Purpose

Q-Tech Nigeria Limited (“Q-Tech”, “We”, “Us”, “the Company”) is committed to protecting the privacy of all users who interact with our website www.q-technigeria.com, mobile applications, and related services (collectively, “the services”). This policy sets out the principles and practices for the collection, processing, storage, and sharing of personal data within Q-Tech. Please read the entire Privacy Notice to know how we process your personal data and the rights available to you. The Company engages in the business of providing energy consulting and smart metering services and has its head office at Suite 3i 1-2 Adisa Plaza, David Ejoor Crescent, Gudu District, Abuja

Scope

This Policy applies to:

• • • All employees, contractors, trainees, consultants, and third parties who handle personal data on behalf of Q-Tech.

• • •  All business operations of Q-Tech, including energy consulting, training, smart metering, project execution, and digital services (website and mobile apps).

• • •  All forms of data processing, whether electronic, paper-based, or otherwise

Definitions

Personal Data:

Any information that identifies or can identify a living individual (e.g., name, contact details, identification numbers, location data).

Data Subject:

Any individual whose personal data is being collected or processed by Q-Tech.

Processing:

Any operation carried out on personal data, such as collection, storage, use, transfer, or deletion.

Data Controller:

Q-Tech Nigeria Limited, which determines the purpose and means of processing personal data.

Data Processor:

Any third party that processes personal data on behalf of Q-Tech.

Personal Information We Collect

We collect personal information about you if you choose to provide it, to fulfil your request and to provide the services requested, and other lawful bases. We may collect the following type of personal data:

Personal information

Your name, email address, phone number, ID card, photo ID, company details, billing information, and any other details you provide when contacting us, registering for our training, or requesting our services.

Location Data

With your consent, we may collect geolocation data (for mobile app features or service delivery).

• • • Cookies and similar technologies.

• • • User authentication login data (e.g login credentials)

• • • Information captured in documentation or data exchange such as emails and application forms.

• • • Closed circuit television (CCTV) in and around Q-Tech facilities (these may collect photos and videos of you).

Information Of Other People

If you provide information to us about any person other than yourself, you must ensure that they understand how their information will be used and that they have given their consent for you to disclose it to us and for you to allow us, and our outsourced service providers to use it.

Sources We Collect Your Personal Data

We collect data directly from you when you correspond with us, fill forms on our website and physically enter upon our premises, register for our programs or enroll for any of our services.

How We Use Your Information

We use your personal data for the following purposes:

• • • Provide and improve energy, consulting, and training services.

• • • Respond to inquiries, service requests, and customer support needs.

• • • Process transactions, quotations, and service agreements. Send you important updates, newsletters, or promotional communications (if you opt-in).

• • • Ensure compliance with regulatory requirements and industry standards.

• • • Monitor and improve the performance, functionality, and security of our Services.

• • • Providing metering services

• • • Managing client records and appointments.

• • • Corresponding with third parties (e.g vendors, installers, regulators etc.) Enforce and defend legal claims.

Legal Basis For Processing

We process your personal data on one or more legal grounds depending on the specific purpose for which we are using your personal data. Kindly contact us if you need further details or clarity about the specific legal ground we are relying on, to process your personal data. We will rely on any of the legal bases listed below depending on the processing activities:

• • •  We will ask for your consent in certain processing activities especially where it involves collection of sensitive data. Your consent is given when you use our services, navigate our website, tick our online forms or boxes, or when you voluntarily submit your personal data to us. When we obtain your consent, kindly note that you can withdraw the consent at any time and we will comply by not further processing your personal data.

• • •  We may process your personal data to perform contract you have entered with us or take pre-contractual steps with your instruction.

• • •  We may rely on our legitimate interest to process your personal data or tailor our services to suit your needs.
    •  We may process your personal data where the law mandates us to do so.

Data Protection Principles

Q-Tech shall process personal data in accordance with the following principles:

• • • Lawfulness, Fairness, and Transparency: Data shall be processed lawfully, fairly, and transparently.

• • • Purpose Limitation: Data shall only be collected for specific, legitimate business purposes.

• • • Data Minimization: Only data strictly necessary for the intended purpose will be collected.

• • • Accuracy: Reasonable steps will be taken to ensure data is accurate and up to date.

• • • Storage Limitation: Data shall be retained only as long as necessary for its purpose or as required by law.

• • • Integrity and Confidentiality: Appropriate security measures shall be implemented to protect data against unauthorized access, alteration, or loss.

