Leadway Assurance Company Limited (Leadway) is committed to ensuring that the privacy and personal information of its clients and employees (data subjects) are protected. Leadway is the entity that collects and processes your personal information and the responsibility is not outsourced to any third party. Leadway is also responsible for complying with extant Nigerian and applicable international laws on data protection. For the purpose of this Privacy Policy, references to Leadway or the Company shall mean Leadway Assurance.

By providing the data subject’s personal information or the personal information of a beneficiary from the data subject’s policy, the data subject acknowledges that Leadway may only use the information in the manner specified in this Privacy Policy.

There may be a need to update this policy periodically, for example as a result of government regulation, new technologies or other developments on data protection and / or privacy laws. The current version of this policy is available on our website (www.leadway.com) and Leadway’s mobile app.

Role Definitions

The following roles are defined for the purpose of this policy:

Data Subject: is an identifiable person; one who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity and includes Leadway’s clients, customers, business partners and employees.

Data Administrator: means a persons or organization that processes data. For the purpose of this policy, Leadway Assurance Company Limited is the Data Administrator.

Data Controller: means a person who either alone, jointly with other persons or in common with other persons or as a statutory body determines the purposes for and the manner in which personal data is processed or is to be processed. For the purpose of this policy, the Managing Director is the Data Controller or whoever he so delegates.

Data Protection Officer: is appointed by the data controller to ensure that the strategy and implementation of data protection requirements are in compliance with the data protection policy and the relevant extant laws. For the purpose of this policy, the data protection officer is defined as the Chief Compliance Officer of Leadway.

Responsibilities of the Data Administrator, Data Controller and Data Protection Officer are clearly outlined in the Change Nigerian Data Protection Regulation 2019 to Nigerian Data Protection Act, 2023

Introduction

When Leadway collects and processes the personal information of its data subjects, Leadway ensures it adheres to strict controls to ensure that personal data of the data subject is obtained and used in line with the company’s privacy principles. Leadway handles personal data with the greatest care and use it only for legitimate and specified business purposes under the following principles:

1. Leadway respects the privacy rights of its employees, customers, clients, business partners and other individuals whose personal data are in its custody and
2. Leadway protects personal data by implementing appropriate technical and organizational measures in our data processing
3. Leadway obtains personal data fairly and only use it for legitimate business
4. Leadway holds itself accountable for demonstrating compliance with applicable legal and regulatory requirements and understanding of our roles and

All personal information collected by Leadway is processed in accordance with the extant data protection laws in Nigeria.

Type of Information Processed by Leadway

The precise nature of the personal data Leadway processes depends on data subject’s relationship with Leadway. However, in many cases, if the Company is handling the data subject’s personal data as part of its role as an insurer, the Company may process the following:

• Information about the data subject – for example name, age, gender, date of birth, nationality. Even though in some instances Leadway do not receive your name, the Company needs enough information to identify the data subject and her policy so that the Company can provide services to its
• Means of identification – date of birth, National Identity Card Number (NIN), International Passport, details, Drivers’ License, Voter’s card details, etc.
• Contact information – in some cases, for example, the Company may receive the data subject’s email, address, and phone number.
• Online information – for example cookies and IP address (your computer’s internet address), if you use Leadway’s
• Financial information – the Company may process information related to payments the data subject make or receive in the context of an insurance policy or This includes information such as Bank Verification Number (BVN) and information obtained from credit reference agencies.
• Contractual information – for example details about the policies a data subject holds and with whom the data subject holds.
• Health information – such as smoker status or medical related issues relevant to a policy the data subject holds or a claim the data subject has.
• Other sensitive personal data (Health background / information, Marital status, criminal history record, Biometric details, Academic records, and Gender)