Privacy Policy

INTRODUCTION 

Sea-Faj Consults values your privacy and is committed to protecting and 

respecting your personal information and rights. We have taken all required 

organizational and technical measures to secure the confidentiality and integrity 

of your personal data and have also adhere to statutory data protection and 

privacy requirements. 

Here is is a summary of how we protect your privacy: 

▪ We  only collect what we need to help you with your request or provide 

you with information that you ask for, personalising it to your interests. 

▪ We won’t hang on to your information. If we don’t need it, and you don’t 

want us to keep it, we’ll delete it. 

▪ We want you to understand everything we do with your information, so 

we’ll try our best to explain. 

▪ No surprises, you decide what and how you hear from us. 

The rest of this privacy policy provides more details of our privacy practices. 

  1. WHO WE ARE 

Sea-Faj Consults (We, us, our) is a firm that offers international Student 

Recruitment services, outsourcing services and business consultancy. Sea-Faj 

Consults is the controller of your personal data, it determines the purposes and 

means of processing your personal data as provided in this privacy policy 

(hereinafter referred to as the policy). 

  1. PURPOSE OF THE POLICY 

This Privacy Policy gives a comprehensive detail of how we collect, process, 

store, share, transfer, protect and delete your personal data and sensitive 

information when you visit our website, Social Networks or use our services. 

You acknowledge that you have read, understood and agreed to the practices 

described in this policy. For the purpose of this policy, 

Personal data or data/information, means any information relating to an 

identifiable natural person(data subject, you, yours). An identifiable natural 

person is a person who can be identified directly or indirectly.  

Processing means any set of operation which is performed on a set of personal 

data. 

  1. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS 

We may collect, process, store and share different kind of your personal data 

such as: 

  1. Personal Information 

When you contact us, sign up for services, use our Social media platforms, or 

submit inquiries, we may collect personal details such as: 

  • Full legal name(including any aliases used) 
  • Date of birth, gender, marital status 
  • Email address, mobile and landline telephone number 
  • Mailing address and residential address including postal codes and 

province  

  • Government-issued identity documents including passport, national IDs, 

Drivers Licences 

  • Visa Application data, employment related data, profile data 
  • Country of residence, nationality, preferred study destination, when you 

intend to study and how you intend to fund your studies.  

  • Educational qualifications and employment status and history, occupation 
  • Visual identification such as photographs, facial scans, video KYC Calls 
  • We may also request sensitive information about such as racial or ethnic 

origin (from your information on your country of origin) and/or your 

health or medical information. 

  1. Non-Personal Information 

We may also gather non-personal information automatically, including: 

  • IP address logs (including time zone and location metadata) 
  • Passwords and security question answers 
  • Detail of transactions carried out through our website and platforms 
  • Device identifiers,Browser type and version 
  • Pages visited, time spent on the site click patterns, navigation paths 
  • Source of traffic 
  • Cookies and usage data 
  • Error logs, crash reports and system diagnostics  
  • Your consent, any permission or preference given to Sea-Faj Consults 
  • Marketing and communications data such as details about you from 

emails, and conversations, chats between us and you and social media, 

your preference in receiving marketing messages from us and any third 

party companies on our behalf. 

  1. Communication Records 

▪ Support chats (live or bot-assisted) 

▪ Support emails 

▪ Recorded phone conversations for compliance and quality assurance 

▪ In app support interactions and alerts  

▪ Voice messages and voice mail correspondence  

▪ Feedbacks, complaints, satisfaction surveys and audit trails of response. 

Our services are not directed to individuals under the age of 18. We do not 

knowingly collect personal information from children. 

