Content & Purpose
3. We have implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While we try our best to provide security that is commensurate with the industry standards, because of the inherent vulnerabilities of the internet, we cannot ensure or warrant complete security of all information that is being transmitted to us by you.
a) The type of Personal Information (including Sensitive Personal Data or Information) that SURJEN collects from the Users;
b) The purpose of collection, means and modes of usage of such Personal Information by SURJEN;
c) How and to whom SURJEN will disclose such information;
d) How SURJEN will protect the Personal Information including Sensitive Personal Data or Information that is collected from the Users; and
e) How Users may access and/ or modify their Personal Information.
What is the personal information?
1. “Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available with SURJEN, is capable of identifying the person concerned.
2. “Sensitive Personal Data or Information” means Personal Information of any individual relating to password; financial information such as bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; biometric information; any detail relating to the above as provided to or received by SURJEN for processing or storage. However, any data/ information relating to an individual that is freely available or accessible in public domain or any other law shall not qualify as Sensitive Personal Data or Information.
Types of personal information collected by SURJEN:
1. A User may have limited access to the Website and utilize some of the Services provided by SURJEN without creating an account on the Website. Unregistered Users can access some of the information and details available on the Website. In order to have access to all the features and benefits on our Website, a User may be required to first create an account on our Website. As part of the registration process, SURJEN may collect the following categories of Personal Information from the Users (hereinafter collectively referred to as “User Information”):
b) User ID;
c) Email address;
d) Address (including country and ZIP/postal code);
g) Phone Number;
h) Password chosen by the User;
i) Valid financial account information; and
j) Other details as the User may volunteer.
3. SURJEN may keep records of telephone calls received and made for making inquiries, orders, or other purposes for the purpose of administration of Services.
4. Internet use: SURJEN may also receive and/or hold information about the User’s browsing history including the URL of the site that the User visited prior to visiting the website as well as the Internet Protocol (IP) address of each User's computer (or the proxy server a User used to access the World Wide Web), User's computer operating system and type of web browser the User is using as well as the name of User's ISP. The Website uses temporary cookies to store certain data (that is not Sensitive Personal Data or Information) that is used by SURJEN and its service providers for the technical administration of the Website, research and development, and for User administration.
5. The Website may enable User to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. SURJEN hereby expressly disclaims any liability for any misuse of such information that is made available by visitors in such a manner.
6. SURJEN does not knowingly collect Personal Information from children.
Purposes for which your information may be used by SURJEN:
1. SURJEN will retain User Information only to the extent it is necessary to provide Services to the Users. The information which SURJEN collects from you may be utilized for various business and/or regulatory purposes including for the following purposes:
a) Registration of the User on the Website;
b) Processing the User’s orders / requests and provision of Services (including provision of safe Services);
c) Completing transactions with Users effectively and billing for the products/ Services provided;
d) Technical administration and customization of Website;
e) Ensuring that the Website content is presented to the Users in an effective manner;
f) Delivery of personalized information and target advertisements to the User;
g) Improvement of Services, features and functionality of the Website;
h) Research and development and for User administration (including conducting user surveys);
i) Non-personally identifiable information, exclusively owned by SURJEN may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes including those for the purposes of determining the number of visitors and transactional details, and SURJEN may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates;
j) Dealing with requests, enquiries, complaints or disputes and other customer care related activities including those arising out of the Users’ request of the Services and all other general administrative and business purposes;
k) In case of any contests conducted by SURJEN in which the User participates, the User Information may be used for prize fulfillment and other aspects of any contest or similar offering;
m) Verification of identity of Users and perform checks to prevent frauds; and
Disclosure and transfer of your personal information:
a) To Sellers and other service providers appointed by SURJEN for the purpose of carrying out services on SURJEN’s behalf under contract. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, will have rights to use and disclose the Personal Information collected in connection with the provision of these services in accordance with their own privacy policies.
b) To our affiliates in Nigeria or in other countries who may use and disclose your information for the same purposes as us.
d) If otherwise required by an order under any law for the time being in force including in response to enquiries by Government agencies for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.
e) In case of contests conducted by SURJEN in which the User participates, the concerned User’s information may be disclosed to third parties, also be disclosed to third parties to the extent necessary for prize fulfillment and other aspects of such contest or similar offering.
