HOGAN ORGANIZATION (HOGAN, We, Our), we understand the importance of privacy, with particular reference to information or personal Data / Information shared by Data / Information Subjects (you, your) and we continually strive to ensure the protection of Data / Information collected at the highest level and the extent permissible by all relevant laws.

This policy constitutes our intention and commitment to ensuring your privacy when using our website, social media or digital platform, applications, newsletter, services, content, technologies, blog and within our premises (Hogan Tools). It details the policy guiding the collection, use, storage, processing, destruction and disclosure of Personal Data / Information of Data / Information Subjects.

It is pertinent to note that for the purpose of this policy, HOGAN is the Data / Information controller. Also, this policy is given and bound by the provision of the Nigeria Data / Information Protection Regulation 2019.


This policy describes your privacy rights, with regards to personal Data / Information collection, use, storage, sharing/ transfer, processing and protection. It also highlights the measures taken to protect Data / Information collected through various means and platforms. Sincerely

As a Data / Information Subject of Hogan tools, you have the following rights, which may be exercised by contacting

  1. The right to request the production / obtain personal Data / Information collected.
  2. The right to restrict the processing of Data / Information
  3. The right to withdraw consent i.e. request that Data / Information or information held be destroyed and that there be a seizure in the collection of Data / Information. The withdrawal of consent shall not affect the lawfulness of processing before the withdrawal.
  4. The right to opt-out of marketing communications, newsletters and other subscriptions.


You accept this policy and give consent to HOGAN to obtain and process personal Data / Information upon access to the Hogan tools, either for enquires, official or non-official purposes.

This policy may be amended from time to time and all HOGAN tool Data / Information Subjects shall be notified by the posting and pasting of the revised version in a conspicuous way and place.

The Hogan tool may contain links or references to other websites and resources but HOGAN shall not be responsible for the privacy practices of such entity, security of transactions or interactions. Data / Information Subjects are therefore required to thoroughly peruse the privacy policy of such links and ensure it is understood, before sharing information or consenting to Data / Information collection. Therefore, incidents arising from the use of such websites or resources shall be wholly borne by the Data / Information Subject.

Also, we may collect and use Data / Information provided by third parties like social media/ digital platforms, search engines etc. and the security/protection of information so released and collected shall not be within the purview of HOGAN’s control. HOGAN shall therefore not be responsible for the collection, use or processing.


We obtain Data / Information from your computer, mobile device and other electronic access devices through the following ways:

  1. By request: this includes information obtained directly from the Data / Information Subject. This includes; name, phone number, email address, sex and other information requested by HOGAN and supplied by the Data / Information Subject pursuant to an enquire, request, subscription or general use of Hogan tools.
  2. By use: this is Data / Information obtained indirectly and automatically by accessing Hogan tools. This includes Internet Process (IP) address, time of access, domain name, browser type, device type etc.

Personal Data / Information: While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data / Information”) and this includes name, email address, phone number, date of birth etc. it also includes information contained in Curriculum Vitae.

Location Data / Information: If location detection services have been enabled on your computer, mobile device or other electronic device used in accessing the Hogan tool, we may collect details on your location to enable the rendering of more efficient services to you. If you do not want us to collect location Data / Information, please deactivate the location detection service.

Log information: this information is collected automatically, gathered and stored by most websites. This information includes IP addresses, internet service provider (ISP), operating system, date/ time stamp, exit pages, device ID, model and manufacturer etc.

Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device’s camera, calendar, BlueTooth, contacts, storage and other features. If you wish to change our access or permissions, you may do so in your device’s setting.

Cookies Data / Information: These are small pieces of information (text files) sent from the website (Hogan tool) to the Data / Information Subjects device and stored on the hard drive. These files are used to ensure Data / Information Subject satisfaction and a more efficient experience while using the tool. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may be unable to use or access some portions of Hogan tools or our services.


Generally, the information collected from Data / Information Subjects is to enable us to provide a seamless and easy experience while using Hogan tools, to ensure requests are responded to timeously and transactions processed appropriately. The usage of Data / Information may be extended whenever required, to meet legal, regulatory, statutory, contractual or judicial obligations and other legitimate business concerns. Use of Data / Information may include but is not limited to the following:

  1. To provide access to Hogan tools, platforms and services
  2. To receive newsletters and other marketing or business subscriptions.
  3. To detect, prevent and address technical issues
  4. To provide and maintain our services
  5. To notify you about changes to our service
  6. To process enquiries, queries and transactions
  7. Verify the identity of the Data / Information Subject (including age and if such is human)
  8. Resolve disputes and complaints about services
  9. Request, collect and confirm accruable fees and other relevant payments
  10. To deliver targeted adverts to you on our services.


