Policy Brief & Purpose

Ardova Plc (AP) is committed to treating information supplied by employees, customers, vendors, stakeholders, and other interested parties with the utmost care and confidentiality. AP as a company collects and processes your personal information and the responsibility, is not outsourced to any third party.

For this Privacy Policy, references to ‘AP’, ‘We’, ‘Us’, ‘Our’ or ‘the Company’ shall mean Ardova Plc.

By providing the Data Subject’s personal information or the personal information of a beneficiary from the Data Subject’s policy, the Data Subject acknowledges that AP may only use the information in the manner specified in this Privacy Policy.

This policy may be updated periodically, for example, because of government regulation or promulgation, new technologies, or other developments on data protection and/or privacy laws.

Role Definitions

The following roles are defined for this policy

Data Subject: This means a person that can be identified directly or indirectly, by reference to an identification number or one or more factors specific to his physiological, mental, economic, cultural, or social identity. Such a person may be AP’s clients, customers, business partners, vendors, and employees.

Data Administrator/Processor: This means a person or organization that processes data.

Data Controller: This means a person who either alone, jointly with other persons, in common with other persons, or as a statutory body, determines the purposes for and the way personal data is processed or is to be processed.

Data Protection Officer: This is a staff of Ardova Plc appointed by the Data Controller, to ensure that the strategy and implementation of data protection principles follow the data protection policy and relevant extant laws. For this policy, the data protection officer is defined as the Information Technology Manager of AP

Key Terms

The following terms are defined for this policy

Consent: Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, through a statement or a clear affirmative action, signifies agreement or approval for the processing of Personal Data supplied to the Data Administrator.

Personal Data: Any information relating to an identified or identifiable person.

Third-Party: This means a person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor are authorized to process personal data.

SCOPE

This Privacy Policy refers to all data subjects who provide information to the Data Controller.

What type of data does AP collect?

AP collects the following data:

1. Personal identification information: This could be any data that could potentially identify an individual. Any information that can be used to distinguish one person from another can be used for de-anonymizing anonymous data. Such data includes, but is not limited to name, age, height, etc.
2. Contact Information: To help us make communication more useful and interesting, we collect information that includes, but is not limited to email address, phone number, etc.
3. Other sensitive personal information: These are defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual, such information includes but is not limited to marital status and religious affiliation.
4. Financial Information: This includes data such as debit or credit card numbers, credit ratings, account balances, and other monetary facts about a person or organization that are used in billing and other financial activities.
5. Mobile: When you download or use apps created by AP, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services such as the closest service station to you, amongst other promotions.
6. Online Information (cookies): Cookies are small text files that are stored on your computer or mobile devices whenever you visit our website.
7. Device Data: We may collect data relating to the device being used to access our services as; device IP address, hardware model, operating system, version, software, unique device identifiers, advertising identifiers, serial numbers, mobile network data, and Web browsing data.
8. Location data: We may collect precise or approximate location data from a user’s mobile device if enabled by the user to do so.
9. Usage Data: We collect data about how users interact with our services via our website and mobile application. This includes data such as access dates and times app usage, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services.
10. Tax compliance information: This includes verification and evidence of compliance to relevant tax regulations by vendors which include but are not limited to Value Added Tax (VAT) certificate

Policy Elements

As part of our operations, we need to obtain and process information. AP transparently collects information and only with the full cooperation and knowledge of interested data subjects. Once this information is available to us, the following rules apply:

AP data will be:

• Accurate/ constantly updated
• Collected fairly and for lawful purposes only
• Processed by the company within its legal and moral boundaries
• Protected against any unauthorized or illegal access by internal or external parties
• Limited to Personal Data that is relevant, adequate, and necessary for carrying out the purpose for which the data is processed.
• Evaluated whether and to what extent the processing of the personal data is necessary and where the purpose allows, anonymized data must be used.

AP data will not be:

• Communicated informally
• Transferred to organizations, states, or countries that do not have adequate data protection policies
• Distributed to any party other than the ones agreed upon by the data Subject (exempting legitimate requests from law enforcement authorities).

Requirement for Consent

In addition to ways of handling the data, AP has a direct obligation toward Data Subjects to whom the data belong. Specifically, we shall:

• Inform the Data Subject which of their data is collected and explain the reason for obtaining their consent. Where the Data Subject provides personal information about third parties, AP will ask such Data Subjects to confirm that the third party has given consent to the Data Subject to act on their behalf and will provide AP with a copy of such consent issued.
• Inform the Data Subjects about how their data is being processed. Consent will be obtained via the same medium used to obtain personal information or through any other means that is acceptable to AP. Reference will be made to this Policy or a summarized version that can be easily understood by the Data Subject. The Data Subject will be required to indicate understanding and acceptance of the terms contained in this policy. This can be through signature for physical documents or a ticked checkbox for electronic platforms.
• Inform the clients about who has access to their information, where AP has appropriate, legitimate business need to use subject personal information for the maintenance of business records including but not limited to development and improvement of products and services, AP will take extra care to ensure that the Data Subject’s rights to security and confidentiality are not infringed upon.

