Privacy Policy

Aethos Dynamic Systems Ltd is a Nigerian technology and systems company focused on aerospace and unmanned systems, intelligence and surveillance technologies, remote sensing, earth observation, artificial intelligence, edge computing, geospatial intelligence and related technology services. For applicable personal-data processing activities, Aethos may act as a Data Controller, Data Processor, or both, depending on the nature of the relationship and processing activity.

This Privacy Policy applies to personal data collected through:

• the Aethos website;
• contact and enquiry forms;
• email communications;
• recruitment and employment enquiries;
• business-development communications;
• customer and supplier interactions;
• events, demonstrations and exhibitions;
• online portals or services operated by Aethos where this Policy is expressly referenced; and
• other legitimate interactions with Aethos.

This Policy does not necessarily apply to third-party websites, applications or services linked from our Website.

3.1 Identity Information

Name, job title, position, organisation, business affiliation and professional profile information.

3.2 Contact Information

Email address, telephone number, business address, mailing address and other contact information you voluntarily provide.

3.3 Enquiry and Communication Information

Your enquiry, correspondence, attachments, meeting requests, communications history and information necessary to respond to your request.

3.4 Recruitment Information

Where you apply for employment or submit a professional enquiry, we may process CV/resume, qualifications, employment history, professional experience, skills, references, contact details and other information voluntarily provided. We will process recruitment information for legitimate recruitment and human-resources purposes and in accordance with applicable law.

3.5 Technical Information

IP address, browser type, operating system, device information, approximate geographic information derived from technical data, referring website, pages visited, access times, Website interactions, and diagnostic and security information.

3.6 Cookies and Similar Technologies

We may use cookies, pixels, tags, local storage and similar technologies to operate essential Website functions, maintain security, remember preferences, measure Website performance, understand visitor behaviour, analyse traffic and improve the Website. Non-essential cookies will be subject to applicable consent requirements.

We may collect personal data directly from you; when you complete an online form; when you contact us by email or telephone; when you request information; when you communicate with our personnel; through Website analytics and technical systems; from publicly available professional sources; from business partners or service providers where lawful; and from other legitimate sources permitted by applicable law.

We may process personal data for purposes including responding to enquiries; communicating with prospective customers; providing requested information; managing business relationships; preparing proposals and quotations; administering contracts; delivering services; managing suppliers and partners; recruitment; responding to employment enquiries; improving Website functionality; analysing Website performance; maintaining cybersecurity; detecting and preventing fraud or abuse; maintaining records; complying with legal and regulatory obligations; protecting our legal rights; managing corporate communications; and other legitimate purposes disclosed at the point of collection.

Where the NDP Act or other applicable law applies, we will rely on an appropriate lawful basis for processing personal data. Depending on the circumstances, this may include:

• Consent — where required. You may withdraw consent where applicable. Withdrawal does not affect processing lawfully carried out before withdrawal.
• Contract — processing may be necessary to enter into or perform a contract with you or an organisation you represent.
• Legal obligation — where necessary to comply with applicable legal or regulatory obligations.
• Legitimate interests — where necessary for legitimate interests pursued by Aethos or a third party, provided those interests are not overridden by applicable data-subject rights. Examples may include cybersecurity, business administration, responding to business enquiries, fraud prevention and maintaining business relationships.
• Other lawful bases provided by applicable law.

If you contact Aethos regarding products, services, partnerships, investments, technology, procurement, distribution or other commercial opportunities, we may use your contact information to communicate with you regarding the relevant matter. Where required by law, marketing communications will be subject to appropriate consent or opt-out mechanisms. You may request that we stop sending non-essential marketing communications.

We do not sell personal data as a business model. We may disclose personal data where reasonably necessary to employees and authorised personnel; affiliated companies; professional, legal and financial advisers; IT, hosting, cloud, cybersecurity, communications and analytics providers; recruitment service providers; contractors; business partners; regulators and government authorities; law-enforcement agencies where legally required; or other third parties where you have authorised the disclosure or where disclosure is otherwise permitted by law. Third parties receiving personal data may be required to maintain appropriate confidentiality and security controls.

