At NBH (Back to Original), we take privacy seriously. This Privacy Policy explains how we collect, use, store, disclose, and protect the personal information of our employees, customers, partners, and visitors. It is rooted in our company’s values of integrity, discipline, transparency, respect, and service. By working with NBH, engaging our services, or becoming a member of our team, you agree to the terms outlined in this policy.
1. Scope of the Policy
This Privacy Policy applies to:
- Employees & Job Applicants – information collected during recruitment, onboarding, and employment.
- Customers & Clients – data gathered when making inquiries, visiting our showrooms, purchasing products, or engaging customer service.
- Partners & Vendors – information provided in the course of doing business with NBH.
- Website & Digital Users – information collected when interacting with our online platforms or digital tools.
This policy is binding on all NBH staff, contractors, interns, and affiliates, and extends to any third parties handling NBH-related data.
2. Information We Collect
NBH may collect the following categories of data:
a. Employee Data
- Personal identification: name, address, phone number, email, next of kin, emergency contact.
- Employment records: CVs, qualifications, performance records, disciplinary records, attendance logs.
- Financial information: bank account details for salary payment.
- Health data: medical reports, maternity/paternity documentation, health insurance information.
- Security data: photographs, ID numbers, CCTV footage within NBH premises.
b. Customer Data
- Identity: full name, contact details, and company name where applicable.
- Transaction details: product purchases, invoices, receipts, payment confirmations.
- Communication history: inquiries, complaints, feedback, and support requests.
- Digital data: interactions on NBH’s website, emails, and online forms.
c. Partner & Vendor Data
- Business registration details, tax information, contact persons.
- Banking/payment details for transactions.
- Contractual agreements and communications.
d. Technical & Digital Data
- Device information (IP address, browser type, operating system).
- Cookies and browsing history when visiting NBH websites.
- Access records for NBH digital platforms and remote work tools.
3. How We Use Your Information
NBH collects information strictly for lawful, ethical, and business-related purposes:
- Employment & HR Management – recruitment, payroll, health and safety, disciplinary processes, and staff welfare.
- Customer Service & Transactions – processing orders, delivering goods, issuing receipts, handling complaints.
- Performance Monitoring – attendance tracking, compliance with workplace rules, CCTV monitoring for safety.
- Legal & Compliance – verifying leave documentation, reporting financial transactions, ensuring health and safety standards.
- Marketing & Communication – sending approved updates, promotional messages, and service information (with consent).
- Security – preventing theft, fraud, misuse of company resources, or unauthorized disclosures.
NBH does not sell, rent, or trade personal information to third parties.
4. Legal Basis for Processing
We process personal data based on:
- Consent – freely given by employees, customers, or partners.
- Contractual obligation – necessary to fulfill agreements.
- Legal requirements – as required under labor, tax, or corporate laws.
- Legitimate interest – ensuring security, discipline, and business efficiency.
5. Confidentiality & Non-Disclosure
- Employees must never share company, customer, or colleague information outside authorized channels.
- Personal contact details (phone numbers, bank accounts) must not be exchanged with customers.
- Social media posts related to NBH are strictly prohibited without written approval.
- Gossip, false absence claims, and unauthorized sharing of documents are violations of both the Employee Handbook and this Privacy Policy.
6. Data Sharing & Third Parties
NBH may share personal data with:
- Service Providers – banks, health insurance providers, logistics partners.
- Regulatory Authorities – tax agencies, labor regulators, or law enforcement.
- Technology Partners – IT vendors maintaining NBH systems and platforms.
All third parties are bound by confidentiality and data protection agreements.
7. Data Retention
- Employee data is retained for the duration of employment and up to 7 years after exit unless longer is required by law.
- Customer data is retained for as long as necessary to complete transactions and maintain after-sales support.
- CCTV and digital logs are retained for a minimum of 90 days unless required for an investigation.
8. Security of Information
NBH implements strict safeguards:
- Access control – only authorized personnel may access sensitive data.
- Digital protections – password policies, device monitoring, and encryption.
- Physical protections – CCTV monitoring, secure filing, restricted access zones.
- Penalties – violations may result in fines, deductions, suspension, or termination as outlined in the Discipline & Compliance section of the Handbook.
9. Employee Monitoring
For transparency and security:
- Attendance, lateness, and absence records are monitored.
- CCTV is installed in NBH facilities for safety and compliance.
- Digital activity (emails, remote work tools, device usage) may be reviewed.
- Unauthorized use of company property or platforms will attract disciplinary action.
10. Your Rights
Employees, customers, and partners have the right to:
- Access – request copies of the personal data NBH holds.
- Correction – update inaccurate or incomplete records.
- Withdrawal of Consent – withdraw consent for optional uses like marketing.
- Deletion – request erasure of personal data when no longer necessary.
- Objection – refuse certain processing activities.
Requests should be directed to NBH Human Resources / Data Protection Office.
11. Social Media & Public Disclosure
- Employees must not post NBH-related content, images, or internal matters online.
- Customers’ information must never be shared in any public forum.
- Violations lead to immediate disciplinary measures, including termination.
12. International Transfers
If NBH data is transferred outside Nigeria (e.g., for cloud hosting or partnerships), NBH ensures compliance with international data protection standards.
13. Updates to Policy
NBH may update this Privacy Policy periodically to reflect changes in law, company policy, or business needs. Updates will be communicated internally and via official company channels.
14. Contact Us
For privacy concerns, questions, or rights requests, please contact:
NBH Data Protection Office (DPO)
Email: [Insert Official Email]
Phone: [Insert Official Line]
Address: [Insert Company Address]
15. Final Note
At NBH, privacy is more than compliance — it is a demonstration of respect, trust, and discipline. Every staff member is personally responsible for upholding this policy. By signing your Employee Agreement or engaging NBH’s services, you confirm that you have read, understood, and accepted this Privacy Policy.
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