hello@vbalagos.com
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+234 902 027 0442
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Apapa • Lekki • Ikoyi
SERVICE AREAS
Mon–Fri • 9AM–5PM
BUSINESS HOURS
Privacy Notice
Effective Date: [To be inserted before launch]
1. About This Privacy Notice
This Privacy Notice explains how VBA — Virtual Business Address (“VBA”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal information when individuals and businesses apply for or use our services, communicate with us, or interact with our website.
We are committed to handling personal information responsibly and in accordance with applicable data-protection requirements in Nigeria.
2. Information We May Collect
Depending on how you interact with VBA and the services you request, we may collect information including:
(a) your full name;
(b) email address;
(c) telephone or WhatsApp number;
(d) residential or contact address;
(e) company, organisation or business name;
(f) CAC registration number and business-registration information;
(g) nature of business or profession;
(h) information about the VBA service or services you require;
(i) the purpose for which you intend to use the selected service;
(j) identification documents, company-registration documents or other supporting documents that we may request for verification;
(k) communications and correspondence between you and VBA;
(l) payment and transaction information necessary to confirm payment for our services; and
(m) other information that you voluntarily provide or that is reasonably necessary to administer your application or service.
We seek to collect only information that is reasonably necessary for the relevant purpose.
3. How We Collect Information
We may collect personal information directly from you when you:
(a) complete the VBA Client Application;
(b) communicate with us through WhatsApp, email, telephone or another official VBA communication channel;
(c) provide identification or supporting documentation requested during verification;
(d) subscribe to or renew a VBA service;
(e) make or confirm a payment;
(f) book or use a meeting room;
(g) collect correspondence or otherwise interact with our mail-management service; or
(h) contact us with an enquiry, request or complaint.
We may also receive information from authorised representatives acting on behalf of a business or applicant and, where appropriate and lawful, from records or sources used to verify information supplied to us.
4. Why We Use Personal Information
We may process personal information where necessary to:
(a) receive and assess applications;
(b) identify and communicate with applicants and clients;
(c) verify applicants, businesses and information provided to VBA;
(d) understand the intended use of our services;
(e) decide whether an application can be approved;
(f) activate, administer, renew, suspend or terminate services;
(g) manage professional business address services;
(h) notify clients about correspondence received for them;
(i) administer meeting-room reservations;
(j) issue or maintain appropriate payment and transaction records;
(k) prevent, identify or investigate suspected fraud, misuse or unlawful activity;
(l) maintain appropriate business and compliance records;
(m) respond to enquiries, requests, complaints or disputes;
(n) protect VBA, its premises, personnel, clients and services; and
(o) comply with applicable legal or regulatory obligations.
5. Lawful Basis for Processing
Depending on the circumstances, VBA may process personal information on one or more lawful bases recognised under applicable data-protection law.
These may include processing necessary to take steps at your request before entering into a service arrangement or to perform an agreement with you, processing necessary to comply with applicable legal obligations, processing based on legitimate interests where those interests are appropriate and do not override applicable rights, and processing based on consent where consent is the appropriate lawful basis.
Where VBA relies on consent, you may withdraw that consent subject to applicable law and without affecting processing that was lawful before the withdrawal.
The Nigeria Data Protection Act recognises several lawful bases rather than requiring consent for every type of processing.
6. Client Application and Verification Information
Information submitted through the VBA Client Application is used primarily to assess the application, communicate with the applicant, perform appropriate verification and determine whether the requested service can be provided.
Submission of an application does not itself mean that the application has been approved.
Where further verification is necessary, VBA may request identification, business-registration documents or other relevant supporting information.
Applicants should provide requested documents only through communication channels designated by VBA.
7. Identification and Supporting Documents
VBA does not presently require applicants to upload identification documents directly through the public Client Application form.
Where identification or supporting documentation is required, VBA may request that it be provided subsequently through an official VBA communication channel, including the official WhatsApp channel where appropriate.
Identification and supporting documents will be used for legitimate verification, compliance, security and service-administration purposes.
Applicants should not send identification or sensitive documents to telephone numbers, email addresses or other channels that have not been designated by VBA.
8. WhatsApp, Email and Other Communications
Where you contact VBA through WhatsApp, email, telephone or another communication service, information contained in those communications may be processed for purposes such as responding to enquiries, reviewing applications, conducting verification, administering services and maintaining appropriate business records.
Your use of a third-party communication platform may also be subject to that provider’s own privacy practices and terms. VBA does not control how an independent third-party platform processes information through its own systems.
Clients should use VBA’s official communication details when sending information relating to their application or service.
9. Mail and Correspondence Information
Where a client subscribes to a mail or correspondence service, VBA may process information necessary to identify correspondence addressed to that client, record its receipt where appropriate, notify the client and facilitate collection.
VBA does not provide a general mail-scanning service unless separately agreed.
Information appearing on correspondence received for a client will be handled only to the extent reasonably necessary to administer the subscribed service, meet applicable obligations and protect the security and integrity of VBA’s operations.
10. Payment Information
Where you pay for a VBA service, we may maintain information necessary to identify and confirm the transaction, including the client or applicant associated with the payment, amount paid, date, payment reference, invoice or receipt information and payment status.
Where payments are processed through a bank, payment provider or other independent financial service, that provider may separately process information in accordance with its own privacy practices.
VBA should not require clients to provide confidential banking credentials such as passwords or PINs for the purpose of confirming payment.
11. How We May Share Information
VBA does not disclose personal information merely because another person requests it.