Reason for use and process of data by AP

AP collects your data so that we can:

• Process purchase orders: Information related to e-commerce orders are used for processing the purchase order and related after-sales services, including customer support and re-delivery. In addition, the order number will be used to cross-check the order with the delivery partner as well as to record the delivery of the item.
• Providing location-based services: While using the AP app, location information may also be used by us to deliver your ordered item to you and obtain feedback on how our various service stations are used.
• Emailers: We send out notification emails from time to time, we may use your personal information to send important notices, such as notices about purchases and changes to our terms, conditions, and policies and about special offers on other products and services we think you might need.
• Inform you of ongoing promos and special offers

If you agree, AP will share your data with our partner companies so that they may offer you, their products.

How does AP store your data?

AP securely stores your data on our secure servers as well as secure physical locations and cloud infrastructure (where applicable).

How long does AP store your data?

We retain your data for as long as necessary for the purpose(s) that it was collected. Storage of data is also determined by legal, regulatory, administrative, or operational requirements.

What are your data protection rights?

AP would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

• The right to access: You have the right to request copies of your personal data from the AP
• The right to rectification: You have the right to request that AP correct any information you believe is inaccurate. You also have the right to request AP to complete information you believe is incomplete
• The right to erasure: You have the right to request that AP erase your personal data under certain conditions.
• The right to restrict processing: You have the right to request that AP restrict the processing of your personal data, under certain conditions.
• The right to object to processing: You have the right to object to AP processing your personal data, under certain conditions
• The right to data portability: You have the right to request that AP transfers the data that we have collected to another organization, or directly to you, under certain conditions.
• The right to withdraw consent at any time: data subjects can withdraw their consent any time they wish. For example, you can withdraw your consent to the receipt of our marketing or promotional materials or unsubscribe to our newsletters

If you would like to exercise any one of these rights, please contact us via a written request, or email provided below. Kindly note that if you make a request, we have one (1) month to respond to you.

If you had given your consent for any specific purpose, you may withdraw that consent whenever you wish, without affecting the lawfulness of the processing based on the consent prior to withdrawal. If you haven’t obtained satisfaction in the exercise of your rights, you may file a complaint with the competent data protection authority.

Consent Of Minors

For the processing of the personal data of minors, the Consent of minors (under the age of 18) will always be protected and obtained from the minor’s representatives in accordance with the Nigeria Data Protection Bureau (NDPB).

Accountability

AP demonstrates accountability in line with the NDPB obligations by monitoring and continuously improving data privacy practices within AP.

Marketing

AP would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may opt-out later.

You have the right at any time to stop AP from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please unsubscribe accordingly.

Social Media Platforms

AP may interact with registered users of various social media platforms, including Facebook, Twitter, LinkedIn, and Instagram. Please note that any content you post to such social media platforms (e.g. pictures, information, or opinions), as well as any personal information that you otherwise make available to users (e.g. your profile), is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review such information carefully to better understand your rights and obligations regarding such content.

The following table contains a breakdown of lawful grounds which AP relies on for processing personal information of its Data subjects:

S/N	The purpose for collection and processing of data subject’s personal information	Collectible personal information includes, but is not limited to the ones set out below	Legal grounds for processing personal information
1	To process data subject’s order of AP’s products using any of AP’s customer engagement platforms	Contact and location details and any information relevant to the policy	The use described is required to process and facilitate the service
2	For special offers on products, services, and promotions	Contact details and any information relevant to the policy	The use described is required to process and facilitate the service
3	For feedback and research	Contact details, age of other persons included in the policy (e.g., employees, family members, etc.)	Feedback and research are conducted for service improvement purposes, in the interest of the data subject. Where sensitive personal information is provided, AP may apply for an exemption
4	To process employment for individuals on a full or temporary basis	Personal details, contact details, and any information relevant to the policy	The use described is required to process the employment of the data subject. Where sensitive personal information is provided, AP may apply for an exemption
5	To process acceptance as a vendor or supplier	Contact details and any information relevant to the policy	The use described is required to process and facilitate the services required of the data subject

Changes To This Policy

We will update this privacy policy, when necessary, to reflect changes in applicable privacy laws or regulations. If there are material changes to the policy, or in how AP will use your personal information, we will notify you to review this policy to learn how AP is protecting your personal information.

Cookies

What are Cookies?

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit www.allaboutcookies.org.

How Do We Use Cookies?

AP uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website

What types of cookies do we use?

There are several different cookies, however, our website uses:

• Functionality - AP uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies are used.
• Advertising - AP uses these cookies to collect information about your visit to our website, the content you viewed, the link you followed and information about your browser, device, and IP address. AP may sometimes share some limited aspects of this data with third parties for advertising purpose. We may also share online data collected thorough cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features maybe may not function as a result.

How To Contact Us

If you have any questions about AP’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact our Data Protection Officer. You may contact us at No. 1 AP/Conoil Road, Ijora, Lagos, Nigeria or at dpo@ardovaplc.com.