796
    Address: Business Centre, Oluwole Street, Ejigbo, Lagos State, Nigeria
    We will respond to your request within 30 days.

Cookies and Tracking Technologies

What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help
us improve your browsing experience and analyze website performance.

Types of Cookies We Use

  • Essential Cookies: – Required for website functionality (login, forms, security) – Cannot be disabled
  • Analytics Cookies: – Track website usage and performance (Google Analytics) – Help us understand user behavior and improve services
  • Marketing Cookies: – Track your browsing across websites for targeted advertising (if applicable) – Can be disabled via browser settings

Managing Cookies

You can control cookies through your browser settings

  • Accept all cookies: Full website functionality
  • Block all cookies: May limit website functionality
  • Delete cookies: Clear stored cookies from your device
  • Note: Disabling cookies may affect your ability to use certain website features (e.g., loan calculator, registration forms).

Third-Party Links

Our website may contain links to third-party websites (e.g., Alwayz Positive Limited UK,
Flexebee, Paystack). We are not responsible for the privacy practices of these websites.
Please review their privacy policies before providing personal information.

Children’s Privacy

Our services are not intended for individuals under 18 years of age.
We do not knowingly collect personal data from children. If we become aware that we have
collected data from a child without parental consent, we will delete it promptly.
Exception: Student loans may be available to individuals aged 16-17 with
parental/guardian consent.

Contact Information

REAL Recruitment Employment Agency Limited
Business Centre, Oluwole Street, Ejigbo, Lagos State, Nigeria

Email: admin@reallending.ng
Phone: +234 904 342 0796
Website: www.reallending.ng
Data Protection Officer (DPO):
For data protection inquiries, contact our DPO at: dpo@reallending.ng

Complaints and Regulatory Authority

If you believe we have not handled your personal data in accordance with this Privacy
Policy or Nigerian data protection laws, you have the right to lodge a complaint with:
Nigeria Data Protection Bureau (NDPB)
Email: info@ndpb.gov.ng
Website: www.ndpb.gov.ng

Consent

By using our website and services, you acknowledge that you have read, understood,
and agree to this Privacy Policy.

For specific processing activities requiring explicit consent (e.g., marketing
communications), we will obtain your separate, informed consent.

Thank you for trusting REAL Recruitment Employment Agency Limited with your
personal information. We are committed to protecting your privacy and providing
excellent service