Effective Date: July 30, 2025
Last Updated: July 30, 2025

1. INTRODUCTION

REAL Recruitment Employment Agency Limited (“we,” “us,” or “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information in compliance with the Nigeria Data Protection Act (NDPA) 2023 and related regulations.

Company Details:

• Name: REAL Recruitment Employment Agency Limited

• Address: Business Centre, Oluwole Street, Ejigbo, Lagos State, Nigeria

• Email: info@reallending.ng

• Phone: 09043420796

• Website: www.reallending.ng

2. DATA CONTROLLER INFORMATION

REAL Recruitment Employment Agency Limited is the data controller for personal information collected through our services.

Data Protection Officer Contact:

• Email: dpo@realrecruitment.ng

• Phone: 09043420796

3. INFORMATION WE COLLECT

3.1 Personal Identification Data

• Full name and contact details

• Date of birth and age

• National Identification Number (NIN)

• Passport/ID card information

• Photographs and biometric data

• Address and location information

3.2 Employment and Professional Data

• CV/Resume and employment history

• Educational qualifications and certifications

• Professional skills and competencies

• References and recommendations

• Work authorization status

• Salary expectations and employment preferences

3.3 Financial Information (For Loan Services)

• Banking details and account information

• Credit history and financial statements

• Income and employment verification

• Loan application details

• Repayment history and financial obligations

3.4 Sensitive Personal Data

• Health and medical information (for healthcare placements)

• Criminal background checks and DBS certificates

• Ethnic origin and nationality (for work authorization)

• Religious or philosophical beliefs (for workplace accommodation)

• Biometric data for identity verification

3.5 Technical Data

• IP addresses and device information

• Mobile app usage and interaction data

• Website cookies and tracking information

• Communication logs and preferences

4. HOW WE COLLECT INFORMATION

4.1 Direct Collection

• Registration forms and applications

• CV uploads and profile creation

• Interview and assessment processes

• Loan application submissions

• Customer service interactions

4.2 Automatic Collection

• Website and mobile app analytics

• Cookies and tracking technologies

• System logs and security monitoring

• Communication tracking

4.3 Third-Party Sources

• Background check providers

• Educational institutions

• Previous employers and references

• Credit bureaus and financial institutions

• Government agencies and regulatory bodies

5. LEGAL BASIS FOR PROCESSING

5.1 Consent

• Marketing communications

• Non-essential cookies

• Sensitive data processing (where required)

• Data sharing with third parties

5.2 Contract Performance

• Service delivery and administration

• Employment placement services

• Loan processing and management

• Payment processing

5.3 Legal Obligation

• Regulatory compliance and reporting

• Identity verification requirements

• Background checks and security clearances

• Tax and financial record keeping

5.4 Legitimate Interests

• Business operations and administration

• Service improvement and development

• Fraud prevention and security

• Marketing to existing customers

6. HOW WE USE YOUR INFORMATION

6.1 Recruitment Services

• Job matching and placement

• CV optimization and career advice

• Interview coordination and scheduling

• Employment verification and references

• Skills assessment and training recommendations

6.2 Loan Services

• Eligibility assessment and credit evaluation

• Loan application processing

• Employment verification for loan purposes

• Repayment management and collection

• Financial counseling and support

6.3 Communication

• Service updates and notifications

• Job opportunity alerts

• Marketing communications (with consent)

• Customer support and assistance

• Regulatory and compliance notices

6.4 Business Operations

• Service improvement and development

• Performance monitoring and analytics

• Quality assurance and feedback collection

• Legal compliance and reporting

• Fraud prevention and security

7. DATA SHARING AND DISCLOSURE

7.1 With Your Consent

• Potential employers for job placements

• Training providers for certification programs

• Professional networks and associations

7.2 Service Providers

• Technology and IT service providers

• Payment processors and financial institutions

• Background check and verification services

• Marketing and communication platforms

7.3 Legal Requirements

• Regulatory authorities and government agencies

• Law enforcement and judicial authorities

• Tax authorities and financial regulators

• Professional licensing bodies

7.4 Business Transfers

• In case of merger, acquisition, or business sale

• With appropriate data protection safeguards

• Subject to notification requirements

8. INTERNATIONAL DATA TRANSFERS

8.1 UK Operations

Data may be transferred to our UK affiliate (Alwayz Positive Limited) under GDPR adequacy protections.

