Background

Colad Gray Consulting (“Colad Gray Consulting”, “Company”, “we”, “us” or “our”) is a Seamless, Remote, Subscription-Based HR Advisory Services for small and medium-sized businesses in Africa. We also offer Payroll, HR Statutory Compliance (Taxes, Pensions, Insurance etc.), Leave, Performance, and HMO Management – All in one place. We are an independent contractor for all HR purposes, providing this website and our services on an independent service provider basis.
This Privacy and Cookie Policy (“Privacy Policy”) describes how we collect, use, store, share, and protect personal data from Website Visitors, Customers, and/or Vendors (“Data Subjects”) who engage with our services. It applies to our website and all related sites, applications, services and tools (collectively, our “Services”).
Our Services are primarily intended for and provided to businesses and other organizations, and individual consumers. Thus, we generally process personal data at the direction of and on behalf of Clients.
By using or accessing our Services, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Your use of our Services is also subject to Colad Gray Consulting’s Terms.

1. The Information we Collect

The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We may collect information from different sources and in various ways, including information you provide directly, information collected automatically from third-party data sources, and data we infer or generate from other data.

1.1 Personal Data You Provide Directly
We collect the personal data you provide to us. For example:
Contact information. As part of our operations, Colad Gray Consulting may collect information such as your name, telephone number, address etc.
Employee personal information such as name, phone number, email address, account number and bank name.
Communications. If you contact us directly, for example with an inquiry or a support request, we may receive additional personal data about you, including your email address and the content of your communications.

1.2 Personal Data We Collect Automatically
Device Information. We receive information about the device and software you use to access our Services, including Internet Protocol (IP) address, web browser type, operating system version, and device identifiers.
Usage Information. To help us understand how you use our Services, including the Demo portion of our website, and to help us improve them, we automatically receive information about your interactions with our Services. This information includes records of your transactions and information about your other activities related to our services, such as the date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. Some of the data we gather through the use of cookies and similar technologies as discussed below.
Location Information. When you use our Services, we may collect or infer your general location information. For example, your IP address may indicate your general geographic region.

1.3 Personal Data That We Receive from Others or Infer
Partners. We may retrieve additional personal data about you from third parties and other identification/verification services such as your financial institution and payment processor. We may combine that data with other information we have about you.
Publicly available sources. Public sources of information such as open government databases.
Inferences. We may infer additional Personal Data based on the Personal Data described above. For example, for site visitors, we may infer your interests based on the web pages you view.
When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

2. How We Use Personal Information

We use the Personal Data we collect to:

• Provide you with the required services.
• Respond to your questions or requests
• Improve features, and website content and analyse data to develop products and services
• Address inappropriate use of our website
• Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools
• Send you marketing content, newsletters and service updates curated by Colad Gray Consulting (only with your explicit consent)
• Verify your identity and the information you provide in line with Colad Gray Consulting’s statutory obligations using internal and third-party tools
• Maintain up-to-date records
• Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
• Any other purpose that we disclose to you in the course of providing Colad Gray Consulting services to you

3. How We Share Personal Data

Colad Gray Consulting does not sell, trade or rent personal data to anyone. Further, we will not share or disclose your personal data with a third party without your consent except as necessary to provide the Services or as described in this Privacy Policy.

Service providers: We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support, to assist in protecting and securing our systems and services, or to perform sanctions screening and identity verification services may need access to personal data to provide those functions. The processing by such third parties shall be governed by a written contract with Colad Gray Consulting to ensure adequate protection and security measures are put in place for the protection of personal data in accordance with the terms of this Privacy Policy.

Financial services & payment processing: When you provide payment data, for example, to make a purchase, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.

Affiliates: We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide our services and operate our business.

Corporate transactions: We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

Legal and law enforcement: We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.

Security, safety, and protecting rights: We will disclose personal data if we believe it is necessary to:

• protect our customers and others, for example, to prevent fraud, or to help prevent the loss of life or serious injury of anyone;
• operate and maintain the security of our services, including preventing or stop an attack on our computer systems or networks; or
• protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

Third-party analytics and advertising companies also collect personal data through our website and apps including, account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses the information at www.google.com/policies/privacy/partners.
Finally, we may share de-identified information in accordance with applicable law.

4. Cookies

We and our partners use cookies and similar technologies on our website to help collect information and operate the site. We use cookies to remember Users and make your user experience easier; customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies are small text files placed by a website and stored by your browser on your device.
Our cookies hold a unique random reference to you so that once you visit the site we can recognise who you are and provide certain content to you.
Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this may impact your experience using our website.

