Privacy Policy

Effective date: [date] · Version 1.0

1. Who we are

Rotation & Precision Machines Limited (“RPM”, “we”, “us”) is the data controller for personal data collected through [website address]. Our registered office is at [address], Ikeja, Lagos, Nigeria.

Privacy enquiries: [privacy email address]. Data Protection Officer: [name and email address].

This policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it and what rights you have. It follows the Nigeria Data Protection Act 2023 (NDPA) and the General Application and Implementation Directive 2025 issued by the Nigeria Data Protection Commission (NDPC).

RPM is one legal entity with branches in several countries. RPM is the only controller for all personal data covered by this policy, wherever it is collected. One Data Protection Officer and one privacy contact serve every branch. Branch details are in section 19.

2. What personal data we collect and why

Where we collect it	Data collected	Why we use it	Lawful basis
Contact and enquiry forms	Name, company, job title, email, phone, your message	To reply to your enquiry	Legitimate interest
Request a Quote	The above, plus product, quantity and delivery details	To prepare and send quotations	Steps taken at your request before a contract; legitimate interest
Chatbot and live chat	Name, email or phone if you give them, chat transcript, device and browser details	To answer questions and pass you to our sales team	Consent; legitimate interest
Newsletter	Name and email address	To send you updates	Consent
Careers	Name, contact details, CV, work history and anything else you submit	To assess your application	Steps taken at your request before a contract; consent for longer retention
Client portal	Name, company, email, order and account information	To give clients access to their orders and account	Contract
Comments	Name, email, website, comment text, IP address and browser user agent string	To publish your comment and detect spam	Consent; legitimate interest
Website visits	IP address, device and browser type, pages viewed, referring site, approximate location	To keep the site secure and understand how it is used	Consent for analytics cookies; legitimate interest for security

We do not collect more personal data than we need for these purposes.

Giving us some data is optional. If you do not give us the data we need for a request, such as a quotation or a job application, we may be unable to deal with it. We do not usually ask for sensitive categories of data, such as health, religion or ethnicity. If a CV or other submission contains them, we process them only where the law allows or with your explicit consent. A separate [Careers Notice] and [Cookie Policy] give more detail on those activities.

3. How we collect it

We collect personal data in four ways: from forms and messages you send us, from conversations in the chat widget, from cookies and similar technologies, and from standard server logs when you visit the site.

4. Consent

Where we rely on your consent, you give it by a clear action, such as ticking a box, submitting a form after reading this notice, or accepting cookies in our cookie banner. You can withdraw consent at any time by emailing [privacy email address] or using the unsubscribe link in any message we send. Withdrawing consent does not affect processing carried out before you withdrew it.

5. Cookies

Cookies are small files stored on your device. We use the following types:

• Strictly necessary: security and login cookies. If you visit our login page, we set a temporary cookie to check that your browser accepts cookies. It holds no personal data and is deleted when you close your browser. When you log in, we set cookies to save your login details and screen display choices. Login cookies last two days and screen options cookies last one year. If you select “Remember Me”, your login lasts two weeks. Logging out removes the login cookies. When you edit or publish an article, a cookie records only the post ID and expires after one day.
• Preference: if you leave a comment, you may choose to save your name, email address and website in cookies so you do not have to enter them again. These last one year. We also use a cookie to remember your language choice [if Google Translate is used].
• Analytics: [Google Analytics, through Site Kit,] helps us understand how the site is used. These cookies are set only after you accept them.
• Chat: [Zoho SalesIQ] sets cookies so the chat widget can recognise returning visitors.

You can manage cookies through our cookie banner and your browser settings. Blocking strictly necessary cookies may stop parts of the site from working.

[A full Cookie Policy listing each cookie is available at [link].]

6. Who we share your data with

We share personal data only with service providers who process it on our instructions, under written agreements, and only for the purposes above:

• [Zoho] for our customer relationship management, chat and customer portal systems.
• [Google] for website analytics and translation.
• [Hosting provider name] for hosting this website.
• [Email service provider] for sending email from the site.
• An automated spam detection service, which may check comments.
• Gravatar (Automattic): an anonymised string created from your email address may be sent to check whether you use a profile picture. Once your comment is approved, your profile picture is visible to the public next to it. Its privacy policy is at https://automattic.com/privacy/.

We may also disclose personal data to professional advisers, and to regulators, courts or law enforcement where the law requires it. We do not sell personal data.

[If you enquire about a product made by a brand we distribute, such as SKF or FUCHS, we may pass your enquiry to that brand’s company so it can respond. That company then handles your data under its own privacy policy.]

For more detail on who receives your data, the safeguards for transfers or how long we keep data, email [privacy email address].

