Privacy notice

Who we are

Malina Nig Ltd ("Malina", "we", "us") is a company registered in Nigeria with the Corporate Affairs Commission under RC XXXXXXX, with its registered office at [registered office address]. We are the data controller for personal data collected through this website.

Our Data Protection Officer is [name], reachable at privacy@malinangrltd.com.

What this notice covers

This notice covers malinangrltd.com. It does not cover data you give us in the course of an engagement once it has begun, which is governed by the contract between us, nor any other company's website you reach from a link here.

What you send us

The audit request form and the live chat are the two places this website asks you for anything. When you submit the form we receive:

• Your name, company, work email address and, if you give it, your telephone number.
• The division, urgency, sector and system you select.
• The message you write, including any technical detail about your plant you choose to include.

All of it is optional in the sense that you do not have to use the form. You can email info@malinangrltd.com instead, and the same notice applies to what you send.

Live chat

The chat panel loads nothing until you open it. No connection is made, no sound plays and nothing about you is collected while it sits closed.

When you start a chat we ask for your name, email address and phone number so we can reply if the conversation is interrupted, and we record which department you chose. Alongside the conversation we keep what your browser tells every website it visits: your IP address, the page you started from, your browser and operating system, your screen size and your language. An agent sees this so they know whether you are on a phone at a plant or at a desk.

Approximate location. If enabled, your IP address is sent to a lookup service to get a city and country. The request is made by our server, never by your browser, so the service never sees your browser, your referrer or any cookie. Private and local addresses are never sent anywhere. This is switched off unless Malina turns it on.

You can ask for the whole conversation to be emailed to you at any point. If nobody is at the desk, the conversation is emailed to us instead so somebody can pick it up. Chat records are kept for six months and then deleted.

What is collected automatically

• Your IP address, recorded when you submit the form. It is used to limit how many submissions one connection can make, and it is included in the enquiry email we receive so we can investigate abuse.
• Ordinary server request logs kept by our hosting provider, such as IP address, browser type, the pages requested and the time of the request.

There is no analytics on this website. No Google Analytics, no advertising pixels, no tracking scripts, no third-party fonts. Pages other than blog posts carrying a video make no requests to anyone but our own server.

Automated checks on enquiries

Every submission is scored automatically before it reaches us, to keep spam out of the inbox. The check looks at the message and the details around it: how quickly the form was filled in, how many links it contains, whether it uses vocabulary typical of bulk selling, whether the address belongs to a disposable-email service, and whether an identical message has already arrived within the hour.

A message that scores in the middle is delivered to us with a marker on it, and a person reads it. A message that scores high enough is discarded and never reaches us. The form gives the same confirmation either way, so that automated senders learn nothing from the response.

We think the check is conservative, but no filter is perfect. If you have used the form and had no reply within two working days, please email info@malinangrltd.com directly, or telephone us. Under the Nigeria Data Protection Act you may also ask us to review any decision reached this way; write to privacy@malinangrltd.com.

Why we use it, and on what basis

Replying to your enquiry

Your request that we get in touch, and our legitimate interest in responding to prospective clients.

Preparing a scope of work or quotation

Steps taken at your request before entering a contract.

Delivering work you engage us for, and keeping records of it

Performance of the contract between us.

Tax, company and regulatory record keeping

Compliance with a legal obligation.

Rate limiting, spam filtering and keeping the site working

Our legitimate interest in keeping the service available and free of abuse.

We do not use anything you send through this website for marketing lists, and we do not send bulk email.

Cookies

This website sets no cookies of its own. No analytics, no advertising, no tracking. On most pages there is nothing to consent to, and so you are asked nothing.

Two things are worth explaining because they are sometimes mistaken for tracking. When you first click into the audit request form, the page fetches a short signed token that proves the form was genuinely loaded and how long you spent filling it in; it is single-use, it expires, and it identifies nobody. Separately, the staff area at /secure/ sets a session cookie for signed-in Malina staff only; it is never set for visitors.

Embedded video

Some articles may embed a video from YouTube or Vimeo. Where they do, your browser connects to that provider and they may set their own cookies and receive your IP address, under their privacy policy rather than ours. We use YouTube's no-cookie player and Vimeo's do-not-track setting, which stops advertising cookies before you press play, but it does not make the connection private. Pages without a video make no such request.

Who we share it with

We do not sell personal data, and we do not share it for anyone else's marketing.

• Our email provider, [provider], which carries the enquiry from this website to our inbox and stores it there.
• Our hosting provider, [provider], which serves the website and keeps the request logs described above.
• Regulators, courts or law enforcement, where we are legally required to hand something over.

Both providers act on our instructions under contract, and only to the extent needed to provide the service.

Transfers outside Nigeria

Our email and hosting providers may store or process data on servers outside Nigeria. Where that happens we rely on the transfer conditions in Part IX of the Nigeria Data Protection Act, and on the contractual protections in our agreements with those providers. You can ask us which countries are involved and what safeguards apply by writing to privacy@malinangrltd.com.

How long we keep it

Enquiries that do not lead to an engagement

Deleted within 24 months of our last exchange with you.

Records relating to an engagement

Kept for the period Nigerian tax and company law requires, then deleted.

The IP address used for rate limiting

Held in the server's memory for ten minutes, and in a site-wide count for one hour. It is not written to a database.

The fingerprint used to spot duplicate submissions

A one-way hash of your email address and message, held in memory for one hour and then discarded.

Server request logs

Kept for the period set by our hosting provider, [period].

Your rights

Under the Nigeria Data Protection Act 2023 you may ask us to:

• Confirm what personal data we hold about you, and give you a copy.
• Correct anything inaccurate or incomplete.
• Delete data we no longer have a reason to keep.
• Restrict what we do with it while a question about it is resolved.
• Provide it in a portable form, or send it to another controller where that is technically feasible.
• Stop processing that relies on our legitimate interests, where your rights outweigh them.
• Withdraw consent at any time, where we relied on consent. Withdrawing it does not affect what we did beforehand.
• Review a decision reached only by automated means, including a message stopped by the spam check.

Write to privacy@malinangrltd.com. We will respond within the period the Act allows, and we will not charge you for a first request. We may ask you to confirm who you are before we release anything.

If you are not satisfied

Tell us first and we will try to put it right. You are also entitled to complain to the Nigeria Data Protection Commission, the regulator for data protection in Nigeria, at ndpc.gov.ng.

Security

This site is served over HTTPS. The staff area is password protected, rate limited against repeated sign-in attempts, and is not reachable from the public site. Enquiry data is available only to Malina staff who need it to respond to you.

If a breach of personal data occurs and it is likely to result in a risk to you, we will notify the Commission and, where the Act requires it, you directly.

Children

This website is aimed at industrial and commercial organisations. It is not directed at children and we do not knowingly collect data from them. If you believe a child has sent us personal data, write to privacy@malinangrltd.com and we will delete it.

Changes to this notice

If we change how this website handles personal data, we will update this page and change the date below. Where a change is significant we will say so at the top of the page rather than leave you to spot it.

Last updated: to be set on publication.