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Privacy Policy

Privacy Policy

At Foodlocker Limited, we are committed to protecting and respecting your privacy.

This Privacy Policy together with our Website, Terms & Conditions, and any other documents referred to here set out the rules guiding the usage of the private information we collect about you. Please read carefully to understand how we treat your personal data. By providing your data to Foodlocker via our Prime program, you are accepting and consenting to this Privacy Policy.

This Privacy policy is in accordance with Nigeria Data Protection Regulation (NDPR) 2019.

Your data is processed in compliance with NDPR 2019 with the objective of discharging our duties to our Primes and customers through Foodlocker’s Prime program. The rules below apply:

We may collect and process the following data about you:

1.1 Information you give us. By registering for our Prime program you choose to give us your information. The information you give us may include your:

  1. Name
  2. Email Address
  3. Phone Number

hereinafter referred to as "Personal Data or Information"

If you do not wish to disclose your Personal Data or Information, please do not sign up for our Prime program. Without such Personal Data or Information, we would not be able to efficiently and effectively serve you through our Prime program.

1.2 Information we collect about you. For your own reference and ours, we will collect information on your purchases, your progress (level) in our Prime program, your performance, downlines, customers, revenues, earnings through the Prime program, etc.

For your visits to our websites, we may collect

  1. Technical information, including the Internet Protocol (IP) address used to connect, your login information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform
  2. Information about your visit, including the Uniform Resource Locator (URL) through which you clicked through to our websites; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We use information held about you in the following ways:

  1. To carry out our obligations to you via our Prime program
  2. To provide product information to you;
  3. To guarantee your rights under the Prime program;
  4. To comply with regulations
  5. To monitor and assure compliance by you with our policies and rules;
  6. To notify you about changes to our service
  7. To ensure that content from our site is presented in the most effective manner for you and for your computer
  8. To ensure effective management of the network of our Primes by ourselves but also by other Primes (mainly your uplines);
  9. To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and surveys
  10. To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  11. To allow you to participate in interactive features of our service, when you choose to do so;
  12. To keep our site safe and secure
  13. To respond to requests and legal demands from regulators or other authorities.

3.1 We do not sell, rent or trade your personal data.

3.2 We may give access to your information and allow its processing in strictly defined scope and purpose to selected third parties such as:

  1. Business partners: suppliers and sub-contractors for the performance of any contract we enter into with them or you. This includes among others: factoring services providers, logistics service providers, customer support services providers, third party software developers, etc.
  2. Other members of our Prime network for the purpose of effective management of our Prime program.
  3. Analytics and search engine providers that assist us in the improvement and optimization of our site.
  4. Providers of technical solutions allowing us to send to you our messages (including marketing messages or customer satisfaction surveys when you consented to receive such information) e.g. mass mailing solutions providers, mass texting solutions providers

We may also disclose your personal information to third parties:

  1. In the event that we sell, buy or in other way transfer any business or assets, in which case we may disclose your personal data to the prospective seller, buyer or acquirer of such business or assets.
  2. If our company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation

All information you provide to us and that we collect about you is stored on secure servers. All online payment transactions will be encrypted using SSL technology and will be processed by secure third party providers with PCI Level 1 Compliant Payment Systems. We do not collect or store credit and debit card information for online transactions.

The data that we collect about you may be transferred to, and stored at, a destination in or outside Nigeria. It may also be processed by staff operating outside Nigeria who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details, processing of your bonuses and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable Laws.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site (hereinafter your “Account”), you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your Account.

If you lose control of your password, you may lose substantial control over your personal data and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify us and change your password. We will never ask for your password except during the login process.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

6.1 Marketing information. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes

6.2 Access to information. Rectification and deletion. You have the right to access information held about you and to request its rectification or deletion. You can see, and review most of your personal data by signing on to your Account. Thus, it is your responsibility to notify us promptly your personal data if it changes or is inaccurate.

As a member of our Prime program, you will have access to some of the personal data of other members of our Prime program on the basis of the below provisions.

We entrust you with personal data processing in the scope and for the purpose defined in the Rules, and you agree to process these data in the manner ensuring compliance with the requirements contemplated in the NDPR 2019, and in particular compliance with rules regarding the processing and protection of the entrusted data.

The sole objective of personal data processing by you is to perform the provisions of the Rules. You are obliged in particular:

  1. To process the personal data entrusted to you by us only within the objective of data processing specified above and in compliance with the Laws
  2. Not to take any actions aimed at making the personal data further available in the manner not described herein, unless the commonly binding provisions of law stipulate otherwise,
  3. You must also ask Customers expressly whether or not they wish to receive commercial communications about Foodlocker products from you
  4. To immediately return the entrusted personal data after termination of your relationship with us (i.e. upon your deregistration as our Prime), and to remove these data from any electronic data devices on which they were recorded by you for the purpose of achievement of the objective described above

We shall have the right to terminate your Prime registration if you use the personal data in contravention of this Privacy Policy.

We are not liable for your obligations towards the third parties resulting from personal data processing in contravention of this Privacy Policy.

Our website uses cookies (small files placed on website users’ hard drive) to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. We use "cookies" to analyze the flow of information; customize the services, content and advertising; measure promotional effectiveness; and promote trust and safety.

Certain cookies contain Personal Data – for example, by clicking to “remember me” when logging in, a cookie will store the username. Most cookies will not collect information that identifies the user and will instead collect more general information such as how users arrive at and use systems, or a user’s broad location.

We offer certain services that are available only through the use of cookies. Generally, the cookies perform up to four different functions:

8.1 Essential Cookies

Some cookies are essential for the operation of the system. For example, some cookies allow us to identify registered users and ensure they can access the whole system. If a registered user opts to disable these cookies, the User may not be able to access all of the content of our system.

8.2 Performance Cookies

Other cookies may be used to analyze how the users use the systems and to monitor system performance. This allows us to provide a high-quality experience by customizing the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages. These cookies may also be used to highlight products or site services that will be of interest to the users based on their usage of the System.

8.3 Functionality Cookies

Functionality cookies are used to allow us to remember some users’ preferences.

8.4 Behaviourally-Targeted Advertising Cookies

We may use cookies to serve the Users with advertisements that are relevant to them and their interests. Foodlocker may also use third party cookies for market research, revenue tracking, improving site functionality and monitoring compliance with our policies.

8.5. Google Analytics

We use Google Analytics to understand how visitors engage with our sites and apps. This means that when you visit our website or use one of our mobile applications your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link: https://www.google.com/policies/privacy/partners/

If you don’t want the Google Analytics to be used in your browser, you can install the Google Analytics browser add-on. You can find more about the Google Analytics and Google privacy policy here.

Users are always free to decline cookies if their browser permits, although doing so may interfere with their use of some of our features. Please find detailed information on how to disable cookies here (http://www.allaboutcookies.org/manage-cookies/).

More detail on how businesses use cookies is available here (http://www.allaboutcookies.org/).

Any changes we may make to our Privacy Policy in the future will be posted on our website and, where appropriate, notified to you by e-mail or otherwise. They will be effective as of the publication date. Your use of the site subsequently to the publication of the amended Privacy Policy or a placement of order with us will be deemed acceptance of such changes

Questions, comments, complaints and requests regarding this Privacy Policy are welcomed and should be addressed to our customer service at [email protected].