  1. HOW WE COLLECT YOUR PERSONAL DATA  

We collect your data you provide through the following avenues: 

  1. Directly from you 

▪ When you visit  our website, social media and use our 

services 

▪ Sign up to our newsletter   

▪ Participation in our webinars and programs 

▪ Apply for jobs through our platforms  

▪ register for, attend and/or otherwise take part in our 

events (e.g. at career fairs, school fairs) 

▪ Click our links 

▪ Submission of CV, Resume 

▪ Through voluntary submissions like surveys or feedback 

forms 

▪ Fill out forms for  our services 

▪ Conversations with a member of our customer service teams 

by phone, social media platforms, emails and chat box 

▪ Contact us for any reason 

  1. Automatically via platform use 
  • Cookies and tracking pixels installed on your browser 
  • Server logs and analytics tools embedded within dashboards 
  • Navigation behavior  
  1. From Third-party Sources 
  • Know your Customers service providers 
  • Affiliate and referral tracking systems 
  • Regulatory watchlists 
  • Public records, corporate registries and data vendors. 
  1. OUR LEGAL BASES FOR PROCESSING YOUR DATA 

Depending on the type of personal data in question and the grounds on 

which we are processing it, should you decline to provide us with such 

data or ask us to stop processing it, we may not be able to fulfil our 

contractual requirements or, in extreme cases, may not be able to 

continue with our relationship or may have to bring that relationship to a 

close (i.e. because we cannot continue it without personal data about 

you). 

Legitimate Interest 

In the course of providing work-finding services to our clients and work-seekers, 

where SEA-FAJ Consults acts as a Data Controller, it will be necessary, and in 

our legitimate interest to process personal data, as defined by the NDPA 2023, 

The NDPA General Application and Implementation Directive (“GAID”) 2025 

DPA 2018, and the GDPR 2018. 

We will process contact data as part of the Refer a Friend schemes on the 

grounds of legitimate interests. This is where referrals are made on behalf of 

people who needs our services by members of their social group. Each referral 

is processed on the basis that there is a legitimate interest in us helping to find 

work for the referred individual. 

Establishing, Exercising or Defending Legal claims 

Sometimes it will be necessary for us to process personal data and, where 

appropriate and in accordance with our legal obligations and regulatory 

requirements, sensitive personal data in connection withexercising or defending 

legal claims. 

The relevant data laws and regulations allows this where the processing “is 

necessary for the establishment, exercise or defence of legal claims or 

whenever courts are acting in their judicial capacity”. 

This will arise for example where we need to take legal advice in relation to 

legal proceedings or are required by law to preserve or disclose certain 

information as part of the legal process. 

To Exercise our Rights or Carry out our Employment and Social 

Security Legal Obligations 

For some clients, Temporary Workers and individuals it will sometimes be 

necessary for us to process your sensitive/special category personal data, for 

the purpose of ensuring compliance with our legal obligations and regulatory 

requirements. 

For example, we may process your medical data to enable us to provide you 

with adequate support if you suffer from a health condition or disability, for 

example by sharing medical information about you with an occupational health 

specialist, in order to determine prognosis and return to work arrangements, 

and to assess your working capacity more generally. 

The relevant data laws allows us to do this where the processing is “necessary 

for the purposes of carrying out the obligations and exercising [our or your] 

specific rights… in the field of employment and social security and social 

protection law”, as long as this is allowed by law. 

Where processing your personal data is necessary for us to carry out our 

obligations under our Contract with you, to ensure that you are properly 

fulfilling your obligations to us, and to ensure that we are fulfilling our 

obligations to others. 

The relevant data laws and regulations applies where processing of personal 

data “is necessary for the performance of a contract to which [you are] party 

or in order to take steps at [your] request … prior to entering into a contract”. 

Where processing your personal data is necessary for us to carry out 

our Legal Obligations 

In relation to the employment or engagement of Temporary Workers directly 

by us, as well as our obligations to you under our contract, we also have other 

legal obligations that we need to comply with.  

An example of a legal obligation that we need to comply with is our obligation 

to co-operate with tax authorities. 

Electronic marketing 

Where we send unsolicited electronic marketing to you we may also require 

either an opt-in consent or opt-out consent.That means we are permitted to 

market products or services to you which are related to the recruitment services 

we provide to you as long as you do not actively opt-out from these 

communications. 