2. SURJEN makes all User Information accessible to its employees and data processors only on a need-to-know basis. All SURJEN employees and data processors, who have access to, and are associated with the processing of User Information, are obliged to respect its confidentiality.
3. Non-personally identifiable information may be disclosed to third party ad servers, ad agencies, technology vendors and research firms to serve advertisements to the Users. SURJEN may also share its aggregate findings (not specific information) based on information relating to the User’s internet use to prospective, investors, strategic partners, sponsors and others in order to help the growth of SURJEN's business.
4. SURJEN may also disclose or transfer the User Information, to another third party as part of reorganization or a sale of the assets or business of a SURJEN corporation division or company. Any third party to which SURJEN transfers or sells its assets will have the right to continue to use the Personal Information and/ or other information that a User provide to us.
Retention of the information:
2. Part of the functionality of the Website is assisting the Sellers to maintain and organize such information to effect sale and purchase of products. SURJEN may, therefore, retain and submit all such records to the appropriate authorities, or to Sellers who request access to such information.
3. The Website is also designed for assisting the Users to access information relating to Healthcare products and services. SURJEN may, therefore, retain and submit all such records to the relevant Users.
4. SURJEN will also ensure that User Information is not kept for a period longer than is required for the purposes for which it is collected or as required under any applicable law.
Links to third-party advertisements:
1. The links to third-party advertisements, third party websites or any third party electronic communication services (referred to as “Third Party Links”) may be provided on the Website which are operated by third parties and are not controlled by, or affiliated to, or associated with SURJEN unless expressly specified on the Website.
Security practices and procedures:
1. SURJEN adopts reasonable security practices and procedures to include, technical, operational, managerial and physical security control measures in order to protect the Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
2. SURJEN takes adequate steps to ensure that third parties to whom the Users’ Sensitive Personal Data or Information may be transferred adopt reasonable level of security practices and procedures to ensure security of Personal Information.
3. You hereby acknowledge that SURJEN is not responsible for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
User's rights in relation to their personal information collected by SURJEN:
5. In case the User does not provide his/ her information or consent for usage of Personal Information or subsequently withdraws his/ her consent for usage of the Personal Information so collected, SURJEN reserves the right to discontinue the services for which the said information was sought.
Additional notes to the user:
2. SURJEN shall not be responsible in any manner for the authenticity of the Personal Information or Sensitive Personal Data or Information supplied by the User to SURJEN or any Seller. If a User provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or SURJEN has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, SURJEN has the right to suspend or terminate such account at its sole discretion.
3. SURJEN shall not be responsible for any breach of security or for any actions of any third parties that receive Users' Personal Information or events that are beyond the reasonable control of SURJEN including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.
4. The User is responsible for maintaining the confidentiality of the User's account access information and password. The User shall be responsible for all uses of the User's account and password, whether or not authorized by the User. The User shall immediately notify SURJEN of any actual or suspected unauthorized use of the User's account or password.
5. SURJEN will communicate with the Users through email and notices posted on the Website or through other means available through the Service, including text and other forms of messaging. The Users can ask SURJEN, by sending an email to email@example.com containing the rectification required.
Complaints and grievance redressal:
1. SURJEN addresses discrepancies and grievances of all Users with respect to processing of information in a time bound manner. For this purpose, SURJEN has designated Mr. Sudhir Singh Rathore as the grievance officer, who will redress the grievances of the Users expeditiously but within one month from the date of receipt of grievance, and who can be reached by:
a) Sending a letter marked to the attention of “Grievance Officer, SURJEN to Suit-01, Commercial Complex, Amina Court, Gudu, Abuja, or
b) Sending an email to firstname.lastname@example.org
SURJEN, Suit-01, Commercial Complex, Amina Court, Gudu, Abuja