1. INTRODUCTION

Your privacy is important to us. It is Astymin.com.ng policy to respect your privacy regarding any information we may collect from you across our website, and URLs we own and operate under the brand Astymin, and its subsidiaries and related brands. This privacy policy explains how we process the personal data obtained from our users. By using our website, and reading this policy:

• you declare your consent for us processing your personal data for contacting purposes;
• you declare your consent for us processing your personal data for internal administrative reasons;
• you declare your consent for us processing and publishing contents uploaded as How Una Dey Do Am (HUDDA) competition/ campaign entries on our website for administrative and marketing purposes; and
• you are deemed notified of such processing

If you do not agree with the processing of your personal data, please do not provide us with your personal data via the Astymin.com.ng website.

We may update our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If you accept these terms on behalf of a third party (such as an agency client), you confirm that the third party you represent has read and understood the Terms of Service and Privacy Policy and that you’re authorized to accept them on their behalf.

2. PERSONAL DATA WE COLLECT AND HOW DO WE USE IT

We collect information by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. You are free to refuse our request for this information, with the understanding that we may be unable to provide you with some of your desired services without it. Examples of personal data that we may collect from you are the following:

• Name
• Email
• Social media profiles
• Profession
• Date of birth
• Phone/mobile number
• Home/Mailing address
• IP address

We also log “non-identifying information”. When you visit our website, our servers may automatically log the standard data provided by your web browser. This data is considered “non-identifying information”, as it does not personally identify you on its own. It may include your computer’s Internet Protocol (IP) address, your browser type and version, visited pages, the time and date of your visit, the time spent on each page, search terms, cookies, and other details. This data is kept for statistical purposes.

We may also collect data about the device you are using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your browser, and accesses each time you visit, so we can understand how visitors use our site. This helps us serve you content based on preferences you have specified.

3. MAIN PURPOSES OF PROCESSING

We may use a combination of identifying and non-identifying information to understand who our visitors are, detect errors, how they use our services, and how we may improve their experience of our website in future. It is used for organizational, administrative, marketing and internal reasons.

We use your personal data for the construction of your profile, which allows you to submit, collect, aggregate, or share (both privately and publicly) information for purposes of Promotional Competitions /Campaigns. As you use our services, we will use, collect, store, record and structure this data to improve and personalize the experience and/or features of our website.

We also use your personal data and entries uploaded/submitted by you for the Astymin’s How Una Dey Do Am Promotional Competition/Campaign for administrative and marketing purposes

However, we cannot exclude other ways of data processing, if necessary for the above mentioned purposes.

We may use your personal details to contact you with updates about our website and services.

4. SECURITY OF YOUR PERSONAL DATA

Astymin.com.ng uses a variety of security measures to keep your personal data protected from unauthorized access and disclosure. Astymin.com.ng processes your personal data based on the following principles:

• Fairness and lawfulness: we process your personal data for a determined specific purpose;
• Transparency: we process your personal data in a transparent manner,
• Purpose limitation: your personal data is processed within the purposes outlined above;
• Data minimization: we only process your personal data to the extent that is actually needed to achieve the purposes;
• Integrity and confidentiality: we secure your personal data with suitable organizational and technical measures.

However, where for the purposes of a competition or campaign, you are required to register/create an account, you are entirely responsible for maintaining the confidentiality of your password and account and for any and all activities that occur under your account(s). You agree to notify us immediately of any unauthorized use of your account(s) or any other breach of security. We will not be liable for any loss that you may incur as a result of someone else using your password(s) or account(s), either with or without your knowledge. However, you could be held liable for losses incurred by us or another party due to someone else using your account(s) or password(s). You may not use anyone else’s account(s) at any time without the permission of the account holder.

5. ACCESS TO YOUR PERSONAL DATA

Only a limited number of Fidson Healthcare Plc employees and contractors have access to your data, having signed confidentiality clauses to protect it.

