Treekle Privacy Policy

RetailCode Ltd ("RetailCode", "we", "our", "us") is committed to protecting personal data and respecting the rights of our data subjects (people whose personal data we collect and use) in full compliance with the relevant data protection legislation including but not limited to Nigeria Data Protection Regulation 2019 issued by Nigeria's National Information Technology Development Agency (NITDA). This Policy is a clear indication that we value the personal information entrusted to us and we respect that trust, by complying with all relevant laws, and adopting global best practices. 

Information Collection

RetailCode, its designated service provider or staff, collects data ("Personal information") that you voluntarily provide on this Website, Mobile Application or offline, which may include your name, address, email address, contact information, credit card number, billing information, password etc. In other words, RetailCode or a designated service provider or staff collects personal information when you register on this Website/App, request any of our services or products, or submit the information to participate in any product/service promotion. 

You are hereby advised not to provide information about others unless you are authorized to do so and consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting the information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

What we do with your Personal Information

We use your personal information for carefully considered business purposes including but not limited to the following:

• to provide our services and products
• to communicate with you
• to improve on our customer experience journey
• to inform you about our new services and products
• to provide ancillary support for our services and products
• to furnish you with offers and promotions about our services and products or that of other parties that may be of interest to you
• to enhance your experience with this Website/App, including to save your preference and login information
• to analyze use of the Website
• to operate our services, products, and systems properly.

We use any debit/credit card or payment information we acquire from you to activate your subscription. You may instruct us at any time not to use your personal information covered by this Privacy Policy to provide you with offers and promotions by unsubscribing. 

We will not: sell or rent your data to third parties; share your data with third parties for marketing purposes; nor expose your data to unauthorized persons in our organization.

Disclosure of Your Personal Information

RetailCode undertakes not to disclose the information provided by the users/subscribers to any person, unless such action is necessary to:

• conform to legal requirements or comply with legal process such as requests of the government, court, tribunal, authority or other regulatory agency and/or required by any law;
• protect and defend the Third Party Service Provider, Analyst or its Affiliates' rights, interests or property;
• enforce the terms and conditions under which its products and/or services are sold; or
• act to protect the interests of RetailCode and its products and services, its Affiliates, or its members, constituents or of other persons.
• operate the systems that provide our services and products properly.

RetailCode may share your personal information with our affiliates (including affiliated websites under common ownership or control) and designated service providers, including for the purposes set out in this Privacy Policy. We may share with other third parties information about our Website users, such as your use of this Website or other websites, and the services provided on this Website or other websites, but only on an unattributed and aggregate basis. We may also share your personal information (excluding security photographs) with a sponsor or other third party ("Third-Party Provider") that provides you with offers or promotions that may be of interest to you. You may instruct us at any time not to share your personal information covered by this Privacy Policy with such Third-Party Providers by unsubscribing or contacting us. Please note that (i) this opt-out process may take some time to complete, consistent with applicable law; and (ii) even after such opt-out process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites under common ownership or control) and designated service providers.

The collection, further use, and/or disclosure of your information by Third-Party Providers or by other third parties is not the responsibility of RetailCode. Rather, such collection, use, and/or disclosure is governed by the third parties' privacy policies.

Security of your Personal Information

Any personal information you provide to RetailCode is kept on secure servers. We use security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of the login ID and password you may have set up in connection with your participation in this Website's service. The users/subscribers should not to disclose their password to anyone or keep any written or other record of the password such that a third party could access it. 

Your Rights regarding your Personal Information

You have the following rights under the data protection legislations. They may not apply in all circumstances depending on your jurisdiction.  

• The right to be informed about the processing of your personal information
• The right to withdraw consent to the processing of your personal information at any time
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the "right to be forgotten")
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information ("data portability")
• The right to lodge a complaint to the Supervisory Authority (NITDA)
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

Please bear in mind that if you exercise such rights, this may affect our ability to provide our products and services. For inquiries about your personal information, please contact us by sending an email to [email protected]. Whilst we make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests as required by applicable laws and it may take some time to process your request.

Disclosure of Data Breaches

We are required, indeed obliged to report any data breaches or cyberattacks within 72 hours of our becoming aware of it.

Transfer of Your Personal Information to Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to such transfers and processing, including to and in Nigeria. 

Children's Privacy

Our Services do not address anyone under the age of 18. We do not knowingly collect personal identifiable information from children under 18 years. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

Third Party Cookies & Tracking Technologies

Cookies are files with small amount of data that is commonly used by an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer's hard drive.

RetailCode and the parties with whom we work (e.g., service providers, business partners, advertisers and advertising servers) 'may' place, view, and/or use "cookies", Web server logs, Web beacons, or other electronic tools to collect statistical and other information about your use of this Website and other websites. This information may include information about the IP address of your computer, browser type, language, operating system, your mobile device, device ID, geo-location data, the state or country from which you accessed this Website, the Web pages visited, the date and the time of a visit, the websites you visited immediately before and after visiting this Website, the number of links you click within this Website, the functions you use on this Website, the databases you view and the searches you request on this Website, the data you save on or download from this Website and the number of times you view an advertisement.

RetailCode and the parties with whom we work may use the information collected for various reasons, either on behalf of RetailCode or for the other parties' own purposes, including research, analysis, to better serve visitors to this Website (such as by enabling log-in, providing access to certain sections of this Website, providing customized content, or presenting online advertising on this Website or other websites tailored to your interests as described further below), to compile aggregate and anonymous information about usage of this Website and other websites, other statistics, etc. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information. 

To assist us with the uses described in this Privacy Policy, information collected about your use of this Website or other websites may be aggregated, analyzed or combined with personal or other information about you from other online or offline sources. If you prefer that we do not combine non-personal information that has been collected, through cookies, about your use of this Website or other websites with personal or other information about you, then please delete and disable cookies for each browser, on each computer you use to surf the Web.

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web.

Links to Third-Party Websites

We may provide links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for any information, you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

Retention of your Personal Information

Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements except you exercise your right to request deletion of personal data. 

Remedies

We will address any complaint or any violation of your privacy rights in accordance with the NDPR 2019. You are also at liberty file an action in court for redress or lodge a complaint with the National Information Technology Development Agency (NITDA).

Time Frame for Remedies

This shall be determined by a court of competent jurisdiction or the regulator as the case may be.

Data Protection Officer

The Data Protection Officer (DPO) provides independent advice and monitoring of our use of your personal information. Please contact our Data Protection Officer (DPO) on ………………... if you: wish to register a data compliance issue with us; have a question about anything in this privacy notice; think that your personal data has been misused or mishandled. You can also make a complaint to the National Information Technology Development Agency who is an independent regulator.

Review of Privacy Policy

We reserve the right to change or modify this Privacy Policy at any time in order to reflect changes in the law and/or our privacy practices. Such changes will be effective immediately after posting, whether dated or not. We encourage you to check this notice whenever you visit our website. 

Contact Us

If you have questions, suggestions or complaints regarding this Privacy Policy, please contact us by sending an e-mail to [email protected]. Please include "Privacy Policy" in the subject line of your inquiry.

Dated 1^st January 2022