Consent 

In certain circumstances, we are required to obtain your consent to the 

processing of your personal data in relation to certain activities. Depending on 

exactly what we are doing with your information, this consent will be opt-in 

consent, or soft opt-in consent. 

You have the right to withdraw your consent to these activities. You can do so 

at any time by contacting info@sea-fajconsults.com 

  1. HOW WE USE YOUR PERSONAL DATA 

The information we collect is used to: 

  • Provide, operate, and maintain our website and services. 
  • Respond to inquiries or customer service requests. 
  • Understand your needs and preferences by communicating through our 

chat box, conducting brief surveys on our website 

  • Send periodic updates or newsletters (if subscribed). 
  • Verify contact information and identity 
  • Marketing and promotional purposes  
  • Improve our website’s functionality and user experience. 
  • Ensure compliance with legal and regulatory requirements. 
  • In appropriate circumstances we may also use candidates data in 

psychometric assessments  

  • We will use or disclose your information for another purpose outside the 

purpose the data is collected for, only if you have consented, or if you 

would reasonably expect us to do so or as required by law. 

  1. WHO WE SHARE YOUR DATA WITH AND IN WHAT CIRCUMSTANCES

We may disclose your personal information to our partners for the purposes of 

delivering our services to you and to help run our business. Such as Service 

Providers, assisting us with website operations or email communication. 

Where you use our services such as outsourcing services, International student 

Recruitment services, business consultancy, apply for a job through us,  we 

may disclose your personal information to overseas recipients such as educational institutions located outside your home country, overseas visa  agencies, IELTS test centers, professional bodies and commercial organizations 

our clients, and regulatory authorities, recruitment agencies , when you have 

sought out assistance to apply for study at those institutions or where disclosure 

is required for verification purposes. As such, the location of these overseas 

recipients would depend on the specific institutions to which you apply or where 

such verification is required. For events or conferences, we may disclose, with 

your consent, some of the information that is collected via the online 

registration form such as your name or your email to sponsors for marketing 

purposes. 

We may hold or transfer the data we collect in or to the following countries (in 

addition to your home country: UK, US, Canada, Australia and others. Your 

personal data is stored and accessed only as required to provide or services to 

you. Where we transfer your data to third parties, we maintain the 

confidentiality and security of the information being transferred. The data 

disclosed to overseas recipients consists of any information you have given us 

to provide the relevant services. By accepting services from us, you consent to 

us proving your personal information to the relevant overseas recipient as 

mentioned above. We take appropriate steps to ensure there are adequate 

safeguards in place for the transfer of your personal data. 

We reserve the right to provide your personal data to third parties if required 

by law and regulatory  Authorities. 

We share your data with providers of web analytics services, marketing 

automation platforms and social media services to make sure any advertising 

you receive from us is targeted to you. 

When you use our outsourcing services, apply for a job through us, we may 

disclose your data to our clients, overseas reciepents  

  1. HOW WE STORE AND TRANSFER YOUR PERSONAL DATA AND 

HOW LONG 

We will store process your personal data as long as we have a business 

relationship with you in a secured computer storage facilities and paper based 

files and other records. We take the necessary measures to protect the personal 

data we hold about you from misuse, loss, unauthorized access, modification 

or disclosure. 

If you instruct us to cease using or processing your personal data, we have the 

right to terminate any existing services to you within a reasonable time or 

immediately, as determined by the Company. 

When we consider that personal data is no longer needed for the purpose for 

which it was collected, we may remove any details that may identify you or we 

may securely destroy the records. However, we may need to maintain records 

for a significant period of time (after you cease to be our client) subject to 

certain laws that require us to retain a copy of the documents we used in order 

to comply with our customer due diligence obligations as well as supporting 

evidence and records of transactions with you and your relationship with us. 

For the personal data held in the form of an email, telephone, electronic, in 

person or otherwise recorded communication, the information will be retained 

in line with the requirements of our Regulatory Authority. 

If you have opted out of receiving marketing communications we will hold your 

details on our suppression list so that we know you do not want to receive these 

communications. 

