Effective October 10th, 2023

PRIVACY POLICY

1. Introduction

This privacy notice provides you with details on how we collect and process your personal data through your use of our website at clienttriggers.com.

By providing us with your data, you warrant that you are over 13 years of age.

Contact Details

Our full details are:

• Full name of legal entity: Client Triggers, INC
• Email address: web@clienttriggers.com
• Postal address: 34b Ibeto Road, Port Harcourt

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at web@clienttriggers.com.

We may change this privacy policy from time to time. If we make changes, we will update the “Effective Date” at the top of the page. If we make a material change in the way we use your personal information, we will prominently note the change through email or notification on our website.

How We Collect Your Personal Data

We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details.

We may receive data from third parties such as analytics providers (e.g., Google) based outside the EU, advertising networks (e.g., Facebook) based outside the EU, search information providers (e.g., Google) based outside the EU, providers of technical, payment and delivery services, data brokers, or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by clicking the 1-click unsubscribe button at the bottom of our emails or by emailing us at support@clienttriggers.com.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases or warranty registrations.

How We Use Your Information

We may use your information and data in the following ways:

• Communicating with You: We may use the information we collect from you to communicate with you and respond to your inquiries. These communications could include service updates, promotions for products or services that we or one of our marketing partners provide, or e-newsletters.

• Service Providers: We may contract with third-party service providers to perform functions for us. These service providers may have access to the information we collect for the purpose of performing those functions but are contractually bound to maintain the confidentiality of the information and not use it for any other purpose.

• Social Media: The Sites may include social media features, such as the Facebook “Like” button and a “Share” button. These features may collect your IP address and which page you are visiting on the Site, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company that provides the feature.

• Business Transfers: If we transfer all or substantially all of our assets to another company, one of the assets we would likely include in the transfer is our database of Personal Information.

• Disclosures for Legal Reasons: We will disclose Personal Information when required to do so by law, regulation, or securities exchange requirement, for example, in response to a court order or subpoena. We may also disclose such information in response to a law enforcement agency’s request or when we believe such disclosure is appropriate to protect our legal rights or to safeguard anyone’s property or safety.

How We Share Information – And Why

We may have to share your personal data with the parties set out below:

• Other companies in our group who provide services to us.
• Professional advisers including lawyers, bankers, auditors, and insurers.
• Government bodies that require us to report processing activities.
• Third-party advertising platforms to create marketing campaigns (e.g., using your email address to create a Facebook targeting audience).
• When you participate in interactive areas of our website, service, and products, your information may be displayed to other users; this information may include your name, photo, the comment, and other information you chose to provide at the time of submission. In the case of surveys, we will never share personally identifiable information without express consent.
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process.
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of Company or others.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
• With your consent or at your direction.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

• We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data.
• If we use US-based providers that are part of the EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
• Where we use certain service providers established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding the appropriate retention period for personal data, we consider its amount, nature, and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, whether these can be achieved by other means, and the applicable legal requirements.

For tax purposes, the law requires us to keep basic information