Privacy Policy

This Privacy Policy covers the processing of personal data by Revapt (“we” or “us” in this policy) when providing its services to its clients. If you have any questions or comments about this Privacy Policy, please contact us at:


Revapt is committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you or from public sources or third parties will be processed by us. When we decide the purpose or means for which this personal data is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the Nigeria Data Protection Act (NDPA). You have the right to object to us processing your personal data for direct marketing purposes. Please see paragraph 7 below for more details on how to do this.


This Privacy Policy explains the following:

  • What personal data we may collect about you
  • Why our processing is lawful
  • Who we may share your information with.
  • How we will use that information.
  • Who we may disclose that information to. and
  • Your rights regarding the information.

1. What information will Revapt collect about me?


We collect and process the following data, which may include your personal data.

Revapt’s Website:

If you contact us about our services or request a demo on our website, the forms you complete or the emails you send may include information about you, such as your full name, your email address, the organisation on behalf of whom you are contacting us, and your enquiry.

Revapt’s Online Client Platform:

In order to provide a Revapt Client with access to our platform and enable them to access our services, we collect the full name, email address, and password of each individual authorised by such client to access the platform.

Analytics on the Website and the Platform:

Our website and online client platform use cookies and other mechanisms to collect and log analytical information, to help analyse use, to compile statistical reports on use of our website, and to improve our website and marketing. To find out more about the use of cookies and adjust your cookie preferences, please see our cookie policy here.

The following data may be collected:

  • Number of visitors to our website.
  • Pages visited while at the website and time spent per page.
  • Page interaction information, such as scrolling, clicks, and browsing methods.
  • Websites where visitors have come from and where they go afterwards.
  • Page response times and any download errors. and
  • Other technical information relating to end user device, such as IP address or browser plug-in.

Revapt Database:

Revapt gathers current and historic business contact data. Revapt collects business contact and similar information related to individuals when they are acting in their professional or employment capacity. Revapt then uses this information to create professional profiles of individuals and profiles of businesses. We provide this information to our clients, who are businesses trying to reach business professionals for their own business-to-business sales, marketing, and recruiting activities. The data collected about individuals on the Revapt Database comprises:

  • Name.
  • Employer Company & Company Details (including alias).
  • Office Location (including City).
  • Business Telephone Number.
  • Business Email Address.
  • Job Title.
  • LinkedIn URL.

We also hold data in respect of your employer company such as its name, alias, size, industry, website, and industry. Where you have moved jobs, we may hold your previous employers and previous titles.

In order to provide certain aspects of its services, Revapt requires a business email address to be recorded against profiles in its database. The majority of the personal data we collect about you comes from publicly available sources such as from business and employment-oriented social networks, recruitment websites, and company websites. Information is also gathered from correspondence with you (by email or phone), from our clients, recruiters, and licensed from other premium data providers. Revapt does not seek to collect any non-business-related data for the Revapt Database such as date of birth, home address, personal email, or home telephone number, and Revapt does not collect sensitive personal data.

Anyone added to the Revapt database may request to be removed at any time, via email or web. We will fulfil such requests as promptly as we can, and in any event within any time period that may be required by applicable law.


2. Controller and Processor


2.1 When Revapt is a Controller

Revapt acts as a data controller when we collect and use information about data subjects who are visitors to our website and client platform, as well as when we collect and use information about data subjects for purposes of creating and maintaining our database, client platform, and providing the services.

2.2 When Revapt is a Processor

When our clients use our services, they are acting as the data controller and are responsible for ensuring that personal information collected about data subjects is being processed lawfully. In those circumstances, we are acting as the data processor and receive personal information as agents of our clients merely for processing as instructed by our clients. Our clients are solely responsible for determining whether and how they wish to use our services, and for ensuring that all third-party individuals that are a visitor to or user of a website, application, or service on which a client uses our services have been provided with adequate notice regarding the processing of their personal information, have given informed consent where such consent is necessary or advised, and that all legal requirements applicable to the collection, use, or other processing of personal information through our services have been met by such clients. Our clients are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the services. Revapt’s obligations with respect to personal information for which we are solely a data processor are defined in our agreements with our clients and are not covered by this Policy.


3. Grounds of Processing


3.1 Consent

On some occasions, Revapt processes your data with your consent. Your consent may be obtained by third parties on Revapt’s behalf. You have the right to withdraw such consent at any time, and we will cease to process your data after consent is withdrawn.

3.2 Legitimate Interest

Revapt processes your personal data when it is in our clients’ legitimate interest to do so and when these interests are not overridden by your rights. Our and our clients’ legitimate interests include: having information about potential business customers organised in one searchable database, having access to up-to-date and complete information, being able to identify the individual that occupies a certain role within a B2B lead; enabling clients to only reach out to relevant contacts, being able to generate and contact potential B2B leads in order to undertake forms of B2B marketing, having access to aggregated statistical insights for the purpose of understanding patterns and trends.

3.3 Necessary because of a Legal Obligation

Revapt may process your data to comply with our legal and regulatory obligations, e.g., preventing, investigating, and detecting crime, fraud, or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.

3.4 Necessary to Fulfil an Obligation under a Contract

Revapt may process your data where we have a contract with the individual, and we need to process their personal data to comply with our obligations under the contract.


4. Data Sharing


We will share your information with the following:

4.1 Our Companies

Access to personal data within Revapt and our group of companies is restricted to those individuals who have a need to access the information for our business purposes.

4.2 Revapt Clients

We may share personal data with our clients or their customers as part of the offering of our services. Revapt provides limited access to its database. Revapt clients or their customers may use the data to contact individuals on their business telephone, at their business email address, through other electronic mail, or through targeted display ads on social networks in order to market products and/or services. Business Data from Revapt may be disclosed to a client’s CRM or sales enablement software as requested or directed by our clients.

