BrandCo Nigeria Limited and its affiliates (the "Company," "we," or "us" or "our") is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Nigerian Data Protection Act (NDPA), the General Application and Implementation Directive (GAID), and General Data Protection Regulation (GDPR), as the standard which governs the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, and phone numbers.

We also collect information about your internet connection which includes: your IP address, the tool you used to access our website, information on websites/links that led you to our website and your website usage details.

How do we obtain the personal information?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, email or otherwise. This includes information you provide when you create an account, subscribe to our service, participate in discussion boards or other social media functions on our website, and when you report a problem with our website.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, and other similar technologies (see Cookies and Automatic Data Collection Technologies).
• Third parties or publicly available sources. We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers.

Cookies and Automatic Data Collection Technologies

Our website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized service when you browse our website. It also allows us to improve our website by enabling us to:

• Estimate our audience size and usage patterns.
• Store your preferences so we may customize our website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our website.

Types of cookies we use

• Strictly necessary cookies: required for site operation.
• Performance/analytics cookies: to understand how visitors use the Site.
• Functional cookies: to remember choices and preferences.
• Advertising/marketing cookies: to deliver relevant adverts (where applicable).

Third-Party Use of Cookies

Some content or applications, including advertisements, on the website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.

How do we use your information?

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing in ways which include:

• Presenting our website and its content to you.
• To fulfill or deliver your orders placed through our website, and any other purposes for which you provide personal information, for example the processing of returns.
• To send you other information about our products, offers and news we think could interest you via email. (We only send you this if you have subscribed to our mailing list).
• To carry out our obligations and enforce any rights which accrues to us from any contracts between you and us, including billing and collection purposes.
• To notify you about changes to our website or our policies.
• To analyze visits to the website and learn about the interests of our visitors and better understand your personal interests and needs, so we can improve our products and services and deliver the type of content and features that would interest you.

We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.

You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained.
• For a secondary purpose that is directly related to the primary purpose.
• With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Please note that except as described in this Privacy Notice, we do not sell, rent or trade any personal information you provide to us online or at our stores, nor do we share such information with third parties.

We may disclose your personal information as described in this Privacy Notice in a number of circumstances including the following:

• To our subsidiaries and affiliates, which may require transferring your information outside Nigeria.
• To our agents, contractors, business partners, service providers, and other third parties who are also bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfilment and shipping, advertising, marketing and promotional material distribution, website usage evaluation, data analysis and, where applicable, data cleansing.
• We also may share non-personal information (such as the number of users who visited the website during a specific time period or who purchased a specific product through the website) with our marketing partners, advertisers and others from time to time.
• To third parties, such as credit agencies, to verify delivery names and addresses for online orders. If you provide us with a delivery name and address which is not yours, you must have that person's permission to give us their personal information and for us to use it for the purposes specified. By providing it, you are affirming that you have their permission to do so.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information about our website users is a part of the assets transferred. If that happens, your personal information may be disclosed to another company, but that disclosure will be subject to this Privacy Notice.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

BrandCo Nigeria Limited will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information, we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

We may also automatically update your personal information through the use of cookies on our website.

Your Rights

Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:

• The right to object to direct marketing.
• The right to access the personal data that we process about you.
• The right to request the deletion of your personal data.
• The right to request the rectification of your personal data.
• You can exercise these rights by contacting our data controller.
• You also have the right to lodge a complaint with a supervisory authority.

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at: