FIVE STAR LOGISTICS TERMINAL DATA PRIVACY POLICY

Effective Date: March 2023
Last Updated: January 2025

1. Introduction

Five Star Logistics Terminal (“we,” “us,” “our”) is committed to protecting the privacy and security of personal data entrusted to us by our customers, employees, and stakeholders. This Data Privacy Policy outlines our approach to collecting, using, storing, and protecting personal data in compliance with global best practices and the Nigeria Data Protection Regulation (NDPR) as enforced by the Nigeria Data Protection Commission (NDPC). We undergo an annual NDPR audit to ensure compliance with data protection standards.

2. Scope

This policy applies to all personal data processed by Five Star Logistics Terminal, including but not limited to customer and employee data, collected through our online platforms, physical terminals, and operational interactions.

3. Data Collection and Processing

We collect and process personal data only for legitimate business purposes, ensuring that data subjects are informed and consent is obtained where necessary. The categories of data we process include:

• Customer Data: Names, email addresses, phone numbers, government-issued IDs, bills of lading, container numbers, and service interaction records collected through our online platform (eservices.fsl.nalcometgroup.com).
• Access Control Data: Names, agency names, biometric data (fingerprints, facial recognition), and other identifiers collected for terminal access control at our e-gate system.
• Employee Data: Biographical details, employment history, and performance records stored strictly for employee management and operational purposes.

4. Purpose of Data Processing

Personal data is processed for the following purposes:

• Facilitating online and in-person port services, including cargo handling and billing.
• Enforcing security measures at our terminals.
• Managing customer relationships and service interactions.
• Complying with regulatory obligations under Nigerian law.
• Employee management, payroll processing, and internal administration.

5. Data Retention and Storage

We retain personal data only for as long as necessary to fulfill the purpose for which it was collected, in line with legal and regulatory requirements:

• Transactional data is stored for a limited period and deleted after its intended use.
• Biometric and access control data are stored only for the duration of the required terminal access.
• Employee records are retained per employment regulations.

6. Data Protection Measures

We implement strict technical and organizational security measures to prevent unauthorized access, alteration, disclosure, or destruction of personal data, including:

• Data encryption and secure access controls.
• Regular cybersecurity audits and risk assessments.
• Compliance with NDPR security requirements.

7. Third-Party Data Sharing

Personal data may be shared with regulatory authorities, business partners, and service providers where required for compliance or service provision. All third parties must adhere to our data protection standards and applicable laws.

8. Data Subject Rights

Individuals whose data we collect have the right to:

• Request access to their personal data.
• Request correction or deletion of inaccurate or unnecessary data.
• Object to data processing or request data portability.
• Lodge complaints with the Nigeria Data Protection Commission (NDPC) if their rights are violated.

9. Compliance and Audit

We conduct an annual NDPR compliance audit and maintain transparency in our data processing activities. Our Data Protection Officer (DPO) ensures adherence to regulatory requirements and is available for inquiries:

Data Protection Officer: Mr. Paul Adeleke
Data Protection Contact: dpo@5starterminal.com

10. Amendments

We reserve the right to update this policy periodically to reflect changes in legal requirements or operational practices. Any updates will be published on our official website.

For further inquiries about this policy, please contact us at info@5starterminal.com or visit our office at 4, Balogun Bisi Omidiora Road, Apapa, Lagos.

Five Star Logistics Terminal