Where necessary and lawful, information may be disclosed to:
(a) employees or authorised personnel who require access to perform their responsibilities;
(b) service providers that support VBA’s website, communications, technology, payment, professional or administrative operations;
(c) professional advisers where their services reasonably require access to relevant information;
(d) competent governmental, regulatory, judicial or law-enforcement authorities where disclosure is lawfully required or otherwise permitted; or
(e) another party where you have authorised the disclosure or where another lawful basis permits it.
Where third parties process personal information on VBA’s behalf, VBA will take reasonable steps appropriate to the circumstances to ensure that the information is handled consistently with applicable requirements.
12. International or Third-Party Services
Some technology, communication, hosting or other service providers used in connection with VBA’s operations may process or store information using infrastructure located outside Nigeria.
Where personal information is transferred internationally, VBA will take reasonable steps to ensure that the transfer is made in accordance with applicable data-protection requirements.
Use of third-party services may also be subject to the independent privacy practices of those providers.
13. Data Security
VBA takes reasonable organisational and technical measures appropriate to the nature of the information we process and the risks involved.
These measures are intended to protect personal information against unauthorised access, loss, misuse, alteration, disclosure or destruction.
Access to personal information should be limited to persons who reasonably require it for legitimate VBA purposes.
No website, electronic communication system or storage method can be guaranteed to be completely secure. Applicants and clients should therefore also take reasonable care when transmitting personal information and should use official VBA channels.
14. Data Retention
VBA will retain personal information for no longer than reasonably necessary for the purposes for which it was collected, subject to applicable legal, regulatory, accounting, dispute-resolution and legitimate record-keeping requirements.
Different categories of information may therefore be retained for different periods.
When personal information is no longer reasonably required, VBA may securely delete, destroy or anonymise it, subject to any continuing obligation or lawful reason for retention.
Storage limitation is among the data-processing principles reflected in the NDPC’s current implementation guidance.
15. Accuracy of Information
Applicants and clients should provide accurate and current information.
Where information supplied to VBA materially changes, the applicant or client should notify VBA so that relevant records can be updated.
VBA may take reasonable steps to verify or correct information where necessary for the administration or security of its services.
16. Your Data-Protection Rights
Subject to applicable law and the circumstances of the processing, you may have rights concerning your personal information, including rights to:
(a) be informed about the processing of your personal information;
(b) request access to personal information held about you;
(c) request correction of inaccurate or incomplete information;
(d) request deletion or erasure where applicable;
(e) request restriction of certain processing where applicable;
(f) object to certain processing where applicable;
(g) request data portability where applicable;
(h) withdraw consent where processing is based on consent;
(i) raise concerns or complaints concerning the processing of your personal information; and
(j) exercise applicable rights concerning certain automated decision-making.
These rights may be subject to conditions, limitations or exemptions under applicable law. The NDPC currently identifies rights including information, access, rectification, objection, restriction, portability, erasure and protections concerning automated decision-making.
17. Exercising Your Rights
Requests concerning personal information may be submitted to VBA using the contact information at the end of this Privacy Notice.
To protect personal information from unauthorised disclosure or alteration, VBA may take reasonable steps to verify the identity and authority of the person making a request before acting on it.
VBA will consider and respond to valid requests in accordance with applicable data-protection requirements.
18. Cookies and Website Information
The VBA website may use cookies or similar technologies that are necessary for website functionality, security, performance or other legitimate website operations.
Where cookies or similar technologies require consent under applicable requirements, appropriate choices should be provided to website visitors.
Third-party services incorporated into the website may also use technologies governed by their own privacy practices.
This section should be read together with any cookie controls or notices displayed on the VBA website.
19. Links and Third-Party Websites
The VBA website or communications may contain links to third-party websites, services or platforms.
VBA is not responsible for the independent privacy practices or content of third parties merely because a link to their service appears on a VBA website or communication.
Users should review the privacy information provided by the relevant third party before providing personal information directly to it.
20. Children
VBA’s services are intended for persons legally capable of applying for or entering into the relevant business-service arrangements and are not designed as services directed specifically at children.
VBA does not intentionally seek to collect children’s personal information through its ordinary Client Application process.
Where VBA becomes aware that personal information relating to a child has been submitted in circumstances requiring additional legal protections or authorisation, VBA may take appropriate steps consistent with applicable requirements.
21. Automated Decision-Making
VBA does not intend to make decisions producing significant effects on applicants or clients solely through automated processing without appropriate safeguards where such safeguards are required by applicable law.
Applications may be reviewed using information supplied by applicants together with reasonable verification and compliance procedures.
22. Data Breaches and Security Incidents
Where VBA becomes aware of a personal-data breach or security incident affecting personal information, VBA will assess the incident and take reasonable steps to contain, investigate and address it.
Where notification to affected individuals or a competent authority is required under applicable law, VBA will take appropriate steps to make the required notification.
23. Complaints
If you have a concern about how VBA has handled your personal information, you may contact VBA so that the matter can be reviewed.
Nothing in this Privacy Notice is intended to prevent an individual from exercising any right to make a complaint to the competent data-protection authority where such a right exists under applicable law.
The Nigeria Data Protection Commission is Nigeria’s data-protection regulator established under the Nigeria Data Protection Act 2023.
24. Changes to This Privacy Notice
VBA may update this Privacy Notice from time to time to reflect changes in our services, information-handling practices, technology, operational requirements or applicable legal requirements.
Where appropriate, an updated version will be published on the VBA website with a revised effective date.
Individuals should review the current version of this Privacy Notice when they wish to understand how VBA handles personal information.
25. Contact Us
Questions, requests or concerns regarding this Privacy Notice or VBA’s handling of personal information may be directed to:
VBA — Virtual Business Address
Email: hello@vbalagos.com
Location: Lagos, Nigeria
This Privacy Notice should be read together with the VBA Terms of Service where you apply for or use a VBA service.