We may keep your data for a longer time than the retention period if for legal, 

regulatory or technical reasons we cannot delete it. 

In order to provide you with the best service and to carry out the purposes 

described in this Privacy Policy; your data will be transferred: 

  • between and within SEA-FAJ  Consults entities globally; 
  • to third parties (such as advisers or other Suppliers to the SEA-FAJ 

Consults business); 

  • to overseas Clients where applicable; 
  • to Clients within your country, where applicable, who may, in turn, 

transfer your data internationally; 

  • to a cloud-based storage 

We want to make sure that your data are stored and transferred in a way which 

is secure. We will therefore only transfer data outside of Nigeria UK, European 

Economic Area (EEA)  where it is compliant with data protection legislation and 

the means of transfer provides adequate safeguards in relation to your data, 

for example: 

  • by way of data transfer agreement, for the transfer of personal 

data by to jurisdictions without adequate data protection laws; or 

  • transferring your data to a country where there has been a finding 

of adequacy  in respect of that country’s levels of data protection via 

its legislation; or 

  • where it is necessary for the conclusion or performance of a 

contract between ourselves and a third party and the transfer is in 

your interests for the purposes of that contract  

  • where you have consented to the data transfer. 

To ensure that your personal information receives an adequate level of 

protection, we have put in place appropriate procedures with the third parties 

we share your personal data with to ensure that your personal information is 

treated by those third parties in a way that is consistent with, and which 

respects the law on data protection. 

We remain devoted to handling your data in an ethical manner, including: 

  • Mandating by contract that all sub-processors adhere to data 

protection legislation requirements; 

  • Ensuring that any data transfers are encrypted in transit; 
  • Storing your data on encrypted servers and networks; 
  • Undergoing yearly security audits; 

We will continue to monitor guidance from authorities and stay closely aligned 

with these developments including adjusting our practices accordingly. 

  1. DATA SECURITY AND PROTECTION 

We implement appropriate technical and organizational measures to protect 

your information against unauthorized access, alteration, disclosure, or 

destruction. However, no method of transmission over the Internet is 100% 

secure. We have put in place procedures to deal with any suspected data 

security breach and will notify you and applicable regulatory agencies of a 

suspected breach where we are legally required to do so. 

If you suspect any misuse or loss of or unauthorised access to your personal 

information, please let us know immediately by emailing info@sea-fajconsults.com 

Data Security is of great importance to SEA-FAJ Consults  and to protect your data we 

have put in place suitable physical, electronic and managerial procedures to safeguard 

and secure your collected data. We take security measures to protect your 

information including: 

  • Limiting access to our buildings to those that we believe are 

entitled to be there by use of passes; 

  • Implementing access controls to our information technology; 
  • We use appropriate procedures and technical security measures 

(including strict encryption, anonymization and archiving techniques) 

to safeguard your information across all our computer systems and 

websites 

  1. USE OF COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance your experience. Cookies 

help us understand how you interact with our website and improve its 

functionality. You can manage your cookie preferences in your browser settings. 

  1. YOUR RIGHTS AS A DATA SUBJECT

You have the following rights regarding your personal data: 

  • Right to Access: Request a copy of the information we hold about you. 
  • Right to Correction: Request corrections to inaccurate data. 
  • Right to Deletion: Request the deletion of your data (subject to legal 

obligations). 

  • Right to Withdrawal of Consent: Withdraw consent to data processing 

where applicable. 

  • Right to restrict processing 
  • Right to rectification 
  • Right of data portability 
  • Right to lodge complaint with a supervisory authority  

To exercise these rights, please contact us at info@sea-fajconsults.com. 

  1. THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible 

for the privacy practices or content of these external sites. We recommend 

reviewing their privacy policies before providing any personal information. 

  1.  

CHANGES TO THIS PRIVACY POLICY  

We review and update our Privacy Policy periodically. We encourage that you 

check this page for the updated version of our privacy policy. 

CONTACT US 

If you have questions or concerns about this Privacy Policy, please contact 

us: 

Sea-Faj Consults