We use our best efforts not to disclose any confidential information to third parties. We maintain a secure site, but you should know that computer use may be monitored by third parties such as network administrators, employers, internet providers, and operation system & internet browser vendors, and, thus, we cannot guarantee the security of information you post online. You disclose all information online at your own risk. Please remember that this website may be hosted outside your home country, and your email communications to us may be directed to a server that is hosted outside your home country. Communications over the Internet may not be secure.

We use third-party services for:

• Analytics tracking
• User authentication
• Comments
• Forms processing
• Advertising and promotion
• Content marketing
• Email marketing

These services may access our data solely for the purpose of performing specific tasks on our behalf. We do not give them permission to disclose or use any of our data for any other purpose.

We may, from time to time, allow limited access to our data by external consultants and agencies for the purpose of analysis and service improvement. This access is only permitted for as long as necessary to perform a specific function. We only work with external agencies whose privacy policies align with ours.

We will refuse government and law enforcement requests for data if we believe a request is too broad or unrelated to its stated purpose. However, we may cooperate if we believe the requested information is necessary and appropriate to comply with legal process, to protect our own rights and property, to protect the safety of the public and any person, to prevent a crime, or to prevent what we reasonably believe to be illegal, legally actionable, or unethical activity.

We do not otherwise share or supply personal information to third parties, unless it is part of a specific service of our website.

6. STORAGE/USAGE OF YOUR DATA

The personal information we collect is stored and processed in Nigeria, or where we or our partners, affiliates and third-party providers maintain facilities. We may disclose your name and email address to our marketing agency for direct marketing purposes.

We only transfer data within jurisdictions subject to data protection laws that reflect our commitment to protecting the privacy of our users.

We only retain personal information for as long as is necessary to provide a service, or to improve our services in future. While we retain this data, we will protect it within commercially acceptable means to prevent loss and theft. That said, we advise that no method of electronic transmission or storage is 100% secure, and cannot guarantee absolute data security.

Our data retention policies and procedures are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:

Usage data will be retained for a minimum period of 2 years following the date of collection, and for a maximum period of 5 years

Enquiry data will be retained for a minimum period of 1 year following the date of the enquiry, and for a maximum period of 2 years following that date;

Marketing data (newsletter sign-up, competition entry and social media lead generation) will be retained for a minimum period of 18 months, and for a maximum period of 4 years.

Notwithstanding these provisions, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

If you request your personal information be deleted, or where your personal information becomes no longer relevant to our operations, we will erase it from our system within a reasonable timeframe.

You acknowledge that personal data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

7. INTELLECTUAL PROPERTY RIGHTS

We are the owner or the authorised licensee of all intellectual property rights appearing on our Website, and in the Products, assets, content and material published on it (“Website Content’). This Website Content is protected by the laws of copyright and other intellectual property laws and treaties around the world. You may not edit or modify any aspect of the Website Content including without limitation any illustrations, photographs, video or audio sequences or any graphics contained on the Site even if it was uploaded by you.

8. THIRD PARTY PROVIDED CONTENT/LINKS

This privacy policy only covers Astymin.com.ng collection and handling of data. We only work with partners, affiliates and third-party providers whose privacy policies align with ours, however we cannot accept responsibility or liability for their respective privacy practices.

We may from time to time include links to third party websites on our Website (such as links to social media platforms like Facebook, Instagram, Tik-Tok, Youtube). The linked third party sites operate fully independent from us and have separate and independent privacy policies, which we encourage you to review when you visit those sites. This Privacy Policy only covers our Website and the How Una Dey Do Am (HUDDA) Competitions and does not cover any competitions, websites or platforms of third parties.

Please be aware that we have no control over the content and policies of those external sites linked to our site but not operated by us, and cannot accept responsibility or liability for their respective privacy practices.

9. COMPETITION/CAMPAIGN PARTICIPATION

If you choose to participate in our How Una Dey Do Am (HUDDA) Competitions/Campaign, we ask you to provide the required information, as set out in the Competition Information Page.

