1. Introduction

Welcome to the Nigerian Association of Chambers of Commerce, Industry, Mines, and Agriculture (NACCIMA) Application Portal. NACCIMA is committed to protecting your personal and corporate data in strict compliance with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID).

This Privacy Notice explains how we collect, use, share, and protect the information you provide when registering and applying for the NACCIMA/ODDO BHF lending and financing support facility via this portal.

2. The Data We Collect

To successfully process your application, conduct Know Your Customer (KYC) verifications, and perform due diligence, we collect the following categories of data:

• Identity & Contact Data: Full name, designation, email address, phone number, and official correspondence details.
• Corporate Data: Company name, RC number, Business Membership Organization (BMO) affiliation status, and operational linkages with MSMEs.
• Financial & Technical Data: 3-year audited financial accounts, Environmental, Social, and Governance (ESG) compliance records, and equipment sourcing documentation.
• System Data: IP address, browser type, device information, and portal usage metrics collected via strictly necessary cookies.

3. Purpose and Lawful Basis for Processing

We process your data under the lawful bases of Consent, Contractual Necessity, and Legitimate Interest. Your data is used exclusively to:

• Evaluate your eligibility for the financing facility (including the 35–50% European-sourced equipment requirement).
• Verify your character and operational standing through affiliated BMOs.
• Communicate application statuses, REOI updates, and subcommittee decisions.
• Comply with national and international financial regulatory requirements.

4. Data Sharing and Third-Party Disclosures

To facilitate this financing scheme, your data may be securely shared with strictly vetted third parties, including:

• ODDO BHF SE: Our financing partner. (Note: As ODDO BHF is based in Germany, your application data will be subject to a cross-border transfer. This transfer is safeguarded by the European Union’s General Data Protection Regulation (GDPR), which the NDPC recognizes as providing an adequate level of data protection).
• Accredited Professionals: Bank of Industry (BOI)-accredited external financial auditors, property valuers, and legal experts engaged by the Joint NACCIMA/ODDO BHF Subcommittee for specialized verification.
• NACCIMA Ecosystem: Regional chambers and BMOs strictly for KYC and membership validation.

5. Data Security and Retention

This portal is built upon a "Privacy-by-Design" framework. All uploaded documents (especially audited accounts) are encrypted in transit and at rest. Your data will be retained only for as long as necessary to fulfill the purpose of the financing scheme, after which it will be securely anonymized or deleted, unless extended retention is required by Nigerian financial regulatory laws.

6. Your Data Protection Rights

Under the NDPA 2023, you retain the following rights regarding your data:

• Right to Access: Request a copy of the data we hold about you.
• Right to Rectification: Correct any inaccurate or incomplete data.
• Right to Erasure: Request the deletion of your data (subject to legal or contractual retention obligations).
• Right to Restrict Processing: Temporarily halt the processing of your data during a dispute.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Withdraw Consent: You may withdraw your consent at any time; however, this will necessitate the termination of your funding application.

7. Contact Information

NACCIMA has appointed a dedicated Data Protection Compliance Organization (DPCO) and Corporate Data Protection Officer (DPO) to oversee our regulatory compliance. For privacy-related inquiries, data subject requests, or to report a breach, please contact our DPO desk:

• Corporate DPO: Data Analytics Privacy Technology Limited
• Official Communication Channel: investment@naccima.com
• Contact Address: NACCIMA Headquarters, No. 8A, Oba Akinjobi Way, GRA, Ikeja, Lagos.