Hogan Organization will take all steps reasonably necessary to ensure that your Data / Information is protected and treated in a secure manner. Thus, we do not disclose or share Data / Information provided to us by Data / Information Subjects of Hogan tools, unless it is absolutely necessary or as described in this privacy policy. Where it becomes absolutely necessary to share your Data / Information, adequate security measures will be taken to ensure the protection of the Data / Information so shared and that access is only granted to the intended recipients. All Data / Information collected shall reside and be stored in Hogan Organization computer and storage systems in Nigeria. Where cloud services are used for storage, all security and governance measures that apply to the use of such cloud services will be complied with. Disclosure may occur for the following reasons but is not limited to:

  1. To fulfil the purpose for which you provide the information and for another other reason disclosed by us when we request for the information and you provide same.
  2. The fulfilment of legal, regulatory, statutory, contractual or judicial proceedings/ obligations, governmental requests and other legitimate business concerns.
  3. Sharing with our Holding Company, Hogan group, subsidiaries within the Hogan Group, affiliate companies, associates, and other related organisations/ persons.
  4. Service providers, vendors and other related organisations/ persons. This also includes mergers and acquisitions.
  5. Where the Data / Information Subject or owner of the Data / Information consents to the Data / Information being shared with a third party.
  6. Third-party service providers to provide services we offer, provide technical support/ repairs and other services.
  7. To protect and defend the right or property of the Hogan Organization.
  8. We may disclose Data / Information where it becomes necessary to investigate, prevent, or take action (defend or prosecute) issues relating to the violation or potential violations of our policies, suspected fraud, misrepresentations (including ascertaining the age of a Data / Information Subject of Hogan tools), situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  9. Where Hogan Organization, its subsidiaries, affiliates Group Company or holding company is undergoing negotiations, merger, sale of company assets, financing or acquisition of all or a portion of our business to another, including the purchase of other business enterprises by Hogan Organization and affiliates6 referenced in Paragraph C above.
  10. With the consent of the Data / Information subject, Data / Information/ personal information may be shared for other purposes.

Transfer of Personal Data / Information to a Foreign Country

  1. Hogan Organization shall ensure that National Information Technology Development Agency (NITDA) has ascertained whether the foreign country, territory or international organisation falls within those with adequate Data / Information protection and this shall be guided by the Nigeria Data / Information Protection Regulation, 2019 (NDPR);
  2. The Data / Information subject has consented to the transfer;
  3. The transfer is in the performance of a contract between the Data / Information subject and the Hogan Organization;
  4. The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the Data / Information subject between Hogangaurds and another natural or legal person;
  5. The transfer is necessary for important reasons of public interest;
  6. The transfer is necessary for the establishment, exercise or defence of legal claims;
  7. The transfer is necessary in order to protect the vital interests of the Data / Information Subjects or other persons, where the Data / Information Subject is physically or legally incapable of giving consent.

Provided, in all circumstances, that the Data Subject has been manifestly made to understand through clear warnings of the specific principle(s) of Data / Information protection that is likely to be violated in the event of transfer to a third country, this proviso shall not apply to any instance where the Data / Information Subject is answerable in duly established legal action for any civil or criminal claim in a third country.

The Bank will take all necessary steps to ensure that the Personal Data / Information is transferred through a safe and secure means. Upon request by the Data Subject, details of the protection given to your Data/ information when been transferred outside Nigeria or to an international organisation shall be provided. Where the recipient country is not on the White List of the National Information Technology Development Agency (NITDA) on the availability of sufficient data protection laws and none of the conditions stipulated in this Privacy Policy are met, Hogan Organization shall communicate with NITDA and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer, in accordance with by the Nigeria Data / Information Protection Regulation, 2019.


The security of your Data / Information is important to us. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment.


The Bank collects Personal Data / Information only for the purposes and reasons stated in this privacy policy and other relevant policies and for which consent has been sought and obtained. Information so gathered cannot be utilised for other purposes unconnected or incompatible with the original purpose, except consent to so use is obtained.


All Data/ Personal information collected shall be retained, stored, deleted and destroyed by Hogan Organization in line with statutory, legislative and regulatory requirements.

The length of storage of personal Data/ Information obtained by HOGAN, shall to the extent permissible under the governing laws and HOGAN’s policy on document retention be determined by:

(a) the terms of the contract between HOGAN and the Data Subject or for as long as is needed for the purpose for which it was obtained;

(b) whether the transaction, contract or relationship between the parties has statutory implication or a statutory retention period; or

(c) whether there is an express request for the destruction/ deletion of Personal Data / Information collected by the Data / Information Subject, provided that such request will only be treated where the Data / Information Subject is not under any investigation, legal or judicial obligation, which may require the retention or production of such Personal Data / Information or there is no subsisting contractual or pre-contractual arrangement with the Data / Information Subject that would require the further processing of the Personal Data / Information; or

(d) whether HOGAN has a lawful or legitimate basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

In line with NDPR, HOGAN shall be entitled to retain, store and process Personal Data / Information collected for the purpose of archiving, scientific research, historical research or statistical purposes for the public interest.

HOGAN shall destroy/ delete Personal Data / Information in her possession where it is no longer required by HOGAN or in line with HOGAN’s Document Retention Policy, provided HOGAN is not required by law or regulation to retain or further process such Personal Data / Information.


We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). Upon cessation of a contract between the Data Subject and Hogan Organization, the contract file shall be closed but will not include the deletion and destruction of information already gathered for reasons contained in this policy. However, unless required by law, law enforcement agents, regulators, statute, defence of the right and property of Hogan Organization, recovery of accrued funds and other related matters, we shall stop the further processing of Data/ Information already gathered, from the time of cessation of contract.


For questions, comments and enquires on this policy, our compliance data protection officer may be contacted by email: or by post: The Data Protection Officer, Block 1 Plot 8 Aduke birogba Industrial Avenue, Km 5 Lagos- Ibadan Expressway, Riverview Estate, Isheri, Ogun State.