If you win a competition that includes the shipment of a prize, we will contact you to ask for a delivery address or provide necessary information on the delivery of the prize.

We process this information so that you are able to participate in our competitions and so that we can notify/announce you as winner online, in accordance with the terms of the competition agreed between us.

We may also use your aforementioned personal information to detect and prevent fraud and misuse of our Services.

If you contact us about our How Una Dey Do Am (HUDDA) Competitions or other related services, the forms you complete or the emails you send may include information about you, such as your name, your email address and your enquiry. We use this information to respond to your enquiries.

In line with the legitimate interest we have in promoting our business, we will process your enquiries to reply and provide you with information about the services we offer.

We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our services.

You are under no obligation to provide us with any details, but if you don’t provide all relevant information, we may not be able to help.

If you win our How Una Dey Do Am (HUDDA) competition, we may publish our username and/or the name submitted by you when entering the competition with regards to the winner publicly, such as online on our websites, social media sites, forum or other platforms and in our games. We may also publish the Competition entries uploaded/ submitted by any user on our social media sites, forum or other platforms

In certain circumstances insofar as it is reasonably necessary for the purposes set out in this privacy policy we may share your personal information and uploaded/submitted contents with carefully-selected third parties, who are engaged to help us run, manage and improve the quality of the Competitions and other services that we offer, as well as for marketing and fraud checking purposes, and/or to protect and defend our rights and property. Activities which are carried out by third party service providers may include: shipment service providers, and other selected third parties who are contracted by us to fulfill our obligations to you under our Competition Terms.

We only provide these companies with the information which they need to carry out their services for specified purposes and in accordance with our instructions, and they will not be permitted to use the information for other purposes. We require all third parties to treat your personal information as carefully and confidentially as we do and to take appropriate security measures to protect your personal information in line with our policies.

You should be aware that if we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your personal information or any other information we obtain about you, we are entitled do so.

If another company acquires us or all or some of our assets, that company will possess the same information and will assume the rights and obligations with respect to that information, in which case you will be notified via email and/or a prominent notice on the Website of any changes in ownership or use of your information, as well as any choices you may have regarding that information.

Except as set out above, we will never sell, distribute or disclose any of your personal data (except anonymous aggregate information) to any third party without your consent.

10. CHILDREN’S PRIVACY FOR COMPETITIONS

The How Una Dey Do Am Competitions are not intended for children and we do not knowingly collect data relating to children under the age of 15. The terms of our competitions prohibit users aged under 15 years from accessing our Competitions without consent of their parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us and we will delete such information within a reasonable time.

You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay in response to any requests by you:

1. To have inaccuracies in your data with us corrected. We will use reasonable efforts to the extent required by law to supply delete or correct personal information held about you on our files (and with any third parties to whom it has been disclosed to);
2. To make a complaint to a data protection regulator. If you are unhappy with the way we are processing your personal data, please let us know by contacting us via support services before taking other steps.
3. UPLOADING MATERIALS TO OUR SITE FOR COMPETITIONS/CAMPAIGNS

Whenever you make use of features that allow you to make posts on, or share or upload content to our Site, or forums or our social network sites such as entries for the How Una Dey Do Am (HUDDA) Competitions, you agree that such content will be considered non-confidential and non-proprietary, and that we have the right to:

• use, host, store, copy, distribute and disclose to third parties any such material for any purpose;
• modify, edit or create derivative works of your content so that it works better with our Services;
• distribute your content in any way and for as long as we choose in any media throughout the world even if you stop using our Site, Services and Products;
• moderate any content you submit, including a right to review, edit or remove it.

We also have the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to our site constitutes a violation of their intellectual property rights, or of their right to privacy. We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by you or any other user of our Site.

12. CONTACTING US

Feel free to contact us if you have any concerns or questions about how we handle your data and personal information.

You can contact us if you have any questions regarding this policy or the use of your data at info@fidson.com