Introduction

Stressfree Technology Nigeria Limited (“Stressfree”, “We”, “Us”, “Our”) is a private limited liability company duly incorporated under the Laws of the Federal Republic of Nigeria (“Territory”) that provides a range of services including aggregating independent contractors and service providers (including but not limited to beauticians, laundry, artisans and handymen), and facilitating the engagement of service providers and independent contractors by clients and for the provision of related services (our “Services”). Your data privacy and protection is important to us. This Data Privacy Policy (“Privacy Policy”) applies to Stressfree’s online interface (i.e. website, mobile application and/or social media accounts) and any affiliate or subsidiary online interface that links to this Policy, (individually referred to as a “Site”, and, collectively, “Sites”). This Policy describes how Stressfree may collect, use, and share information from or about you, and explains how information may be collected and used for advertising purposes. Please read this Privacy Policy carefully. By using our Services which we offer via the Site, you are agreeing to be bound by this Privacy Policy in respect of the information collected about you via this Site.

The information we will collect about you

This Privacy Statement applies to all personal information and data about an identifiable, living, natural person and, where it is applicable, an identifiable existing juristic person (“Personal Information”), including, but not limited to:

• your names and your images (where applicable);
• information relating to your gender, date of birth, education, and employment;
• any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the Person;
• your preferences, such as consents for marketing and other communications;
• correspondence sent by the Person that is implicitly or explicitly of a private or confidential nature, or further correspondence that would reveal the contents of the original correspondence;
• the name of the Person if it appears with other Personal Information relating to the Person or if the disclosure of the name itself would reveal information about the Person;
• and all other personal data that you share with us during your dealings with us.

How we use your personal Information

We collect personal information directly from you, and where lawful and reasonable, we may collect personal information about you from third parties and publicly available sources, such as credit reporting and government agencies for the purposes set out below:

• meet our responsibilities to you;
• follow your instructions;
• provide you with our Services;
• to manage your registration as a user of the Service;
• process your Personal Information for ordinary business purposes (including processing with respect to the use of our services, give effect to transactions and your instructions, administer claims where applicable, manage our risks and maintain our overall relationship with you);
• carry out statistical and other analysis to identify potential markets and trends, evaluate and improve our business (this includes improving existing and developing new products and services);
• tell you about available services and products;
• make sure our business and Services suits your needs;
• comply with applicable regulations;
• responding to any feedback that you send to us, resolving complaints and troubleshooting problems;
• detecting, preventing and remediating fraud or other illegal activities;
• tracking data breach and remediating such identified data breaches;
• contacting you at needed times through your provided phone number, email address or any other contact details made available to us by you.

Without your personal information, we may not be able to provide or continue to provide you with the products or services that you need.

How do we share your Personal Information?

We will only disclose your personal information if:

• the law requires it;
• we have a public duty to disclose the information;
• our or your legitimate interests require disclosure;
• you agreed that we may disclose your information.

We ask third-party service providers to agree to our privacy policies if they need access to any Personal Information to carry out their services. We will not disclose your personal information to external organisations that are not our service providers, unless you gave us your consent, or unless we are required to do so by law, or if it is necessary for the conclusion or performance of our agreement with you, and such disclosure shall be governed by a written contract between that third party and us.

How we secure your Information

Our security systems are designed to prevent loss, unauthorised destruction, damage and/or access to your personal information from unauthorised third parties. The security of your personal data is important to us. We store and process your personal information on our computers in the Territory, and where necessary transfer same outside for processing. We have information security standards which ensure that your personal data is secured against all foreseeable hazards and data breaches such as theft, cyberattacks, viral attacks, manipulations etc. We also have a data breach incident management procedure which documents our quick response to any reported personal data breach incident, and ensure all incidents are managed in accordance with legal and regulatory requirements and best practice guidelines. Where we need to transfer your data to another country, such country must have an adequate data protection law. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorisation controls.

How long do we keep your information

We retain and store personal information as long as is required for the purpose for which you have given it and as required by law. Your information is destroyed or anonymised once they are no longer required for the purpose they were collected and no statutory requirement to retain them.

Information from locations outside Nigeria

Sometimes we will process your personal information in other countries, either to carry out your instructions or for ordinary business purposes. Some countries may not have the same level of protection. If necessary, we will ask the party to whom we transfer your personal information to agree to our privacy principles, associated policies and practices.

Accuracy and update of your Information

As a user, you may:

• ask us to give you a description of your personal information that we hold;
• ask us to correct or update your personal information through our customer service channels.

We may, where a user requests for such personal information in a customized/specified format if allowed by law, charge a fee.

Your Rights

We will take note of your rights under applicable privacy and data protection laws, especially your right to object, on reasonable grounds, to certain types of processing. You have the right to query a decision that we make about a product or service that you have applied for and that was made solely by automated means. You have the right to withdraw consent previously given and lodge a complaint with the relevant regulatory authority. You have the right to contact the Data Protection Officer, report to a regulator or seek redress within the law whenever there is a violation of this policy.

Privacy of minors

Take note that you must be at least 16 years old of age to use our Services or any of our Sites.

Social Media Platforms

We operate and communicate through our designated channels, pages and accounts on some social media sites to inform, help and engage with our users. We monitor and record comments and posts made about us on these channels so that we can improve our services. The general public can access and read any information posted on these Sites. We are not responsible for any information posted on those sites other than the information posted by our designated officials. We do not endorse the social media sites themselves, or any information posted on them by third parties or other users. We do not give investment, tax or other professional advice on social media sites. You should always get independent advice before making any decisions. When you engage with us through social media your personal information may be processed by the site owner; this process is outside our control and may be in a country outside Nigeria that may have different privacy principles.

Third Party Websites

Our Sites, related Sites and mobile applications may have links to or from other Sites. Although we try to link only to Sites that also have high privacy standards, we are not responsible for their security, privacy practices or content. We recommend that you always read the privacy and security statements on these Sites.

Service Providers

We ask third-party service providers to agree to our privacy policies if they need access to any Personal Information to carry out their services.

Changes to this Policy

This Privacy Policy is subject to change. Please review it periodically. If we make changes to the Privacy Policy, we will revise the “Last Updated” date at the top of this Privacy Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy. You agree that it is your obligation to visit our Site from time to time and keep yourself abreast of any change or update that may be made to this Privacy Policy, and we are not obligated to notify you of any such change or update.

Contact Us

If you have any queries or complaints about privacy, please contact:

• Email: info.stressfreeng@gmail.com

We will ensure all complaints are resolved in a timely manner consistent with all relevant regulatory provisions.