8.2 Cloud Storage

We use EU/UK-based cloud services with appropriate data protection safeguards.

8.3 Safeguards

• Standard Contractual Clauses

• Adequacy decisions where applicable

• Additional security measures

• Regular compliance monitoring

9. DATA SECURITY

9.1 Technical Measures

• End-to-end encryption for data transmission

• Secure encrypted storage systems

• Multi-factor authentication

• Regular security audits and penetration testing

• Automated backup and recovery systems

9.2 Organizational Measures

• Staff training on data protection

• Access controls and need-to-know principles

• Regular compliance reviews and updates

• Incident response and breach procedures

• Vendor security assessments

10. DATA RETENTION

10.1 Retention Periods

• Active candidates: 3 years from last interaction

• Placed candidates: 7 years from placement date

• Client records: 7 years from contract termination

• Financial records: 7 years (regulatory requirement)

• Marketing data: Until consent withdrawn

• Sensitive data: Minimum period necessary

10.2 Secure Deletion

• Automated deletion processes

• Secure data destruction methods

• Regular retention reviews

• Documentation of deletion activities

11. YOUR RIGHTS UNDER NDPA 2023

11.1 Right to Access

• Request copies of your personal data

• Information about how data is processed

• Details of data sharing and transfers

11.2 Right to Rectification

• Correct inaccurate or incomplete data

• Update outdated information

• Amend processing records

11.3 Right to Erasure

• Delete data when no longer necessary

• Withdraw consent for processing

• Object to unlawful processing

11.4 Right to Restrict Processing

• Limit how data is used

• Suspend processing activities

• Maintain data without active use

11.5 Right to Data Portability

• Receive data in structured format

• Transfer data to another controller

• Direct transfer where technically feasible

11.6 Right to Object

• Object to processing for direct marketing

• Object to processing based on legitimate interests

• Object to automated decision-making

12. EXERCISING YOUR RIGHTS

To exercise your rights:

• Email: dpo@realrecruitment.ng

• Phone: 09043420796

• Written request to our registered address

• Through your account settings (where available)

Response time: Within 30 days of receipt
Fee: Generally free (reasonable fees may apply for excessive requests)

13. COMPLAINTS

If you’re not satisfied with our response:

• Contact our Data Protection Officer

• File a complaint with the Nigeria Data Protection Commission (NDPC)

• Seek legal advice or representation

NDPC Contact:

• Website: ndpc.gov.ng

• Email: info@ndpc.gov.ng

14. COOKIES AND TRACKING

14.1 Cookie Types

• Essential cookies for website functionality

• Analytics cookies for usage statistics

• Marketing cookies for targeted advertising

• Preference cookies for user settings

14.2 Cookie Management

• Browser settings for cookie control

• Opt-out options for non-essential cookies

• Regular cookie policy updates

• Clear information about cookie purposes

16. CHANGES TO THIS POLICY

16.1 Notification

• 30 days’ advance notice of material changes

• Email notification to registered users

• Website posting of updated policy

• Mobile app notifications where applicable

16.2 Continued Use

Continued use of our services after changes constitutes acceptance of the updated policy.

17. CONTACT INFORMATION

Data Protection Officer:

• Email: dpo@realrecruitment.ng

• Phone: 09043420796

General Contact:

• Email: info@realrecruitment.ng

• Phone: 09043420796

• Address: Business Centre, Oluwole Street, Ejigbo, Lagos State, Nigeria

18. EFFECTIVE DATE

This Privacy Policy is effective from July 30, 2025, and supersedes all previous versions.

ACKNOWLEDGMENT

By using our services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

REAL Recruitment Employment Agency Limited
July 30, 2025