Privacy Notice

This notice explains how Vlaian Limited collects, uses, stores and shares personal information, and the choices and rights available to you. It applies to visitors to our website, people who enquire about our services, our clients, and the people connected to our work for clients, such as family members, travelling companions and the recipients of gifts.

Vlaian Limited is a company registered in Nigeria with the Corporate Affairs Commission under registration number RC 1953349. We trade as Vlaian Group and through our divisions, including Vlaian Mobility, Vlaian Travel and Vlaian Gifts, each of which is a business name of Vlaian Limited. In this notice, "Vlaian", "we", "us" and "our" refer to Vlaian Limited under all of these names. Vlaian Limited is the data controller responsible for the personal information described here.

Questions about this notice or about your information may be sent to our Data Protection Officer at data@vlaian.com, or in writing to the Data Protection Officer, Vlaian Limited, Plot 975, Cadastral Zone A0, Central Business District, Abuja, Nigeria.

Information you give us. When you use our enquiry form, we collect your name, email address, telephone number, country of residence, the service you are interested in, and anything you choose to include in your message. When you write to us on WhatsApp, we receive your name and number as they appear on your WhatsApp profile, the content of our conversation, and any documents you send.

When you become a client, the information we collect depends on the service. It may include:

• ·identity and passport details, date of birth and nationality
• ·contact details
• ·travel history and plans
• ·employment and education details
• ·financial information required for visa applications or for payment
• ·information about family members travelling or relocating with you
• ·delivery addresses and gift preferences
• ·the information we are required to collect to verify your identity and the source of the funds used to pay us

Information about other people. Our work for a client sometimes involves information about others: a spouse or partner, children, travelling companions, household members, or the recipient of a gift. Where you give us information about another person, we ask that you do so with their knowledge, or where you are otherwise entitled to, and that you make this notice available to them. For the recipient of a gift, we hold only what is needed to prepare and deliver it.

Sensitive information. Some services require information the law treats as sensitive or handles with special care. Where a destination country's application asks for it, this may include religious information and police or criminal record certificates. It may also include health information, such as the results of a visa medical examination, and dietary and allergy information for travel and gifts. We handle this information only where a service requires it, with your explicit consent or where the law otherwise permits. We hold it under our most restricted level of access and keep it only as long as the service and the law require.

We do not collect biometric data. Where an application requires fingerprints or photographs, they are captured directly by the visa application centre or authority concerned.

Children. Some services involve children, including family relocation, schooling support and family travel. We collect a child's information only from a parent or legal guardian, only as far as the service requires, and with that parent's or guardian's consent.

Information collected automatically. When you visit our website, we measure visits in aggregate: the pages viewed, the site that referred the visit, and the general type of device and country. Section 8 explains how.

We do not sell personal information. We do not use information about gift recipients to profile them or to market to them.

Within Vlaian. Access is limited to members of the Vlaian team who need the information to serve you. It is governed by tiered access, so that the most sensitive client information is available only to a small number of named people. Every member of the team is bound by written confidentiality undertakings.

Outside Vlaian. We share information only to the extent each party needs it:

Many of our services are international by nature: a visa application is decided by a foreign government, a journey involves hotels abroad, and a gift may be delivered in another country. The providers that host our systems may also store information on servers outside Nigeria. When we transfer personal information outside Nigeria, we do so only on a basis the Nigeria Data Protection Act permits. That means the destination offers an adequate level of protection, or appropriate safeguards such as binding contractual terms are in place, or the transfer is necessary to deliver a service you have asked for, or you have consented. You may ask our Data Protection Officer for more detail about the safeguards that apply to your information.

WhatsApp is operated by Meta. When you message us on WhatsApp, Meta processes your information under its own privacy policy, as a separate controller. Messages and documents on WhatsApp are end to end encrypted.

You may send us documents on WhatsApp. We use WhatsApp only on devices owned and managed by Vlaian. When a document reaches us, we transfer it to Vlaian Folio and remove it from the conversation and the device. If you would prefer a more private channel for particularly sensitive documents, we will arrange one.

Our website uses only the cookies it needs to function, such as those that keep it secure and remember that a form has been sent. These are essential to the site, and the law does not require consent for them.

We measure visits to our website with an analytics service that sets no cookies and does not identify, follow or profile individual visitors. It tells us only how many people visit, which pages they read, and in aggregate how they found us.

We keep personal information only for as long as we need it:

At the end of each period, information is securely deleted or anonymised.

We protect personal information through:

• ·access restricted by role across three tiers
• ·logging of who accesses client records
• ·encryption of information in storage and in transit
• ·secure custody of physical documents
• ·vetting of the providers and partners we work with
• ·written confidentiality undertakings from every member of the team

If a breach occurs that is likely to put your rights at risk, we will notify the Nigeria Data Protection Commission and, where the law requires, inform you directly, within the time the law sets.

You have the right to:

• ·ask for a copy of the information we hold about you
• ·have inaccurate information corrected
• ·ask us to delete your information
• ·ask us to restrict how we use it
• ·object to our use of it, including an absolute right to object to direct marketing
• ·receive your information in a portable format
• ·withdraw your consent at any time, without affecting anything we did before the withdrawal
• ·be informed where a decision about you is made solely by automated means (we make no such decisions)

To exercise any of these rights, write to our Data Protection Officer at data@vlaian.com. We may ask you to verify your identity before we act. We will respond within 30 days, and there is no charge unless a request is plainly unfounded or excessive. Some rights are limited where the law requires us to keep information, for example our anti money laundering records.

You may also complain to the Nigeria Data Protection Commission through its official channels at www.ndpc.gov.ng. We would welcome the chance to address your concern first.

We will update this notice as our services and the law develop. The date at the top shows when it last changed. Where a change is significant, we will tell our clients directly.