This site may include embedded content, such as videos, images or articles from other websites. Embedded content behaves as if you had visited the other website. Those sites may collect data about you, use cookies, add their own tracking and monitor how you interact with the content, including when you are logged in to an account there. Their own privacy policies apply.

7. Where we send your data

Some of our service providers process data outside Nigeria. We transfer personal data abroad only where the destination provides adequate protection, where we have put appropriate safeguards in place such as contractual clauses, or where another lawful ground under the NDPA applies. You can ask us for details of the safeguards we use.

If you upload images to this site, avoid including embedded location data (EXIF GPS). Anyone who visits the site can download an image and extract that data.

8. How long we keep your data

We keep personal data only for as long as necessary for the purposes set out above, or for as long as the law requires. To decide how long that is, we consider why we collected the data, whether we still need it to respond to you or provide our services, and whether any legal, accounting or regulatory requirement applies. When we no longer need personal data, we delete it or anonymise it.

If you register an account on this site, we store the personal information in your profile. You can see, edit or delete it at any time, except your username. Website administrators can also see and edit it.

9. Your rights

Under the NDPA you have the right to:

• be informed about how we use your data;
• access the personal data we hold about you and receive a copy;
• have inaccurate or incomplete data corrected;
• have your data erased, except where we must keep it for administrative, legal or security reasons;
• restrict our processing, or object to processing based on our legitimate interest and to direct marketing;
• receive your data in a structured, commonly used, machine-readable format and have it passed to another controller where possible, where we process it based on your consent or a contract;
• withdraw consent at any time; and
• not be subject to a decision based solely on automated processing that has legal or similarly significant effects on you.

To use any of these rights, email [privacy email address]. We may ask you to confirm your identity first. We respond within [one month] and do not normally charge a fee.

10. Complaints

If you are unhappy with how we have handled your data, please contact us first at [privacy email address] so we can put it right. You also have the right to complain to the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng.

11. Automated decision-making and profiling

We do not make decisions about you based solely on automated processing that has legal or similarly significant effects. Our website chatbot [uses artificial intelligence to answer common questions]. It will tell you that you are talking to an automated assistant, and you can ask to be passed to a member of our team. We use analytics to understand overall site use. We do not use it to build individual profiles for marketing.

12. How we protect your data

We protect personal data with measures that include [encrypted connections (HTTPS), access controls limited to staff who need the data, regular software updates and backups, and confidentiality obligations for staff and service providers]. No system is completely secure, but we review these measures regularly.

13. Data breaches

If a personal data breach is likely to put your rights and freedoms at risk, we will notify the NDPC within 72 hours of becoming aware of it. Where the risk to you is high, we will also tell you without undue delay, explaining what happened, the likely consequences and what we are doing about it. We keep a record of every breach.

14. Children

This website is not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us and we will delete it.

15. Data we receive from other sources

We may receive business contact details from our clients’ staff, from referrals, from public business sources, and from the customer relationship management system we use. We use this data only to deal with the business relationship and will tell you how we obtained it when we first contact you.

16. Regulatory compliance

RPM complies with the NDPA and the NDPC’s directives. [RPM is registered with the NDPC as a data controller of major importance and files an annual compliance audit return.] We disclose personal data to regulators, courts or other authorities only where the law requires it.

17. Changes to this policy

We will update this policy when our practices or the law change. The effective date and version number at the top show when it was last changed. We will post material changes on this page [and notify subscribers by email].

18. Contact us

Rotation & Precision Machines Limited, [address], Ikeja, Lagos, Nigeria. Email: [privacy email address]. Phone: [phone number]. Data Protection Officer: [name and email address].

19. Our branches

Branch	Country	Address	Local contact
Head office, Ikeja	Nigeria	[address]	[name and email]
[Branch]	[Country]	[address]	[name and email]
[Branch]	[Country]	[address]	[name and email]

You can send any privacy request to [privacy email address], whichever branch you deal with.

20. Regional information

Keep only the regions where RPM has branches or targets visitors.

• Nigeria: we process personal data under the Nigeria Data Protection Act 2023 and the NDPC’s General Application and Implementation Directive 2025. Your right to complain to the NDPC is in section 10.
• Other African countries: where we operate in another African country, we also follow its data protection law. You may complain to that country’s data protection authority: [authority and website for each country].
• Europe and the UK: where our branches process data in the European Economic Area or the UK, the GDPR or UK GDPR applies. You may complain to the data protection authority in the country where you live or work. Data moves between our branches under [standard contractual clauses or other approved safeguards].
• United States: if you live in a US state with a privacy law, you may have the right to know, correct, delete and opt out of the sale or sharing of your personal data. We do not sell personal data. [Confirm before publishing.]

Where the law of your country gives you further rights, we will honour them.