FacelessCounselling / Facelesscounselling.com is provided by
FacelessCounselling. At Facelesscounselling, we value your privacy, and we are committed to
safeguarding your personal information. All personal data that you provide us will be protected and
kept confidential among our affiliates, representatives, and privies.
Throughout the website, the terms
“we”, “us” and “our” refer to Facelesscounselling.
This Privacy Policy
explains how we collect, use, share and protect your personal data in connection with your
relationship with us as a user of the Faceless Counselling Services. It applies to all our
counsellees (service consumers) and counsellors (service providers)
and every other person we hold information about.
This policy also sets
out your rights and who you may contact for further information. You agree to this Privacy Policy by
visiting our website and when you use our services.
Your use of any of
our services, and any dispute over privacy is subject to this Policy and our Terms of Service,
including its applicable limitations on damages and the resolution of disputes. Our Terms of Service
are incorporated by reference into this Policy.
Our website is hosted
in Nigeria and is subject to the laws of the Federal Republic of Nigeria. If you are accessing our
website from other jurisdictions, please be advised that you are transferring your personal
information to us in Nigeria, and by using our website, you are agreeing to the transfer and use of
your personal information in accordance with this Privacy Policy. You also agree to abide by the
applicable laws of the Federal Republic of Nigeria concerning your use of the website and your
agreements with us.
Our website and the
Facelesscounselling Services are not directed at you if we are prohibited by any law of any jurisdiction from
making the information on our website available to you and is not intended for any use that would be
contrary to local law or regulation.
2. Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following
conditions. The following definitions shall have the same meaning regardless of whether they appear
in singular or in plural.
Consent
-
means the consent of the data subject which must be a freely given, specific, informed, and
unambiguous indication of the data subject’s wishes by which they (by a statement or by a clear
affirmative action) signify their agreement to the processing of personal data relating to them;
Data
Controller - means the natural or legal person or organisation which, alone or
jointly with others, determines the purposes and means of the processing of personal data. For
the purposes of this Policy, FacelessCounselling is the data controller of all personal data
provided in relation to our website and the Facelesscounselling Services;
Data
Processor - means a person or organisation which processes personal data on behalf
of a data controller. This includes FacelessCounselling, its employees and third-party service
providers;
Data
Protection Legislation - means all applicable data protection and privacy laws
including, but not limited to the Nigeria Data Protection Act 2023 (NDPA), and any successor
legislation;
Data
Subject -
means a living, identified, or identifiable individual about whom Facelesscounselling holds
personal data;
Personal
Data - means any information relating to a data subject who can be identified,
directly or indirectly, in particular by reference to an identifier such as a name,
identification number, location data, an online identifier, or to one or more factors specific
to the physical, physiological, genetic, mental, economic, cultural, or social identity of that
data subject;
Personal
Data Breach - means a breach of security leading to the accidental or unlawful
destruction, loss, alteration, unauthorised disclosure of, or access to, personal data
transmitted, stored, or otherwise processed;
Processing - means any operation or set of operations performed on personal
data or sets of personal data, whether or not by automated means, such as collection, recording,
organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction
Facelesscounselling Services - means Social Therapy via feed posts, Faceless
Support Group, Facelesscounselling, Organizational (school and work place) faceless counselling,
Couples or group faceless counselling, pre marriage faceless counselling offered by
Facelesscounselling through the Website, subject to updates or additions over time.
User
- means you who views this Website, mobile app access Facelesscounselling Services
Website
-means Facelesscounselling.com including any mobile or web
application hosted by Facelesscounselling for the purpose of providing Facelesscounselling's
Services.
3. Consent
3.1. Where processing of your personal data is based on consent, we shall obtain the requisite consent at the time of collection of the personal information. In this regard, you consent to the processing of your personal information when you access our Website, or use our Facelesscounselling, content, features, technologies, or products offered on our Website or other digital platforms. You can withdraw your consent at any time, but such withdrawal will not affect the lawfulness of the processing of your data based on consent given before its withdrawal.
3.2. Where your personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to you when you first provided your consent, we will obtain your consent to the new purpose or purposes.
4. Age Restriction
4.1. You affirm that you are over 18 years old and have the right to contract in your own name, and that you have read the above authorisation and fully understand its contents.
4.2. Individuals under 18 years old are only allowed to sign up for our services or provide us with their information when an adult above the age of 18 is signing contracts in their stead.
5. Data Protection Principles
The Data Protection Legislation sets out the following principles with which anyone handling personal data must comply. We, our employees, agents, contractors and third-party service providers comply with the following principles when collecting or processing your personal data. All personal data must be
5.1. processed lawfully, fairly, and in a transparent manner in relation to the data subject;
5.2. collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
5.3. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
5.4. accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;
5.5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Legislation in order to safeguard the rights and freedoms of the data subject
5.6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
6. Information Collected
In providing the Facelesscounselling Services to you, we collect certain non-personal and personal data about you. Our policy is to keep this information confidential and strictly secure, and to use or disclose it only as needed to provide the Facelesscounselling Services to you, or as permitted or required by the Data Protection Legislation.
