Privacy Policy

SBTS Group Limited ("SBTS," "we," "us," or "our"), headquartered in Washington D.C., is a global technology provider committed to protecting the privacy of our clients and users worldwide. We operate in compliance with the Nigeria Data Protection Act (NDPA) 2023, the SECURE Data Act, and other applicable regional data protection laws.

This policy applies to all personal data processed by SBTS Group across our global offices, including:

• Americas: Washington, D.C. (Headquarters).

• Africa: Nigeria, Sierra Leone (Freetown), Liberia (Monrovia), Democratic Republic of Congo (Kinshasa).

• Asia: India (Pune).

We process personal data under several legal frameworks depending on the jurisdiction and nature of the interaction:

• Contractual Necessity: To provide training, ERP solutions, cybersecurity services, and other services.

• Consent: Explicitly obtained for marketing, training enrollment, and digital counseling.

• Legal Obligation: To fulfill regulatory reporting and compliance requirements in our operating regions.

• Legitimate Interests: For security monitoring via our SOC, incident remediation, and the preservation of evidence of security incidents.

To effectively provide our services and manage our relationship, we collect identifying, traffic, and metadata to deliver enterprise-grade digital solutions across our global network:

a) Personal identifiers, including full name, government-issued identification, nationality, and contact details, to facilitate enrollment in training programs and provide secure access to our Enterprise Resource Planning (ERP) systems.

b) Log data and IP addresses, anonymized where feasible, utilized by our 24/7 Security Operations Center (SOC) to monitor for threats and protect critical national and private infrastructures.

c) Professional credentials, academic history, and background check results to verify qualifications for international professional certifications and maintain the integrity of our digital counseling services.

d) Content of electronic communications, including email addresses and message history, to provide timely customer service and ensure consistent support across our international offices.

e) Statistical analysis to improve our training activities, streamline administrative admission processes, and enhance our customer service infrastructure globally.

We maintain robust security measures to protect your personal information, utilizing physical, technical, and administrative protocols. At our organization, we take strong measures to safeguard your personal information. However, ensuring a secure online experience is a shared responsibility. While we protect your data on our platform, you are responsible for maintaining the security of your account credentials and other sensitive information.

We will retain your personal data for as long as necessary for the purpose for which it was collected. After this period, we will securely destroy your data when it is no longer required, in line with legal, administrative, and regulatory requirements.

We may share your personal data with third parties who act as data processors on our behalf and are bound by contractual data protection clauses. We only share the minimum amount of data necessary with these third parties to enable them to perform their services. We may also pass certain requests from you to these third-party service providers. Regardless of the third party involved, any disclosure shall be for a lawful purpose only.

As a global entity, SBTS may transfer data across borders. We ensure these transfers are lawful by:

• Utilizing Standard Contractual Clauses (SCCs) or similar safeguards.

• Ensuring third-party processors are contractually bound to the same high data protection standards.

• Documenting safeguards for Nigerian data subjects as required by the NDPC.

You have the following rights regarding your personal data collected by us:

a) The right to be informed about the collection and use of your personal data.

b) The right to request a copy of the personal data we hold about you.

c) The right to request the correction of any inaccurate or incomplete personal data we hold about you.

d) The right to request the deletion of your personal data, subject to legal and contractual obligations.

e) The right to request that we restrict the processing of your data under certain circumstances.

f) The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

g) The right to object to the processing of your personal data under certain conditions, particularly for direct marketing purposes.

h) The right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significant effects on you.

All copyrights, trademarks, patents, and other intellectual property rights on our website and its content belong solely to SBTS Group Limited or its licensors. You can't use our trademarks, content, or intellectual property without our express written permission.

You must not do any of the following without our prior written consent:

• Republish, sell, or rent any material from our website.

• Reproduce, copy, or create new versions of our content for any purpose.

• Redistribute any content from our website, including by posting it on another website.

You agree to use our website only for lawful purposes and in a way that respects and doesn't interfere with anyone else's use and enjoyment of the site. This means you must not:

• Harass, cause distress to, or inconvenience any other user.

• Transmit obscene or offensive content.

• Disrupt the normal flow of dialogue on our website.

• Use our website to send unsolicited commercial communications (spam).

• Use our content for any marketing-related purpose without our express written consent.

How We Handle Your Communications

If you choose to communicate with us via email, or if you provide your email address by registering on our website, signing up using a form, we may retain the content of your email messages along with your email address and our responses. We apply the same robust security measures and data protection standards to these electronic communications as we do to all other personal information we collect.

We are committed to keeping your email address confidential. We will not sell, rent, or lease our email subscription lists to third parties. Your email address will be used solely to provide you with timely information about SBTS and its services.

How We Use and Disclose Your Information

We use the personal information you provide to us to administer admission, statistical, and training activities and provide customer service. We will not obtain personally-identifying information about you unless you voluntarily provide it to us. Furthermore, we will not sell or otherwise transfer your personal information to unaffiliated third parties without your explicit consent at the time of collection.

We may disclose your information if we are legally compelled to do so, for example, when we believe in good faith that the law requires it or for the protection of our legal rights.

You have the right to opt out of receiving communications from us. If you no longer wish to receive our newsletters, you can easily unsubscribe by following the instructions and clicking the "unsubscribe" link found at the bottom of any email you receive from us.

To exercise any of the rights listed above, please submit your request in writing to our Data Protection team at:

Email: privacy@sbtsgroup.com

Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our data processing practices or legal requirements. We will notify you of any significant changes by posting the updated policy on our website.