Website Privacy Policy

1 INTRODUCTION

1.1 Important information and who we are
Welcome to RealServInc’s Privacy and Data Protection Policy (“Privacy Policy”).
At RealServInc (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal
Data in compliance with the Nigerian Data Protection Act (“NDPA”) 2023, and UK General Data Protection
Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018) as well as the UK Data Protection Act 2018
and all other mandatory laws and regulations of Nigeria. In the event of dispute resolutions, applicable law will be
based on your place of permanent residence.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about
your privacy rights, how the law protects you, and inform our employees and staff members of all their
obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• Suppliers
• Business contacts
• Employees/Staff Members
• Third parties connected to your customers and any other people that the organisation has a relationship
  with or may need to contact. 

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by
us.

1.2 Your Data Controller
RealServInc is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to
appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries
about your data should either be sent to us by email to info@realservinc.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in
the first instance.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller, we have employees who will deal with your data on our
behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to
apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR
  (see 2.2 below for more information).
• Ensure that Processors authorised to process Personal Data have committed themselves to
  confidentiality or are under an appropriate statutory obligation of confidentiality.
• Implement appropriate technical and organisational measures to ensure a level of security
  appropriate to the risk associated with the processing of Personal Data.
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor.
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for
  exercising the data subject's rights.
• Make available to the Controller all information necessary to demonstrate compliance with the
  obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted
  by the Controller or another auditor mandated by the Controller.
• Maintain a record of all categories of processing activities carried out on behalf of a
  Controller.
• Cooperate, on request, with the supervisory authority in the performance of its tasks.
• Ensure that any person acting under the authority of the Processor who has access to Personal Data
  does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not
include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped
together below. Not all of the following types of data will necessarily be collected from you, but this is the full
scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving marketing information and
  other information from us.
• Billing Data: This is information relating to your debit and credit card information such as the name
  attached to your payment details and your billing address.
  Financial Data: These are your banking details e.g. your account number and sort code.
• Transactional Data: This is information of details and records of all payments you have made for our
  services or products.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating
  system and platform, and other technology on the devices you use to engage with us.
• Customer Support Data: This includes feedback and survey responses.
• Usage Data: information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as website visits and compile it into reports that enable us
better to understand and improve our services to our users.. Aggregated Data could be derived from your
Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your
identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or
indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this
Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and
others. For example, we may conduct research on your demographics and usage. Although this aggregated data
may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous
data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about your health, and genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.

2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data.
The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that
  confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual
  obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent
  activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our
  legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that
  will not have a material impact on your rights, freedom or interests. Examples could be your address, so that
  we know where to deliver something to, or your name, so that we have a record of who to contact moving
  forwards.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses
We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the lawful basis for
processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may
be broader than described but we will never process your data without a legal basis for doing so and it is for a
related purpose. For further inquiries please contact us.