• • • Accountability: Q-Tech shall demonstrate compliance with this Policy and applicable data protection laws.

Data Subject Rights

Q-Tech respects the rights of individuals under the NDPA, including:

• • • The right to access their personal data.

• • • The right to rectify inaccurate or incomplete data.

• • • The right to request erasure of your data under certain circumstances.

• • • The right to restrict processing of your data

• • • The right to withdraw consent where processing is based on consent.

• • • The right to object to certain forms of processing (e.g., direct marketing).

• • • The right to data portability.

• • • Request can be made by contacting us at info@q-technigeria.com

Data Security Measures

To protect personal data, Q-Tech shall:

• • • Implement firewalls, encryption, and access control on IT systems.

• • • Restrict access to personal data on a need-to-know basis.

• • • Ensure secure storage and disposal of paper-based data.

• • • Conduct regular security audits and risk assessments.

• • • Provide continuous training for employees on data protection.

Data Sharing And Third Parties

• • • Personal data shall only be shared with third parties under lawful conditions, subject to contracts ensuring adequate data protection.

• • • Cross-border data transfers shall comply with NDPA requirements and applicable international safeguards.

Roles And Responsibilities

Management

Ensure company-wide compliance with this Policy.

Data Protection Officer (DPO)

Oversee implementation, handle data subject requests, and liaise with regulators.

Employees & Contractors

Handle personal data in accordance with this Policy and report incidents promptly.

Cookies And Tracking Technologies

Our website and digital platforms may use cookies and similar tracking technologies to enhance user experience and analyze website traffic. These technologies help us:

• • • Remember user preferences.

• • • Personalize your browsing experience.

• • • Measure site traffic and engagement.

• • • Analyze site usage to improve performance.

• • • Enable essential features such as login sessions.

• • • Enhance performance and security.

You can manage your cookie settings at any time via our cookie consent banner. Disabling certain cookies may affect functionality or user experience.

Data Retention

We retain your personal data as long as necessary to fulfil the purpose for which it was collected, for the period required by law or where we have any legitimate bases for retaining same. We may retain your data where we are required to assert or defend against legal claims, pending final adjudication of the claim. Any personal data held by us will be kept by us until such time you exercise your right to request deletion of personal data. In some circumstances, we may anonymize your personal data so that it can no longer be associated with you for research purposes, in which case we may use this information indefinitely without further notice to you.

Children’s Privacy

We do not knowingly collect, store, or process personal data belonging to individuals under the age of 18 years, except with the verifiable consent of a parent or legal guardian. If we become aware that such data has been collected without appropriate consent, we will promptly delete the data from our records.

Training And Awareness

Q-Tech will provide periodic data protection training for employees, ensuring awareness of obligations under NDPA and international best practices.

Data Breach Notification And Management

In the event of a personal data breach that is likely to result in a risk to your rights or freedoms, we shall take the following steps:

• • • We will notify the NDPC within 72 hours of becoming aware of the breach, in line with legal requirements.

• • • Where the breach is likely to result in significant harm, we will also inform affected individuals without undue delay, using appropriate communication channels.

• • • We will immediately investigate the cause of the breach, take containment actions, and implement measures to prevent future occurrences.

Automated Decisions And Profiling

We do not use automated systems to make automated suggestions or decisions including profiling, based on personal information we have, or that we are allowed to collect from other authorized sources, about you. All personal data we collect have human involvement.

Right To Complaint

Kindly note that you have the right to lodge a complaint at any time to the Nigeria Data Protection Commission (NDPC), the Regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the NDPC. If you choose to contact us first, you may do so through our Data Protection Officer via info@q-technigeria.com or call +234 816 069 9136 or send a letter to our physical office.

Data Protection Officer

Q- Tech has appointed a Data Protection Officer (DPO) to oversee the implementation of this Policy and ensure compliance with the NDPA and other data protection frameworks. If you have any questions or concerns about this Notice or our privacy practices, or if you would like to exercise your rights regarding your personal data, please contact our DPO via info@q-technigeria.com or call +234 816 069 9136.

Review And Updates

This Policy Notice will be reviewed periodically or whenever there are changes in applicable data protection laws or Q-Tech’s business practices. Updated versions will be published on our official website and will include the “Last Updated” date, unless another type of notice is required by any applicable law. We encourage you to review this Policy periodically to stay informed about how we protect your data.