5. How We Protect Your Information

Colad Gray Consulting shall establish adequate controls in order to protect the integrity and confidentiality of personal data, both in digital and physical format and to prevent personal data from being accidentally or deliberately compromised.
Colad Gray Consulting is committed to managing your personal data in line with best practices. We protect your personal data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration, we also use industry-recommended security protocols to safeguard your personal data. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files, and only granting access to personal data to employees who require it to fulfil their job responsibilities. Employees may have access to personal data only as is appropriate for the type and scope of the task in question and are contractually forbidden to use personal data for their own private or commercial purposes or to disclose them to unauthorised persons, or to make them available in any other way.

Two-factor authentication (“2FA”) is an additional layer of security we have added to your account. When 2FA is enabled, you will be required to enter a One Time Password (OTP) (which is a verification code we have sent to you for authentication purposes), each time you try logging in to Oleefee Payroll. While we encourage you to enable this feature on your account, you may choose to disable the 2FA feature by clicking on the toggle button to disable. However, if you choose to disable this feature, you agree that Colad Gray Consulting shall not be liable for any loss or damages incurred as a result of your action.

Colad Gray Consulting also maintains a data breach procedure in order to deal with incidents concerning personal data or practices leading to the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. You may contact our Data Protection Officer (DPO) upon becoming aware of any breach of personal data or if your access credentials have been compromised, to enable us to take the necessary steps toward ensuring the security of your personal data or account. We will report any breaches that will compromise your rights and freedoms to the Relevant Authority within 72 hours of discovery.

6. Storage Limitation

We will retain your information for the following periods:

• As long as reasonably necessary for the purpose of providing our services to you
• For the duration your account is active and we have your consent
• For the period needed to comply with our legal and statutory obligations
• As needed to verify your information with a financial institution

7. Transfer of Data

As part of our service provision, we may rely on third-party servers, databases co-located with hosting providers, and residents in foreign jurisdictions, which constitutes the transfer of your personal data to computers or servers in foreign countries. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law wherever the data is located.

Where personal data is to be transferred to a country outside Nigeria, Colad Gray Consulting shall put adequate measures in place to ensure the security of such personal data. Any transfer of personal data out of Nigeria will be in accordance with the provisions of relevant data protection regulations. In particular, Colad Gray Consulting shall, among other things, use contractual terms to ensure the protection of the data or ensure the country has adequate data protection laws (i.e. listed in Nigeria’s National Information Technology Development Agency’s [“NITDA”] White List of Countries, or the General Data Protection Regulation’s [“GDPR”] Adequacy List).

Should you wish to transfer personal data to a country deemed to have inadequate data protection laws, Colad Gray Consulting will take all necessary steps to ensure that informed consent is obtained from you, and you are aware of the risks entailed with such transfer. In any instance, Colad Gray Consulting will ensure personal data is transmitted in a safe and secure manner. Details of the protection given when your personal data is transferred abroad, and details of the basis of such transfers shall be provided to you upon request.

8. Grounds for Processing of Personal Data

Processing of Personal Information by Colad Gray Consulting shall be lawful if at least one of the following applies:

• the Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;
• the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which Colad Gray Consulting is subject;
• processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
• processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Colad Gray Consulting.

9. Choices and Rights

Individuals who have Personal Information held by Colad Gray Consulting are entitled to reach out to Colad Gray Consulting to exercise the following rights:
Right to request for and access any Personal Information collected and stored by Colad Gray Consulting;

• Right to be informed regarding their Personal Information;
• Right to be informed about appropriate safeguards in place where data is transferred abroad;
• Right to object to automated decision making and processing;
• Right to request rectification and modification of Personal Information which Colad Gray Consulting keeps;
• Right to request the deletion of their data;
• Right to request the movement of data from Colad Gray Consulting to a third party – this is the right to the portability of data;
• Right to revoke consent;
• Right to object to direct marketing, and to request that Colad Gray Consulting restricts the processing of their information; and
• Right to submit a complaint to the National Information Technology Development Agency (NITDA).

Your request will be reviewed and answered by Colad Gray Consulting’s Data Protection Officer within a 30-day period.

10. Changes to This Privacy Policy

We may need to update, modify or amend our Privacy Policy as our technology evolves and as required by law. If we materially change the ways in which we use or share personal data previously collected from you through our Services, we will provide notice or obtain consent regarding such changes as may be required by law. The Privacy Policy will apply from the effective date provided on our website.

11. Policy Violations

Any violation of this Privacy Policy should be brought to the attention of the Data Protection Officer (details below) for appropriate sanctioning and treatment.

12. Pricing

To process payroll on Oleefee, we charge the sum of 2,000 Naira and 50 Naira on each employee per payroll run. Each company is entitled to a free month’s trial to run the payroll but will be charged 50 Naira for transfer fees.