Privacy Policy

FOOSION PRIVACY POLICY

At Foosion, we understand that your privacy is important. We respect and value the privacy of everyone who visits www.Foosion.ng (the “Site”) or uses any of our mobile applications on their devices ("App"). We only collect and use your Data as described in this Privacy Policy (the "Policy") and as permitted by applicable data protection regulations. Please read this Policy carefully and ensure that you understand it. This Policy should be read together with our Terms and Conditions.
The Site and the App are owned and operated by Foosion; a company registered in Nigeria.
"Foosion" "we", "us" or "our"). For the purposes of the Nigerian Data Protection Regulation 2019, we are the Data Controller which means that we are responsible for determining the purposes for which and means of how your personal information (“Personal Data”) is processed.
Foosion takes its responsibilities with regard to the management of Personal Data very seriously and we do not take lightly the trust you have reposed in us, in providing us with your personal information. This Policy describes how Foosion processes your Personal Data, but it may not address all possible data processing scenarios. This Policy is a guide to help you understand:
(1). The Information We Collect
(2). How We Collect and Use Your Data
(3). Consent and Access Rights
(4). Personal Data Protection Principles;
(5). User Responsibility
(6). Data Security
(7). Link to Third Party Sites
(8). Third Party Access
(9). Violation of Privacy
(10). Marketing
(11). Transfer of Personal Data Outside the Country
(12). Data Retention
(13). How to Contact Us; and
(14). Changes to this Privacy Policy

1.1 The Information We Collect

The type of Personal Data which we collect and which may be processed by us includes but is not limited to your name, home address, email address, telephone number, date of birth, username and passwords, your account information such as your unique customer identification, payment method information, marketing preferences, complaints details, your location information including your IP address, financial information, transaction history with us, communications on the Site and the App, how you use the Site and the App, your device information, your response to advertising and direct marketing campaigns and other personal data provided by you or third parties as well as relevant information which constitute Personal Data.
1.2 Cookies
We use Cookies on the Site and the App to personalize content, ensure that you have a seamless experience when you visit the Site and the App and to improve the Site and the App. For more information on our cookie policy, please see our Terms and Conditions .

2. How We Collect and Use Your Data

2.1. Foosion may collect Personal Data from you, your authorized representatives, third parties or from publicly available sources including but not limited to, government department or agencies, public registries, social media, websites and publications.
2.2. When you send emails or other communication to Foosion, we may retain those communications for record purposes and in order to process your inquiries, respond to your requests and improve our services. When you access Foosion’s services, our servers automatically record information that your browser sends whenever you visit our Site and App..
2.3. We use the above-mentioned Personal Data for the following purposes:
(a). setting up and managing your account and to communicate with you;
(b). to comply with legal and/or regulatory requirements;
(c). improving the services that we offer you;
(d). to help us make decisions in order to prevent fraudulent and unlawful practices on the Site and the App;
(e). for our day-to-day operations and administrative purposes;
(f). providing you with marketing information and information concerning promotional offers by post, email, telephone and other means;
(g). for security and internal audit purposes including monitoring emails, mailboxes and correspondences;
(h). and to notify you about changes to our services.
And for such other purposes as may be directed or consented to by you; and for any other relevant purposes that are related to the purpose for which you submit your Personal Data to us (collectively “Purposes”).