6.1
Information Collected Automatically: Whenever you visit our Website, our web servers automatically collect non-personal information such as the domain name of the internet access provider, the internet protocol address used to connect the computer to the internet, the average time spent on our Website, pages viewed, information searched for, access times, usage statistics about your interactions with the Facelesscounselling Services, including content accessed, search queries, location data, Information on the rewards earned, time spent on pages or the service, and other relevant statistics. We share aggregated demographic information with our partners and sponsors not linked to any personally identifiable information.
6.2. Information You Provide Us: Facelesscounselling collects your data from you, your authorised users, and processes that data on behalf of you as a data processor. If you provide us with personal information, you create a login account on our Website by contacting us, creating a login account on our Website or subscribing to the Facelesscounselling Services we collect the following personal information:.
6.2.1. Name and email address, phone numbers and such other information as we may require.
6.2.2. Username and password;
6.2.3 Contact information;
6.2.4 Social media handles (For our counsellors registration): This is to help us examine your previous contents and post so as to aid us in deciding if you (the applicant) is a good fit as a counsellor in Facelesscounselling
6.2.5 Any other information you provide to us.
6.2.6 If you contact us, we collect additional information such as your location, and any personal information that you provide in your contact request.
7. Using your Personal Data
7.1. We primarily collect your personal data to ensure that we provide the Facelesscounselling Services to you, monitor the use and improve our Website and other legitimate interests. Your information will solely be used and disclosed for the following purposes:
7.1.1. To provide and operate the Facelesscounselling Services;
7.1.2. To help us verify your identity;
7.1.3. To carry out our obligations ensuing from any contracts entered into between you and us;
7.1.4. To provide you with ongoing customer assistance and technical support;
7.1.5. To assist you with enquiries and improve our customer service;
7.1.6. To assist us in carrying out marketing analysis and customer profiling (including transactional information), conduct research, including creating statistical and testing information;
7.1.7. To facilitate the services technical functioning, including troubleshooting and resolving issues, securing the services, and preventing fraud and abuse;
7.1.8. To allow us to communicate with you in any way (including e-mail, telephone, visit, and text or multimedia messages);
7.1.9. For our billing and account purposes;
7.1.10. To help prevent and detect fraud or loss;
7.1.11. To update our records
7.1.12. To make recommendations and suggestions to you about services offered by us unless you have previously asked us not to do so;
7.1.13. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
7.1.14. To send you service or support messages, such as updates, security alerts, email notifications and /or newsletters;
7.1.15. To conduct investigations and risk assessments;
7.1.16. As required or permitted by law;
7.1.17. For compliance with legal and regulatory obligations;
7.1.18. As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our services.
7.2. Employees, agents, contractors, or other parties working on behalf of Facelesscounselling shall collect your personal data only to the extent required for the performance of their job duties and only in accordance with this policy. Excessive personal data will not be collected.
7.3. Employees, agents, contractors, or other parties working on behalf of Facelesscounselling shall process your personal data only when the performance of their job duties requires it. Your personal data held by Facelesscounselling cannot be processed for any unrelated reasons.
8. Data Accuracy
Your personal data must be accurate and kept up to date. In this regard, Facelesscounselling shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to you; make efforts to keep your personal data updated where reasonable and applicable; and make timely efforts to correct or erase your personal data when inaccuracies are discovered.
9. Data Retention
Facelesscounselling shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. Except in the case of our obligations to keep your personal data to fulfil statutory obligations, on the authority of a competent court or authority, or to assist us in any investigations, your personal data will not be held for more than a period more than 5 years from the end of our business relationship with you.
10. Other Information We Collect
Facelesscounselling uses various analytic tools, including Google Analytics to help analyse how visitors use our Website. Google Analytics uses cookies to collect standard internet log information and visitor behaviour information in an anonymous form. We may also collect Personal Data pertaining to visitors and users of your Website or Facelesscounselling Services. We may also collect information from you using cookies and other analytical tools especially when you use our products and services. More details are provided below in our section on Cookies. Facelesscounselling may receive Personal Data about you from third-party sources, such as security providers, fraud detection and prevention providers to help us screen out users associated with fraud, and in some cases, we may collect Personal Data from lead enhancement companies which help us to improve our service offering; advertising and marketing partners in order to monitor, manage and measure our advertisement campaigns.
11. Data Confidentiality
Your information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request copies of any and all information we keep on you, if such requests are made in compliance with applicable laws and other relevant enactments. While we are responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorised officers of Facelesscounselling.
12. Disclosures
12.1.
We will not sell, publish, or disclose to third parties your personal data collected on our Website, through our servers or otherwise obtained by us, other than to provide our services and as set forth in this policy. We may share generic aggregated demographic information not linked to any personally identifiable information regarding visitors and users with our business partners, trusted affiliates, professional advisers and advertisers for the purposes outlined above. We may share your information with these third parties for those limited purposes if you have given us your permission and in compliance with the Data Protection Legislation.
12.1.2.
We may request and provide information about you from and to third parties to provide our Facelesscounselling Services. Facelesscounselling has partnered with service providers, whose services and solutions complement, facilitate, and enhance our own including hosting and server co-location services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimisation and marketing services, and content providers. may share the following categories of Personal Data with Third Party Service Providers for a business purpose:
12.2.1.
identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
12.3.
