Privacy Policy

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1. Introduction and Corporate Commitment

Dexlapro, including its subsidiaries and affiliates (collectively, “the Company”), operates as a diversified industrial conglomerate. In the course of our global operations—spanning energy, infrastructure, manufacturing, and logistics—we process significant volumes of data.

We are committed to the principles of transparency, data minimization, and purpose limitation. This Policy is designed to comply with the General Data Protection Regulation (GDPR), the Nigerian Data Protection Act (NDPA), and the Ley Federal de Protección de Datos Personales (LFPDPPP), reflecting our dual-market heritage and international reach.

2. Definitions

  • Data Subject: Any identifiable natural person whose personal data is processed by Dexlapro.

  • Personal Data: Any information relating to an identified or identifiable natural person.

  • Processing: Any operation performed on personal data, such as collection, recording, storage, or erasure.

  • Industrial Data: Technical, non-personal data generated by machinery, sensors, or logistics systems, which may be governed by specific confidentiality agreements.

3. Categories of Data Collected

3.1. Business and Contact Information

We collect names, professional titles, business addresses, email addresses, and phone numbers of our clients, vendors, and partners to facilitate contract execution and operational communication.

3.2. Operational and Safety Data

Due to the high-risk nature of our industrial sites (offshore platforms, chemical plants, and construction zones), we collect:

  • Biometric Data: Fingerprints or facial recognition for secure facility access (where permitted by law).

  • Geolocation Data: Real-time tracking of personnel and assets within hazardous zones for emergency response and safety coordination.

  • Medical Information: Limited to fitness-for-duty certifications and emergency contact details for personnel working in remote or offshore environments.

3.3. Financial and Transactional Data

Tax ID numbers, bank account details, credit history (for vendors), and records of services rendered or goods purchased to ensure compliance with international anti-money laundering (AML) and “Know Your Vendor” (KYV) regulations.

4. Legal Basis for Processing

Dexlapro processes data under the following legal frameworks:

  • Contractual Necessity: Processing required to fulfill our obligations under service agreements, employment contracts, or supply chain mandates.

  • Legal Obligation: Processing required to comply with maritime, energy, and labor laws.

  • Legitimate Interests: Processing necessary for corporate security, internal auditing, and the improvement of industrial safety protocols.

  • Consent: Where we specifically ask for your permission for activities such as marketing or specific biometric registrations.

5. Data Retention Standards

Dexlapro adheres to a strict retention schedule. Personal data is kept only as long as necessary for the purposes for which it was collected:

  • Project Records: Retained for 10 years post-completion to satisfy engineering warranty and liability requirements.

  • Employee Records: Retained for the duration of employment plus 7 years, unless local labor laws dictate otherwise.

  • Visitor Logs: Retained for 1 year for security audit purposes.

6. Data Security and Technical Safeguards

Given our “modus operandi” involves critical infrastructure, our security measures are of military-grade standard:

  • Encryption: AES-256 encryption for all data at rest and TLS 1.3 for data in transit.

  • Air-Gapping: Critical industrial control systems (ICS) are isolated from public internet access to prevent cyber-espionage.

  • Access Control: Implementation of the “Principle of Least Privilege” (PoLP) across all corporate databases.

7. International Data Transfers

Dexlapro operates across multiple jurisdictions. Data may be transferred between our Nigerian headquarters, Mexican operational hubs, and international cloud servers. We utilize Standard Contractual Clauses (SCCs) and Binding Corporate Rules (BCRs) to ensure that your data receives the same level of protection regardless of its geographical location.

8. Rights of the Data Subject

You have the following rights regarding your data:

  • Right to Access: Request a copy of the data we hold about you.

  • Right to Rectification: Request correction of inaccurate information.

  • Right to Erasure: The “Right to be Forgotten,” subject to legal retention obligations.

  • Right to Portability: Request your data in a structured, machine-readable format.

  • Right to Object: Object to processing based on legitimate interests.

9. Contact and Grievance Redressal

For any inquiries regarding this Policy or to exercise your data rights, please contact the Dexlapro Data Protection Office (DPO):

  • Email: privacy@dexlapro.com

  • Address: Data Protection Department, Dexlapro Corporate Tower.