Activity	Type of Data	Legal Justification	Lawful Basis for Processing Data
User visiting the public website for the first time	Technical Data Usage Data	Legitimate Interest	(a) Legitimate Interest – We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic, diagnose service provision issues, keep our records up-to-date and analyse how customers use our services.
User signing up to the platform and creating an account	Profile / Identity Data Contact Data Marketing and Communications Data Billing Data Financial Data Technical Data Customer Support Data Usage Data	Consent Contractual Obligations Legitimate Interest	(a) Consent – Personal Data is included in your personal or company profile so the content you create can be linked to your account. Contact details may be used to reach you if necessary. Payment details may be retained through our payment processor API (Paystack) to fulfil obligations. (b) Contractual Obligation – Creating an account forms a contract under our Terms of Service. Transactional Data must be retained to comply with legal invoicing obligations. (c) Legitimate Interest – We must identify users to deliver services and provide support related to purchases.
Non-registered user contacting us through live chat or contact form	Profile / Identity Data Contact Data Marketing and Communications Data Technical Data	Consent Legitimate Interest	(a) Consent – Contact information is provided voluntarily so we can respond and connect the conversation to an individual. (b) Legitimate Interest – We analyse login location and browser data to understand our customer demographics, diagnose service issues, maintain records and improve our services.
User contacting us via live chat or form while logged in	Profile / Identity Data Contact Data Marketing and Communications Data Customer Support Data	Consent Contractual Obligations Legitimate Interest	(a) Consent – Contact details allow us to connect conversation history to your profile and communicate with you. (b) Legitimate Interest – Understanding login location and browser information helps diagnose service issues and analyse platform usage. (c) Contractual Obligation – This data supports our contractual relationship under our Terms of Service.
User requesting or attending a live demo or speaking with sales/support	Profile / Identity Data Contact Data Marketing and Communications Data	Consent Legitimate Interest	(a) Consent – Personal or company information may be collected to create profiles and connect activity on the platform. (b) Legitimate Interest – This information helps us assist you in setting up and maximising platform services. Calls may be recorded for reference.
User makes a purchase on the website	Profile / Identity Data Financial Data Transactional Data Usage Data	Consent Contractual Obligations Legitimate Interest	(a) Consent – Payment details may be retained through our payment processor (Paystack) to fulfil obligations. (b) Contractual Obligation – Transactional data is retained to comply with invoicing and legal requirements. (c) Legitimate Interest – We must identify the purchaser to deliver services and provide support.
User support for specific products	Profile / Identity Data Transactional Data Usage Data	Consent Legitimate Interest	(a) Consent – Additional contact details may be used to assist you outside of live chat if necessary. (b) Legitimate Interest – Transaction and usage records help us identify issues quickly and provide efficient support.
Sharing personal information with third parties	Profile / Identity Data Contact Data	Consent Legitimate Interest	(a) Legitimate Interest – Users may share data with third parties who can provide requested services and who have agreed to the platform’s Terms of Service.
Administering and protecting the business and platform	Profile / Identity Data Contact Data Technical Data	Contractual Obligations Legitimate Interest	(a) Legitimate Interest – For running our business, IT administration, security, fraud prevention and restructuring activities. (b) Contractual Obligation – To comply with legal obligations surrounding data processing and retention.
Using analytics to improve the website and services	Technical Data Usage Data	Legitimate Interest	(a) Legitimate Interest – To analyse customer behaviour and improve products, services, marketing and user experience.

2. Marketing and content updates
You will receive marketing and new content communications from us unless you specifically request that you would not like to 
receive these communications. From time to time we may make suggestions and recommendations to you about goods or 
services that may be of interest to you.

3. Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to
use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows 
us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, 
where this is required or permitted by law.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to 
your personal data:

• Right to be informed: You have a right to be informed about our purposes for processing 
  your personal data, how long we store it for, and who it will be shared with. We have 
  provided this information to you in this policy.
• Right of access: This enables you to receive a copy of the personal data we hold about you 
  and to check that we are lawfully processing it (also known as a "data subject access 
  request"). See section 4.5 below for more details on how you can make a data subject access 
  request.
• Right to rectification: You have a right to request correction of the personal data that we hold 
  about you. This enables you to have any incomplete or inaccurate data we hold about you 
  corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to erasure: You have the right to ask us to delete or remove personal data where there is 
  no good reason for us continuing to process it, where you have successfully exercised your 
  right to object to processing (see below), where we may have processed your information 
  unlawfully or where we are required to erase your personal data to comply with local law. 
  Note, however, that we may not always be able to comply with your request of erasure for 
  specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to object: You can object to the processing of personal data we hold about you. This 
  effectively allows you to stop or prevent us from processing your personal data. Note that this 
  is not an absolute right and it only applies in certain circumstances, for example:
  (i) Where we are processing your personal data for direct marketing purposes.
  (ii) Where we are relying on a legitimate interest (or those of a third party) and there is 
  something about your particular situation which makes you want to object to 
  processing on this ground as you feel it impacts on your fundamental rights and 
  freedoms.
  (iii) In some cases, we may continue processing your data if we can demonstrate that we 
  have compelling legitimate grounds to process your information which override your 
  rights and freedoms.
• Right to restrict processing: You have the right to request the restriction or suppression of 
  their personal data. Note that this is not an absolute right and it only applies in certain 
  circumstances:
  (i) If you want us to establish the data's accuracy.
  (ii) Where our use of the data is unlawful but you do not want us to erase it.
  (iii) Where you need us to hold the data even if we no longer require it as you need it to 
  establish, exercise or defend legal claims.
  (iv) You have objected to our use of your data but we need to verify whether we have 
  overriding legitimate grounds to use it.
• Right to data portability: You have the right to request the transfer of your personal data to 
  you or to a third party. If you make such a request, we will provide to you, or a third party you 
  have chosen, your personal data in a structured, commonly used, machine-readable format.
  Note that this right only applies to automated information which you initially provided 
  consent for us to use or where we used the information to perform a contract with you.
  If you wish to make a request under any of these rights, please contact us at info@realservinc.com.