You have the right to request an erasure of your data at any time.
12.4.
We will notify you if we are transferring your data.
12.5.
You may request at any time that we halt further dissemination of your data or cease to use your data.
12.6.
If you submit content in a public forum or a social media post, or use a similar feature on our Website, that content is publicly visible.
12.7.
We may disclose Personally Identifiable Information if required to do so by law or in the good faith belief that such action is necessary to
i.
conform with the requirements of the law or comply with legal process served on us, or
ii.
act in urgent circumstances to protect the personal safety of users of our service or members of the public.
12.8.
To the extent practicable and legally permitted, we will attempt to advise you prior to any such disclosure, so that you may seek a protective order or other relief limiting such disclosure.
13. Transfer of Personal Data
13.1. Third Party Processor
Third Party Processor
We may engage the services of third parties in order to process your personal data. The processing by such third parties shall be governed by a written contract with Facelesscounselling Health to ensure adequate protection and security measures are put in place by the third party for the protection of your personal data in accordance with the terms of this policy and the Data Protection Regulation.
13.2. International Transfers
13.2.1.
Your information may be transferred to a foreign country or international organisation for the purpose of providing our service to you. We will ensure that there are adequate data protection laws in the recipient country or organisation before transferring your information. In particular, we shall, among other things, conduct a detailed assessment of whether the said country is on the Nigeria Data Protection Commission (NDPC) Whitelist of Countries with adequate data protection laws or any other relevant authorities that exist and may come into existence in the jurisdictions where the company has offices.
13.2.2.
Transfer of your personal data out of Nigeria would be in accordance with the provisions of the NDPA. We will therefore only transfer your personal data out of Nigeria on one of the following conditions:
13.2.2.1.
our explicit consent has been obtained;
13.2.2.2
The transfer is necessary for the performance of a contract between you and Facelesscounselling;
13.2.2.3
The transfer is necessary to conclude a contract between Facelesscounselling and a third party in your interest;
13.2.2.4
The transfer is necessary for reason of public interest;
13.2.2.5
The transfer is for the establishment, exercise or defense of legal claims;
13.2.2.6
The transfer is necessary in order to protect your vital interests or the interests of other persons, where you are physically or legally incapable of giving consent.
13.2.3.
Provided, in all circumstances, that you have been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this provision shall not apply to any instance where you are answerable in duly established legal action for any civil or criminal claim in another country.
13.2.4.
We will take all necessary steps to ensure that your personal data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Nigeria shall be provided to you upon request.
13.2.5.
Where none of the conditions stipulated in clause 13.2.1 and 13.2.2 of this Policy are met, Facelesscounselling will engage with NDPC for approval with respect to such transfer.
14. Your Rights
Subject to certain limitations and exceptions, you are entitled to the following principal rights under the Data Protection Legislation:
You have the right to be notified if we are transferring your personal information.
You have the right to request that we rectify inaccurate personal information.
You may request at any time that we halt further dissemination of your data or cease to use your personal information.
You have the right to request for copies of your personal information.
15. Website Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as secure sockets layer (SSL) to safeguard and secure the information we collect online. We use encryption tools when accepting and transmitting delicate visitor information through our Website. Some of the other safeguards we use are firewalls and physical access controls to our data centers, and information access authorisation controls.
16. Training
We shall ensure that employees who collect, access and process your personal data receive adequate data privacy and protection training in order to develop the necessary knowledge, skills and competence required to effectively manage the compliance framework under this policy and the Data Protection Legislation with regard to the protection of personal data. On an annual basis, we shall develop a capacity building plan for our employees on data privacy and protection in accordance with the Data Protection Legislation.
17. Use of Cookies
We use cookies to identify you as a user and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our Website. Cookies allow our servers to remember your account log-in information when you visit our Website, IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities. If your browser or browser add-on permits, you have the choice to disable cookies on our Website; however, this may limit your ability to use our Website.
19. Data Breach Management Procedure
19.1.
In the event where there is any accidental or unlawful destruction, processing, loss, alteration, unauthorised disclosure of, or access to your personal data, we shall:
19.1.1.
notify you within 24 hours of the occurrence of the data breach;
19.1.2.
properly investigate the breach and take the necessary steps to mitigate such breach;
19.1.3.
identify remediation requirements and track the resolution of such breach;
19.1.4.
notify the Nigeria Data Protection Commission or any other regulatory authority, where necessary.
20. Links to Third Party Websites
20.1.
Our Website may contain links to third-party websites or services that are not owned or controlled by us.
20.2.
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services.
20.3.
We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.
21. Limitation of Liability
We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorised disclosure of personal data that occurs through no fault of ours.
22. Changes to this Privacy Policy
Changes may be made to this Privacy Policy from time. Whenever such changes are made, we will notify you. These changes will take effect immediately after you have been notified.
23. Contact Us
Contact Us
If you would like more information or you have any comments or questions on our Privacy Policy, please contact our Data Protection Contact at [email protected].
Faceless