PRIVACY POLICY

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract between you and HUNCHOGADGET.
• Where you provide consent. You have the right to withdraw consent to marketing at any time by contacting us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

We may process your personal data for any of the purposes below

• To process your registration on the Platform.
• To allow us to better serve you in responding to your customer service requests.
• To quickly process your transactions.
• To follow up with you after correspondence (email or phone inquiries).
• To help us develop the Platform and our services.
• To provide your information to our customer service agents for research and analysis purposes so that we can monitor and improve the services we provide. We or our agents and sub-contractors may contact you by post, e-mail or telephone to ask you for your feedback and comments on our services.
• To provide you with information about special features of our App or any other service or products we think may be of interest to you.
• To provide you with related information from third parties we think may be of interest to you.
• To provide your information to carefully selected third parties whose products or services we believe may be of interest to you. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. We seek to protect the integrity of our site and welcome any feedback about these sites.

We will only use your personal data for the purposes for which we have collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Law.

We may share your personal data with certain third parties without further notice to you, in certain instances. We have set out some of the instances below:

• Related Companies: We may share your personal data with our related companies for purposes consistent with this Policy.
• Agents, Consultants and Related Third Parties: HUNCHOGADGET may engage other companies and professionals within and outside Nigeria to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another entity to perform a function of this nature, we will only provide them with the information that they need to perform their specific function.
• Legal Requirements: HUNCHOGADGET may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of HUNCHOGADGET, (iii) act in urgent circumstances to protect the personal safety of users of the services or the public, or (iv) protect against legal liability.
• Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In operating the Platform, we may use a technology called "cookies". A cookie is a piece of information that the computer that hosts our Website gives to your browser when you access the Website. Our cookies help provide additional functionality to the Website and help us analyze Website usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission or use information gathered for tracking purposes.

We have put in place various appropriate security procedures as set out in this policy, to prevent your personal data from being lost, used or accessed without authorization.

Our Platform is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Platform as safe as possible.

We use regular malware scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who need to know. They have special access rights to such systems and are required to only process your personal data on our instruction and to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data; see your legal rights below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under the Applicable Laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate basis to process your information which overrides your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate basis to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdrew your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdrew your consent.

If you wish to exercise any of the rights set out above, please contact us.

In the case of a breach of any of the obligations with respect to your personal data, a data breach procedure is established and maintained in order to deal with incidents concerning personal data or privacy practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. On notification of such breach, Hunchogadget will investigate to determine if an actual breach has occurred and Hunchogadget will take such actions required to manage such breach.

In the event you believe we have breached any applicable law or this Policy, you have the right to file a complaint with the Nigeria Data Protection Commission. You may however contact our Data Protection Officer to enable us rectify such breach as soon as possible.

You can contact us at our office at ADEDOYIN CLOSE, MILLENIUM ESTATE, GBAGADA- 8909938, Lagos State, Nigeria or through our phone +2348156772152 or our email admin@hunchogadgets.com. You may contact our Data Protection Officer via esther.ajogi@tenece.com