4.2 Your control over RealServInc’s use of your Personal Data
You may delete your account at any time – this will remove your account page from our systems and 
our related software.
We do not guarantee the ability to delete all stored data. If you would like us to delete /correct 
personally identifiable data, let us know and we will action your request as soon as practicable.
You can access information associated with your account by logging into your account you created 
with us.
Your account information will be protected by a password for your privacy and security. You need to 
prevent unauthorized access to your account and personal information by selecting and protecting 
your password appropriately and limiting access to your computer or device and by signing off after 
you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents 
are entitled to ask us for a notice identifying the categories of personal customer information which 
we share with our affiliates and/or third parties for marketing purposes, and providing contact 
information for such affiliates and/or third parties. If you are a California resident and would like a 
copy of this notice, please submit a written request to info@realservinc.com.
4.3 How RealServInc protects customers' Personal Data
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any 
Personal Data collected by us is only accessible by a limited number of employees who have special 
access rights to such systems and are bound by obligations of confidentiality. If and when we use 
subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to 
security risks that would not have arisen had the data remained in our possession. However, 
unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may 
be possible for third parties not under the control of RealServInc to intercept or access transmissions 
or private communications unlawfully. While we strive to protect your Personal Data, we cannot 
ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done 
at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.4 Opting out of marketing promotions
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal 
Data provided to us as a result of interactions with us not related to your marketing preferences.
4.5 How to request your data and the process for obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). 
However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure 
you have the right to access your Personal Data (or to exercise any of your other rights). This is a 
security measure to ensure that Personal Data is not disclosed to any person who has no right to 
receive it. We may also contact you to ask you for further information in relation to your request to 
speed up our response.
5 YOUR DATA AND THIRD PARTIES
5.1 Sharing your data with third parties
We may share non-Personal Data with third parties. We may share your Personal Data with 
subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for 
which we disclose it to them and pursuant to our instructions.
12
We may also share Personal Data with interested parties in the event that RealServInc anticipates a 
change in control or the acquisition of all or part of our business or assets or with interested parties 
in connection with the licensing of our technology.
If RealServInc is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign 
your Personal Data to a third party as part of or in connection with that transaction. Upon such 
transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. 
In all other situations your data will still remain protected in accordance with this Privacy Policy (as 
amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our 
terms or this Privacy Policy.
5.2 Third-Party Links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or 
enabling those connections may allow third parties to collect or share data about you. We do not 
control these third-party websites and are not responsible for their privacy statements. When you 
leave our Site, we encourage you to read the privacy policy of every website you visit.
6 HOW LONG WE RETAIN YOUR DATA
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected 
it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we 
reasonably believe there is a prospect of litigation in respect to our relationship with you.
7 AGE LIMIT FOR OUR USERS
You must not use RealServInc unless you are aged 18 or older. If you are under 18 and you access RealServInc
by lying about your age, you must immediately stop using RealServInc.
This website is not intended for children and we do not knowingly collect data relating to children.
8 INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictions outside the US 
where RealServInc has facilities. By using RealServInc, you are permitting and consenting to the transfer of 
information, including Personal Data, outside of the US.
9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates here. This version is dated 7 April 2025.
By using RealServInc, you consent to the collection and use of data by us as set out in this Privacy Policy. 
Continued access or use of RealServInc will constitute your express acceptance of any modifications to this 
Privacy Policy.
10 INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not 
intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy 
may be used solely for the purpose for which they are stated to be provided, and any unrelated 
correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to 
emails, even if they relate to a legitimate subject matter for which we have provided an email address. You 
are more likely to get a reply if your request or question is polite, reasonable and there is no relatively 
obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, 
etc.).
Our staff are not authorised to contract on behalf of RealServInc, waive rights or make representations 
(whether contractual or otherwise). If anything contained in an email from a RealServInc address contradicts 
anything in this policy, our terms or any official public announcement on our website, or is inconsistent with 
or amounts to a waiver of any RealServInc rights, the email content will be read down to grant precedence to 
the latter. The only exception to this is genuine correspondence expressed to be from the RealServInc legal 
department.
11 TERMS OF USE
Please also see our Terms of Use (www.realserv.inc.com/terms of service) which set out the terms, 
disclaimers, and limitations of liability governing your use of RealServInc.