3. Consent and Access Rights

3.1. We require your consent for the processing of your Personal Data. We shall obtain your consent for/to individual matters, where any document deals with different matters.
3.2. We can process your Personal Data in the absence of consent where:
(a). processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; ;
(b). processing is necessary for compliance with a legal obligation to which you are subject to;
(c). processing is necessary in order to protect your vital interests or that of another natural person; and;
(d). processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in us;
3.3. If we intend to use your Personal Data for a purpose which is different from the Purposes, we will seek your consent prior to the use of your Personal Data for that other purpose.
3.4. In the event of any arrangement whereby Foosion sells or transfers all, or a portion of, its business or assets (including in the event of a reorganization, dissolution or liquidation) to third parties, you hereby consent that your Personal Data held with Foosion can be transferred or assigned to third parties who may become the controllers and/or processors of your Personal Data that was held by Foosion prior to such arrangement. Foosion shall at all times ensure that you are notified when your Personal Data is intended to be transferred to third parties in the circumstances outlined in this clause.
3.5. No consent shall be sought, given or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.
3.6. Your rights:
3.6.1 You may withdraw your consent at any time and may request access to your personal information in our possession. The withdrawal of your consent shall, however, not affect the lawfulness of processing that was based on such consent before its withdrawal. You may also request that we transfer the Personal Data we hold on you to a third party, you can do this by sending a data transfer request by email to our Data Protection Officer. The request must include which Personal Data you would like to be transferred, to whom it should be transferred and by which method. Please note that we can, deny you access to the information in our possession where we determine that your request is unreasonable.
3.6.2 You can object to the processing of your Personal Data, including for marketing purposes, by contacting our Data Protection Officer. Please note that after you have objected to such processing , you can change your mind at any time by contacting us again. Your account will not be accessible while the restriction is in place.
3.6.2 You reserve the right to request the modification or amendment of your Personal Data in our possession.If you wish to delete, edit or correct any inaccurate Personal Data in the [●]section of the Site or App or any other Personal Data, please contact our Data Protection Officer by sending an email to Foosion data protection.
3.6.3 You reserve the right to require us to erase your Personal Data if (a) the Personal Data is no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent on which the processing is based; (c) you object to the processing and there are no overriding legitimate grounds for the processing; (d) the Personal Data has been unlawfully processed; and (e) the Personal Data must be erased for compliance with a legal obligation in Nigeria. You can request the erasure of your Personal Data by contacting our Data Protection Officer.
3.6.4 You reserve the right to require us to erase your Personal Data if (a) the Personal Data is no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent on which the processing is based; (c) you object to the processing and there are no overriding legitimate grounds for the processing; (d) the Personal Data has been unlawfully processed; and (e) the Personal Data must be erased for compliance with a legal obligation in Nigeria. You can request the erasure of your Personal Data by contacting our Data Protection Officer.
3.6.5 You may request for a copy of the Personal Data we hold on you in a structured, commonly used and machine readable format. Such request can be sent to our Data Protection Officer. This request is generally free. If, however, your request is repetitive or excessive, we may refuse to comply or we may charge you a fee.
3.6.6 You have the right to be informed about the existence of automated decision making including profiling and, in such cases, to be provided with meaningful information about the logic involved, the significance and the envisaged consequences of such processing. You can exercise this right by contacting our Customer Support team at: [•].
3.6.7 You reserve the right to request the modification or amendment of your personal data in our possession.
3.6.8 In all cases of access or modification/amendment of personal information, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed or modified/amended.
4. Personal Data Protection Principles
When we process your Personal Data, we are guided by the following principles, which require Personal Data to be:
(a). processed lawfully, fairly, in a transparent manner and with respect for the dignity of the human person.
(b). collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.
(c). adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
(d). accurate and where necessary kept up to date.
(e). removed or not kept in a form which permits identification of a data subject for longer than is necessary for the purposes for which the Personal Data is processed.
(f). providing you with marketing information and information concerning promotional offers by post, email, telephone and other means;
processed in a manner that ensures its security, using appropriate technical and organizational measures to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage.

5. User Responsibility

You are required to familiarize yourself with this Policy and to ensure that the information you provide to us is complete, accurate and up to date.

6. Data Security

6.1 Foosion implements and maintains appropriate safeguards to protect Personal Data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to your Personal Data.
6.2 Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting the confidentiality (i.e. that only those who need to know and are authorised to use Personal Data have access to it), integrity and availability of the Personal Data. We regularly evaluate and test the effectiveness of those safeguards to ensure security of our processing of Personal Data.
6.3 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot guarantee absolute security. Foosion, therefore, accepts no liability for any damage or loss, however caused, in connection with transmission over the Internet or electronic storage.

