Privacy Notice for Website - Nigeria

Effective Date: June 1, 2021

Privacy notice for website (in accordance with Section 2.5 of the Nigerian Data Protection Regulation)
This privacy notice explains how Vertiv Group Corporation (“Vertiv”) processes the personal data you provide when using our website or that are provided by third parties.

Vertiv is a Delaware corporation established in the United States and, as site owner, acts as joint data controller together with the different companies of the Vertiv group to which your personal data may be transmitted to manage the relationship with you and to accommodate your requests.

Please read this privacy notice carefully before using our website because it will help you understand what data we collect, how we use and share the data, and what your choices are in that respect.

Personal data processed

Through your use of the website, we may collect personal data provided by you, including without limitation:

1. contact information, such as your first and last name, email address, username, phone number, and home address;
2. your company, job title, and employment status;
3. publicly available information about you collected from third parties, such as from the postal service for shipping address verification;
4. analytical information, such as pages and products viewed, ads clicked on, emails from us that you opened, browser, operating system ("OS"), Internet Protocol ("IP") address and device information (please refer to our cookie policy for further details).

The terms of this privacy notice apply also to personal data received from third parties, unless we inform you otherwise. Vertiv is not responsible for the dissemination of your personal data by third parties.

Purposes of the processing

Your personal data may be processed for the following purposes:

1. Compliance: to fulfil obligations provided by law and regulations.
2. Account registration: to create an online account, whether as a General User, a Vertiv Partner or a Vertiv Consultant, and your experience will vary depending on your type of account (e.g., with a General User account, you can edit your profile, visit the forums, and add your employer’s name and your job title; with a Partner and a Consultant account, you may, in addition to the above, access more information unavailable without login and you have more privileges in terms of engaging in the forums)
3. Customer services: to provide you with a response to your questions (e.g., concerning products, services, or warranties) and to inform you about contests, surveys, and sweepstakes; to arrange a meeting with a Vertiv expert; to provide you with e-books, whitepapers, reports, and other documents regarding our business, products and services; and to enable you to attend events (internal and external) and webinars.
4. Marketing
   • to send marketing communications (e.g., newsletters on latest trends and technologies, and news regarding our business, events, new products and services, and updates/news on existing products and services);
   • to conduct market research; and
   • to objectively rank one sales lead against another by using lead scoring to evaluate criteria such as job title, industry, and engagement with Vertiv marketing activities and website. Vertiv’s lead scoring is used exclusively to decide whether the sales department will make sales calls and/or conduct sales activities in relationship to you. No decisions are made with any legal effects, or that significantly affect you. Vertiv’s lead scoring does not analyse or predict aspects concerning your performance at work, economic situation, health, personal preferences or interests (with the exception of Vertiv product interest), reliability or behaviour, or movements. Location is considered for internal Vertiv territory assignment. Vertiv does not consider gender, race, religion, or sexual orientation as part of its lead scoring process.

The legal bases for processing personal data are the following:

• for purpose (a): to fulfil legal obligations
• for purpose (b) and (c): to enter into a contract with you to provide customer services as a user or, at your request, to take pre-contractual measures
• for purpose (d): your consent

Nature of providing the requested data

Providing your personal data is required for the purposes under points (a), (b) and (c); consequently, refusal to provide the requested data or its inaccuracy may prevent Vertiv from providing you with an account registration and customer services.

Providing your personal data for marketing under point (d) is optional; however, refusal to provide the data for this purpose may prevent Vertiv from providing you additional or tailored information on products/services. You may revoke your consent at any time.

Methods and place of processing and place of storage of personal data

Your personal data will be processed in accordance with the principles of correctness, lawfulness, and transparency.

Rest assured that we maintain appropriate security, technical, and organizational measures that ensure a level of security appropriate to the risk of unauthorized access to, and accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, personal data transmitted, stored, or otherwise processed. We ensure that our affiliates third-party service providers who access or handle personal data on our behalf maintain the same safeguards.

Your personal data will be processed manually or electronically using automated tools that ensure the security and confidentiality of the data.

Your processed data are stored at our registered office or at the office of any external providers we entrust to store personal data. If you wish to know the list of our external providers, please contact us.
We will process only personal data necessary for the above purposes. The people authorized to process personal data will immediately delete or make anonymous personal data unnecessary for the above purposes.