By remaining in our database, you may be contacted by our clients when they are conducting their business-to-business sales, marketing, and recruiting activities. Communications you receive from our clients may be relevant to your profession or employment role, but we cannot guarantee that you will find such communications to be relevant or of interest to you.

Please note that in making available the data to its clients, Revapt is at times processing such data as a processor on behalf of the client, who is acting as the controller. Clients will act as controllers and have their own privacy policies and opt-out options, and we recommend you review them. Where Revapt has made personal data available to its clients, the client privacy policy should list Revapt as a data source.

4.3 Suppliers, Subcontractors, Service Providers

We keep your information confidential but may disclose it to suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy. However, this is on the basis that they have agreed to safeguard this information.

This includes external third-party service providers, such as accountants, auditors, experts, lawyers, and other outside professional advisors; IT systems, support, and hosting service providers; technical engineers; data storage and cloud providers; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

4.4 Government Authorities

In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention).

4.5 Potential Acquirers or Investors

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message, and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.


5. How we will use information we collect about you


Revapt Website and Revapt Client Platform:

We may process your personal data for the following purposes:

  • To administer platform log-ins (where applicable) and to deliver our services to our clients or their customers under the agreed terms of service.
  • To process your enquiries to reply and provide support, including providing you and/or your organisation with information about the services Revapt offers.
  • To consider persons for possible employment with Revapt and communicate about employment opportunities or submitted employment applications.
  • To keep you updated via our mailing list with information on news, offers, and updates about Revapt (see below for how to unsubscribe).
  • To send technical notices, updates, security alerts, and support and administrative messages.
  • To facilitate contests, sweepstakes, and promotions, process entries, and deliver rewards.
  • To provide and maintain the website and to compile reports on how visitors use the Revapt website and improve the website.
  • To conduct remarketing for Revapt, which allows us to show Revapt ads to people who’ve previously visited our website.
  • To conduct advertising on social networks for Revapt, which means that if you link to one of our social media platforms, you may be subject to targeted marketing displaying Revapt ads via that site.

We work with third-party advertising networks and social media platforms as set out in our cookie policy here. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.

Revapt Database:

We may use your personal data on the Revapt Database for the following purposes:

  • To provide, maintain, and build our sales intelligence database to enable our clients or their customers to generate and manage sales leads in respect of businesses.
  • To deliver, maintain, and improve our services.
  • To enable our clients or their customers to serve relevant display ads on social networks (such as Facebook, LinkedIn, and Instagram) and other services.
  • To verify, cleanse, update, and maintain information provided through our services.
  • To enable our clients or their customers to enrich their existing customer relationship management records and receive timely updates of changes.
  • To undertake research and compile statistical aggregated reports based on data held in Revapt’s sales intelligence database (which may include inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or clients may use to provide and improve our respective services.
  • To run our own marketing campaigns and promote our services.

General:

We also process personal data to comply with our necessary legal and regulatory obligations. These include preventing, investigating, and detecting crime, fraud, or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies, protecting the rights and property of Revapt and our clients, and responding to rights requests under applicable law.

If you send us objectionable content or otherwise behave in a disruptive manner when using our website, we may process personal data included in your messages to respond to and stop such behaviour. Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

7. Marketing Opt-Out Options

If you’d like to permanently erase your data from the Revapt Database, please complete this form. Please note that we need the information included in this form to be able to locate you in our database and action your request. The information provided will only be used to process and action your request. Your request will be processed in the shortest time possible and within the timeframes set forth in GDPR.

Where you receive a marketing email from us, and you would like to be removed from that mailing list, please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.


8. Your Rights in Relation to Personal Data Which We Process Relating to You


You have the following rights over the way we process personal data relating to you. After receiving a request to exercise any of your rights, we aim to comply without undue delay, and within one month at the latest.

To make a request, please contact us using the above contact details, addressed to the Data Protection Officer.

8.1 Right to Access and Correct

You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. We will use reasonable efforts to the extent required by applicable law to supply, correct, or delete personal data held about you on our files (and with any third parties to whom it has been disclosed).

8.2 Object to Processing

You can ask us to restrict, stop processing, or to delete your personal data if:

  • you consented to Revapt processing the personal data, and have withdrawn that consent;
  • Revapt no longer needs to process that personal data for the reason it was collected;
  • Revapt is processing that personal data because it is in the public interest or in order to pursue a legitimate interest of Revapt, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
  • the personal data was unlawfully processed; or
  • you need the personal data to be deleted in order to comply with a legal obligation.

8.3 Data Portability

If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy, or transfer your personal data to other IT systems. If you request, Revapt will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

8.4 Make a Complaint

If you are unhappy with the way Revapt is processing your personal data, please let us know. If you do not agree with the way we have processed your data or responded to your concerns, or if you do not think we are handling your personal data adequately, you have the right to lodge a complaint with your local supervisory authority. The supervisory authority for Revapt Limited is the Nigeria Data Protection Commission. Further information, including contact details, are available at https://www.ndpc.gov.ng/.


9. Data Retention


We will hold your personal data for as long as is necessary for the relevant purpose. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


10. Children


We do not knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files within a reasonable time.


11. Security


Revapt is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure, or destruction of information that we hold. We will take all reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal data.

Our security measures include:

  • Hashing and encryption of our services and data;
  • Regular review of information collection;
  • Encryption of our services and data;
  • Restricted access of data to employees, contractors, and agents on a need-to-know basis; and
  • Internal policies setting out our data security practices.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.


12. Changes


We will notify you of any changes to this Privacy Policy by email and/or notice on the website, as appropriate.