7. Links to third party sites

The Site and the App may contain links to other websites owned and operated by third parties. These links are provided for your information and convenience only and are not an endorsement by Foosion of the content of such linked websites or third parties. The information that we collect from you will become available to these websites if you click the link to the websites. These linked websites are neither under our control nor our responsibility. Foosion, therefore, makes no warranties or representations, express or implied about the safety of such linked websites, the third parties they are owned and operated by and the suitability or quality of information contained on them. This Policy does not apply to these websites, thus, if you decide to access these linked third party websites and/or make use of the information contained on them, you do so entirely at your own risk. Foosion accepts no liability for any damage or loss, however caused, in connection with accessing, the use of or reliance on any information, material, products or services contained on or accessed through any such linked websites. We advise that you contact those websites directly for information on their privacy policy, security, data collection and distribution policies.

8. Third Party Access

8.1. Foosion only shares Personal Data with other companies, entities or individuals in the following limited circumstances:
(a). We have your consent.
(b). We provide such information to other professional advisers or other trusted businesses or persons for the purpose of processing Personal Data on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
(c). We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Foosion , its users or the public as required or permitted by law.
8.2. Foosion is at all times, responsible for the security and appropriate use of that data as long as it remains with Foosion.

9. Violation of Privacy

9.1. We have put in place procedures to deal with any suspected Personal Data breach and will notify you of any breach to your Personal Data and will let you know the steps we have taken to remedy the breach and the security measures we have applied to render your Personal Data unintelligible.
9.2. All suspected breach of Personal Data will be remedied within 1 (one) month from the date of the report of the breach.
9.3. If you know or suspect that a Personal Data breach has occurred, you should immediately contact the Foosion team at www.foosion.ng/support.
9.4. Foosion will not be responsible for any Personal Data breach which occurs as a result of:
(a). an event which is beyond the control of Foosion;
(b). an act or threats of terrorism;
(c). an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises Foosion’s data protection measures;
(d). war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilization, requisition, or embargo;
(e). rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises Foosion’s data protection measures;
(f). the transfer of your Personal Data to a third party on your instructions; and
(g). the use of your Personal Data by a third party designated by you.

10. Marketing

You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you. We will obtain this information from you when we collect your Personal Data and will ask you what kind of communication you would like to receive from us. You can opt-out from receiving marketing communications from us at any time by following the instructions below:
(i). Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences through the “Account Details” section of the Site or the App.
(ii). SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences through the “Account Details” section of the Site or the App.
Please be aware it may take up to 28 (twenty-eight) days for your request to take effect. Please note you may still receive other important information about our product and services.

11. Transfer of Personal Data Outside the Country

We primarily store and process the Personal Data of our users in Nigeria. However, if we transfer your Personal Data outside of Nigeria, we ensure a similar degree of protection is afforded to it to safeguard your Personal Data in accordance with applicable data protection regulations in Nigeria, which can include by: (i) ensuring that your Personal Data is only processed in countries which provide adequate data protection laws (in accordance with the applicable data protection regulations in Nigeria); (ii) requiring recipients to sign up to strong contractual commitments that ensure the protection of your Personal Data; or (iii) taking any other measures that comply with the applicable data protection regulations at the time of transfer.

12. Data Retention

We will retain your Personal Data only for the period within which it is reasonably needed in order to fulfill the purpose for which it was collected, or as required by the Nigeria Data Protection Regulation 2019 as may be amended and other applicable laws..

13. How to Contact Us

For any enquiries you have in relation to this Policy, please feel free to contact our Data Protection Officer.

14. Changes to this Privacy Policy

We may, from time to time, change or update this Policy in line with legal requirements or if our business changes. All changes to this Policy will be published on the Site and the Append will become effective on publication. We will notify you when we make changes to this Policy. This Policy was last reviewed and updated on November, 2023.