Corporate Privacy Policy
Cleocy Nigeria Limited (RC: 1953806) values your operational privacy. This document outlines how we protect and manage critical engineering designs, RFQ bids, secure sourcing, and personal data under NDPR (Nigeria Data Protection Regulation) and GDPR standards.
1. Scope & Introduction
Cleocy Nigeria Limited (hereinafter referred to as "the Company," "we," "us," or "our"), a fully indigenous corporate body registered in the Federal Republic of Nigeria under RC: 1953806 and TIN: 24288163-0001, operates elite-tier industrial engineering, specialized procurement, ship chandling, surgical equipment and medical consumables supply, and agricultural supply chains.
This Privacy Policy applies to all operations of our digital systems, our client portal, our bidding structures, the USA Sourcing Liaison operations, and our local/branch offices. We strictly enforce compliance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR), the General Data Protection Regulation (GDPR), and all applicable global data sovereignty laws.
By accessing our platforms, submitting an RFQ, or utilizing our procurement pathways, you explicitly acknowledge the processing of data in absolute alignment with the parameters defined inside this Policy.
2. Information We Collect
To deliver certified QMS engineering procurement packages, we process specific categories of data, which may include:
- Operational Identity Information: Full names of engineering contacts, corporate titles, department identifiers, and corporate affiliations.
- Corporate & Liaison Details: Official corporate addresses (including Headquarters, regional branch nodes, and USA sourcing hubs), active email coordinates, telephone numbers, and corporate registration status.
- Bidding & Technical Materials: Uploaded CAD drawings, material safety data sheets, specialized medical inventory lists, ship chandling requests, agribusiness specs, and PET RFQ files.
- Technical Session Data: IP addresses, browser configuration signatures, geolocation metadata (at state or national granularity), page access latencies, and device indicators.
3. How We Use Your Data
We utilize information collected strictly in support of our industrial execution and legal obligations. The legal bases for our data processing include contract performance, compliance with statutory requirements, and protecting legitimate company interests.
- Contract Processing: Translating uploaded lists into official procurement proposals, engineering evaluations, and mobilization schedules.
- Compliance & Safety Auditing: Reviewing drawings and vendor specifications in absolute conformance with ISO 9001:2015 QMS standards and target HSE zero-LTI mandates.
- Tendering Services: Facilitating registered portal uploads and indigenous contractor validations.
- Communications & Liaison Operations: Routing inquiries from our Port Harcourt HQ, Owerri branch, and USA sourcing network to respond with high-precision schedules.
4. RFQ Sourcing & PET Systems
Our proprietary RFQ Bid Portal creates unique, cryptographically secure Project Execution Team (PET) references (e.g., PET-RFQ-26-XXXX) upon submission of drawings or specialized lists.
Any CAD drawing, Bill of Quantities (BOQ), agricultural load manifest, or medical supply catalogue uploaded to our systems is:
- Subject to strict local encryption and access controls, restricting views solely to the appointed PET director and QMS inspectors.
- Used exclusively to generate price calculations, sourcing origins, and logistic pathways via our international supply network (including our Minnesota USA liaison team).
- Never sold, leased, or distributed to non-affiliated third-party bidding platforms.
5. Information Sharing & Transfers
Due to our dual-sector operational structure (Energy and Public Sector) and our active international sourcing, we may share relevant information under strict protective measures with:
- Liaison Operations: Authorized staff at our USA Sourcing Liaison Office (Savage, Minnesota) to coordinate material procurement, custom certifications, and direct manufacturer validation.
- Statutory Regulators: Government and joint-venture auditing bodies, including NNPC and NCDMB, to satisfy local content and indigenous contractor registration parameters.
- Safety & ISO Inspectors: Quality and environmental auditing personnel evaluating compliance with ISO 9001:2015 QMS standards.
All cross-border transfers of data—specifically between our operations in Nigeria and our USA liaison hub—are executed under strict NDPR Standard Contractual Clauses (SCCs), ensuring equivalent protection standards.
6. Security & Data Retention
Cleocy Nigeria Limited deploys comprehensive physical and electronic security layers to safeguard corporate data:
- Encryption: Standard TLS/SSL encryption on all portal connections, combined with encrypted database backends for project submissions.
- Access Controls: strict Role-Based Access Controls (RBAC) preventing unauthorized viewing of engineering designs.
- Retention Schedule: We retain active RFQ bid entries, engineering drawings, and communications for a duration of seven (7) years following project closure, in conformance with Nigerian corporate laws and taxation regulations. Unconverted RFQ drafts are purged after twelve (12) months.
7. Your Rights under NDPR & GDPR
As an authorized corporate user or data subject, you hold complete rights regarding your data:
- Right of Access: The right to demand confirmation and records of all personal and corporate information we process.
- Right to Rectification: The right to correct inaccurate operational metrics or obsolete address records.
- Right to Erasure ("Right to be Forgotten"): Request complete purging of records, subject to company statutory retention obligations.
- Right to Object: Oppose specific marketing channels or automated system actions.
To invoke any of the aforementioned rights, please contact our Data Protection Officer at the coordinates listed inside Section 9.
9. Contact our Privacy Office
For inquiries, rights requests, or corporate compliance questions, please contact our Data Protection Officer: