This is the Privacy Policy of PAN Nigeria Limited. In this document, "we", "our", or "us" refer to PAN Nigeria Limited. We are a company registered in Nigeria with RC Number 10961 with our principal address at Plot 1144 PAN Drive, Kakuri Industrial Estate, Kaduna State Nigeria.

Introduction

This Privacy Policy aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“Personal Data”) and information that could not. In the context of the law and this policy, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your Personal Data. We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate. Our policy complies with the Nigerian Data Protection Regulation (NDPR).

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

You accept this Privacy Policy and hereby give us consent to save, process and use your Personal Data to the extent as allowed by law when you provide us with details of your Personal Data or by clicking on the “accept” button.

Collection of Personal Data

Personal Data is information that can be directly associated with an identifiable natural person such as a name, address, telephone number, or email address, photo, etc. You may be asked to provide your Personal Data anytime you contact us, and we shall use the Personal Data in consistence with this Privacy Policy. We may combine the Personal Data with other information in order to improve our solutions, services, content, and advertising. You may choose not to provide the Personal Data that we have requested but if you do so, we may not be able to provide you with our solutions or services or respond to any queries you may have.

We may collect Personal Data when you:

• Use our website - we may automatically collect some information such as information on the website from which you linked to our website, the time and date of your visit and activities.
• Request that we provide you with our solutions and services.
• Send your CV or apply for a job application and employment.
• Contact our customer service centre whether by post, phone, email, or chat.
• We may collect Personal Data received from third parties to the extent that they have represented that they have entered into an agreement with you for the provision of our solutions or services.
• Information we collect when we receive calls to and from our call centre for quality assurance purposes.

Use of Personal Data

We may use your Personal Data, including non-Personal Data as follows:

• Provide, maintain, and improve our Products, solutions or services.
• Provide and deliver our Products, solutions and services you request, process transactions and send you related information, including confirmations.
• Verify your identity and prevent fraud.
• Send you technical notices, updates, security alerts and support and administrative messages.
• Respond to your comments, questions and requests and provide customer service.
• Communicate with you about our Products, solutions, services, offers, promotions, rewards, and events offered by us and others, and provide news and information we think will be of interest to you.
• Monitor and analyse trends, usage and activities in connection with our Products and services.
• Personalize and improve the Products, services and provide advertisements, content or features that match user profiles or interests.
• Process and deliver contest or promotion entries and rewards.
• Link or combine with information we get from others to help understand your needs and provide you with better Product and/or service.
• Carry out any other purpose for which the Personal Data was collected.

PAN Nigeria Limited is based in Nigeria and the information we collect is governed by the Nigeria Data Protection Regulation (NDPR). By accessing or using the Services or otherwise providing Personal Data to us, you consent to the processing and transfer of information in and to Nigeria and other countries.

Data Processing for Advertising Purpose

In the event you contact us for information (e.g. request for information on our Products or services), we may use your Personal Data for market research and to communicate and advertise to you about our Products, solutions, services, offers, promotions, and rewards.

We may use various cookies on our website, such as:

Category 1 — Strictly Necessary Cookies

These cookies are essential to enable you to browse around our website and use its features.

Category 2 — Performance Cookies

These cookies collect information about how you use our website — for instance, which pages you go to most. This data may be used to help optimize our website and make it easier for you to navigate. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous.

Category 3 — Functionality Cookies

These cookies allow our website to remember choices you make while browsing. For instance, we may store your geographic location in a cookie to ensure that we show you our localized website (when applicable). These cookies may also be used to keep track of what featured products or videos have been viewed to avoid repetition. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on non-PAN Nigeria websites.

We treat information collected by cookies and other technologies as non-personal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by local law, we also treat these identifiers as Personal Data. Similarly, to the extent that non-personal data is combined with Personal Data, we treat the combined information as Personal Data for the purposes of this Privacy Policy.

Lawful Basis for processing Personal Data

We may use your Personal Data in performance of a contractual agreement, for compliance with legal obligations to which we are subject to, for your vital interest, when we have assessed it is necessary for our or a third-party legitimate interest, or when we obtain consent from you.

Retention of Personal Data

Except as otherwise mentioned in this Privacy Policy, we keep your Personal Data only for as long as required by us:

• to provide you with the services you have requested.
• to comply with other law, including for the period demanded by our tax authorities.
• to support a claim or defence in court.
• in accordance with our Retention Policy.

Disclosure of Personal Data

Although we do not disclose your Personal Data to any third party (except as set out in this Policy), we sometimes receive data that is indirectly made up from your Personal Data from third parties whose services we use.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of PAN Nigeria Limited
• Prevent or investigate possible wrongdoing in connection with a service
• Protect the personal safety of others or the public
• Protect against legal liability

We may also use outsourced services in countries outside Nigeria or the European Union from time to time in other aspects of our business. Accordingly, data obtained within Nigeria, the UK or any other country could be processed outside the European Union. We would ensure that these countries are NITDA’s White List of Countries and with adequate data protection laws.

Security of Personal Data

PAN Nigeria Limited takes reasonable measures to help protect all Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, we have implemented policies designed to protect the confidentiality and security of your Personal Data.

Your Rights as a Data Subject

• You have a right to consent to this Privacy Policy and to withdraw your consent at any time.
• You have a right to a copy of your Personal Data that we hold about you.
• You have a right to freely transfer your Personal Data received from us to any other organisation.
• You have the right to have the Personal Data we hold about you corrected if it is factually inaccurate.
• In some circumstances, you have the right to the deletion of your Personal Data.
• Where certain conditions apply, you have a right to object to the processing of your Personal Data.
• You have the right to restrict processing of certain types of processing we carry out on your Personal Data, such as direct marketing.
• You have a right to lodge a complaint about the way we handle of your Personal Data with the National Information Technology Development Agency (NITDA).

NITDA’s website (https://nitda.gov.ng/nit/ ) has a wealth of useful information in respect of your rights over your personal data.

Where we do not act on your request to exercise any of your rights, we shall inform you within one month of the receipt of your request, of the reasons for not taking action.

Breaches / Privacy Violation

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NITDA.

Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.

Changes to our Privacy Policy

Any changes we make to this Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this Policy.

Please note that from time to time, we may post on our website links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

How to Complain

If you are not happy with our Privacy Policy or if you have any complaint, then you should tell us customerservice.pannigeria.com. If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

Questions or Concerns

We have appointed a Data Protection Officer (DPO) who is responsible for ensuring that our policy is followed. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPO,

customerservice@pannigeria.com