If we have given you, or you have chosen, a password to access certain areas of our website, you are responsible for keeping the password confidential: you should not share your password with anyone.

Data retention period

Your personal data will be kept by us:

• for contractual purposes: for the entire duration of your subscription on this website and, following the withdrawal of your registration, for the period thereafter which is necessary for the purposes of (i) establishment, exercise, or defense of legal claims and keeping accounting records of Vertiv and the companies of the Vertiv group, and (ii) fulfilment of legal obligations applicable to Vertiv and the companies of the Vertiv group. Please bear in mind that the statute of limitations and other applicable regulations may vary for each jurisdiction: for further information you may contact Vertiv at dataprotection@vertiv.com.
• for sending newsletters, advertising material, and other communications on new products/services and updates/news on existing products/services, and for carrying out surveys, including on customer satisfaction: for 24 months from their collection, unless it is necessary under, or permitted by, applicable laws to keep them longer.

The data will be deleted or rendered anonymous at the end of the above-listed periods.

Data dissemination, sharing and communication

Personal data will be disseminated only to the extent necessary for Vertiv to fulfil the obligations provided by law or regulations.

Your data may be processed by our employees authorized to process personal data for the purposes set out above. Vertiv may appoint external data processors to manage customer relationship databases; to send newsletters; to provide call center, credit recovery, logistics and telematics payment services; and to carry out surveys.

Your data may be shared with professionals, law firms, and notaries for auditing and due diligence activities. The above entities/individuals will act as autonomous data controllers or data processors.

The list of the above entities/individuals is kept up-to-date, and you can access it at our office on request.
Please consider that your personal data may be transferred to other companies of the Vertiv group or third parties located outside Nigeria. In such cases, Vertiv will take appropriate measures to ensure that safeguards are in place by verifying that (i) Binding Corporate Rules adopted by the National Information and Technology Development Agency (NITDA) are in place, (ii) Standard Contractual Clauses approved by the NITDA are entered into with the third party and, if required, supplementary measures to ensure that the law of those countries to which the data is transferred does not impinge on the adequate level of protection that Nigeria guarantees or (iii) other lawful data transfer mechanism.

Right to access, correct, and supplement data and object to processing and to submit complaints

You have the right to obtain confirmation of the existence or non-existence of personal data relating to you.

You also have the right to be informed of the following:

• the origin of the personal data
• the purpose and methods of data processing
• the logic applied to the data processed electronically
• the identity of the data controller and the data processors
• the identity of the individuals or categories of individuals to whom your personal data may be sent to or who may acquire your data as appointed representatives of our company in your country of residence or as individuals authorized to process your data

You equally have the right to:

1. have your data updated, corrected, and supplemented
2. have the processing of your personal data restricted, any unlawfully processed data erased, made anonymous, or blocked
3. require a declaration attesting that the people/companies we communicate or disseminate your data to have been notified and given full details of any of the operations under points (a) and (b) above having been carried out, unless this proves impossible or implies an effort that is clearly disproportionate to the right to be protected
4. obtain, in a structured format commonly used and readable by electronic devices, the personal data provided you give us and to have the data transmitted, directly or through Vertiv, to another data controller (known as data portability)
5. object, in whole or in part, to the processing of your personal data to carry out profiling, to send you advertising material and direct sales messages and to conduct market or commercial communication surveys

To exercise your above rights, please contact us at dataprotection@vertiv.com.

If you believe that we or a person/company we have communicated your data has violated your rights, you may file a complaint with NITDA.

Changes to Personal Information

It is imperative that your data with us is current and accurate. You may request for the rectification of any personal data that we hold about you so as to enable you to correct any incomplete or inaccurate data we hold about you. We may, however, need to verify the accuracy of the new data you provide to us.

Children's Privacy

Our website does not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Contact details of the Data Controller and Data Protection Officer

Vertiv, whose global headquarters is located at 1050 Dearborn Drive, Columbus, Ohio 43085, USA, acts as the Joint Data Controller of your personal data together with the other companies of the Vertiv group with which your personal data may be shared. To contact us in this respect or to exercise your above rights, please email dataprotection@vertiv.com.