Aethos may use service providers, technology infrastructure or business partners located outside Nigeria. Where personal data is transferred internationally, Aethos will take steps required by applicable law to ensure that the transfer is lawful and that appropriate safeguards are implemented. Such safeguards may include contractual protections, approved transfer mechanisms, adequacy mechanisms or other lawful measures.

Aethos takes reasonable technical and organisational measures to protect personal data against unauthorised access, unlawful processing, accidental loss, destruction, alteration, disclosure and other security incidents. Security measures may include access controls, authentication, encryption where appropriate, secure hosting, monitoring, backups, confidentiality obligations and organisational controls. However, no internet-based system can be guaranteed to be completely secure. You should therefore avoid sending highly sensitive, classified, export-controlled or confidential technical information through ordinary Website forms or unsecured email.

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, unless a longer period is required or permitted by applicable law. Retention periods may depend on the purpose of processing, contractual requirements, legal and regulatory obligations, accounting and audit requirements, dispute resolution, legitimate business requirements, and security or fraud-prevention requirements. When personal data is no longer required, we will take reasonable steps to delete, anonymise or securely dispose of it.

Subject to applicable law and relevant exemptions, you may have rights including: the right to be informed about processing; to request access; to request correction of inaccurate or incomplete data; to request deletion or erasure; to restrict processing; to object to certain processing; to data portability; to withdraw consent where processing is based on consent; rights relating to certain automated decision-making; and the right to lodge a complaint with the relevant data-protection authority. These rights are not absolute and may be subject to legal limitations or exemptions.

To exercise an applicable data-protection right, contact us using the details below. Your request should identify your name, contact details, the nature of your request, relevant information that will help us identify the records concerned, and any other information reasonably necessary to verify your identity and process your request. We may request reasonable identity verification before releasing or changing personal data. We will handle requests within the timeframe required by applicable law.

If you believe that Aethos has processed your personal data unlawfully or has otherwise failed to comply with applicable data-protection requirements, you may contact us so that we can investigate and address the matter. You may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another competent supervisory authority.

The Website is intended primarily for business and professional audiences. We do not knowingly seek to collect personal data from children where such collection would be unlawful. If you believe that a child has provided personal data to Aethos without appropriate authorisation, contact us so that we can assess and, where appropriate, delete the information.

The Website may contain links to third-party websites. Aethos does not control the privacy practices of those third parties. You should review the privacy policy of each third-party website before providing personal information.

The Website may use third-party technologies for website hosting, analytics, maps, video, fonts, security, communications, customer relationship management, form processing and Website performance. Such technologies may process technical or personal information according to their own privacy practices. Where required, appropriate consent mechanisms will be implemented.

Where Aethos becomes aware of a personal-data breach, we will assess the incident and take appropriate containment, investigation, remediation and notification measures in accordance with applicable law. Where notification to regulators or affected individuals is legally required, Aethos will make such notifications within the applicable statutory or regulatory timeframe.

We seek to maintain accurate and relevant personal data. If your information changes or you believe information held by Aethos is inaccurate, you may contact us and request correction.

Aethos may use artificial intelligence, machine-learning or automated technologies in certain business, technical or operational activities. We will not use personal data for automated decision-making in a manner prohibited by applicable law. Where legally required, appropriate information, safeguards and mechanisms for human intervention or review will be provided.

Aethos operates in technology sectors that may involve sensitive commercial, technical, security or government information. This Privacy Policy concerns personal data and does not constitute an authorisation to submit classified, restricted, export-controlled or otherwise protected information through the Website. Users should use designated secure channels where Aethos specifically provides them for sensitive information.

We may update this Privacy Policy from time to time to reflect changes in law, regulatory guidance, our services, Website technologies, data-processing activities, or improvements to our privacy practices. The latest version will be published on the Website with its effective date.

For privacy enquiries, data-subject requests or concerns relating to the processing of personal data, contact Aethos Dynamic Systems Ltd at victor.bassey@aethosdynamicsystems.com. Please include “Data Protection Request” in the subject line where appropriate.

The relevant Nigerian supervisory authority for data protection is the Nigeria Data Protection Commission (NDPC). The NDPC is responsible for overseeing implementation of the Nigeria Data Protection Act 2023 and regulating data-protection and privacy matters in Nigeria.