Data Protection Policy

1. Introduction

Lubumi Africa is a one stop online market store where African entrepreneurs from over the world exhibit and sell their crafts and wares, ranging from food items to clothing items amongst others. As an online market, there is a need to gather and process certain information about customers who shop on the platform. In the light of the emerging data regulatory environment which requires higher transparency and accountability on how companies manage and use personal data, the Business must ensure that its operation aligns with global best practices on protection of rights and privacy of individuals.

2. Policy

The Data Protection Policy (the “Policy”) is a formal acknowledgment that the Business is committed to the protection of rights and privacy of individuals, in accordance with the Nigerian Data Protection Regulation 2019 (the “Regulation”).

3. Description

The Policy describes how the Company shall collect, handle and store personal data of customers and users of its website and its other affiliated platforms that make reference to this policy, to meet the data protection standards. This Privacy Policy is designed to inform the customer and user about the personal data the Business collects, how the data is received, the uses of the data and rights relating to the personal data when customers use this service or purchase the products offered on the website. The Company is committed to protect the personal data of its customers and users while the Business website is used. By continuing to use the Business’s website, you acknowledge that you have reviewed the privacy policy and agree to its terms of use. This also means that you have consented to the use of your personal data and you have accepted the applicable disclosures.

4. Definitions

Business/Company- Lubumi Africa.
Consent of the data subject- any freely given specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Cookies- a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. They contain various data which include but not limited to the name of the server from which it comes, the numeric identifier amongst others.
Customer/User- users of the website or any person who visit the website.
Data- characters, symbols and binary on which operations are performed by a computer which may be stored or transmitted in the form of electronic signals which is stored in any format or any device.
Database- a collection of data organized in a manner that allows access, retrieval, deletion and processing of that data; it includes but not limited to structured, unstructured, and cached and file system type databases.
Data Administrator- a persons or organization that processes data.
Data Controller- a person who either alone, jointly with other persons or in common with other persons or as a statutory body, determines the purposes for and the manner in which personal data is processed or is to be processed.
Data Subject- an identifiable person; one who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
Personal Data- any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others.
Processing- any operation or set of operations which is performed on personal data or onsets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

The purpose of this policy is to:

Protect the Company from the risks of a data breach.
Disclose how Lubumi Africa stores and processes customers’ data.
Comply with the regulation and follow international best practices.

5. Applicability

Lubumi Africa will be the data controller under the terms of the regulation- this means it is ultimately responsible for controlling the use and processing of personal data. The Company shall appoint a Data Protection Officer (DPO) for the purpose of ensuring adherence to this Regulation, relevant data privacy statements and data protection directives of the Business.

6. Personal Data required from Data Subject

6.1. Various information will be required from the Data Subject to enable the Company provide good service to all Customers, depending on how the Company services will be used, the different type types of Personal Data required include but are not limited to the following:

Name;
Home Address;
Email Address;
Phone Number

6.2. The following is used to collect Personal Data from Data Subject:

6.2.1 Cookies: The data collected by the cookies is used to offer Customers the best experience on the website. The types of cookies used are as follows:

Technical Cookies: This cookies are essential for the correct functioning of our website and to provide the services required to our users.
Profiling cookies: These cookies are used to create user profiles based on personal choices and preferences in order to send advertising messages to your device.
Third party cookies: While using the Company’s services, you may receive cookies from website managed by other organizations. Third party analytical cookies are used to detect information on user behavior on performance and improve the usability of this Website.
Support in configuring browser: Customers can manage cookie settings of browser on device. However, deleting cookies from browser may remove the preferences set for this website.

6.2.2 Log Data: Log files are used, which store automatic information collected when users visit the Company’s website. The log data which may be collected are as follows:

The domain and host from which a customer used in accessing the website.
Name of the internet service provider.
Date and time of visit.
Your computer operating system and browser software.
Web pages visited and duration and frequency of visits.
Internet protocol (IP) address.

7. Third Party Data Processing Contracts

The Company may utilize third party service providers from time to time to help in processing customers personal data and help the Company with its website. The Company shares customer’s personal data with third parties in order to protect the rights, properties or safety of the Company, the users or as otherwise required by law. The Company may disclose personal information to law enforcement agencies or institutions, third party rights owners or others in the good belief that such disclosure is reasonably necessary to enforce the Company’s Terms of Use or Privacy Policy or to respond to claims that an advertisement, posting or other content violates the rights of a third party, or protect the rights, property or personal safety of our users of the general public.

8. Storage of Personal Data

The Company takes the security of the personal data received very seriously and take reasonable measures to reduce the risk of accidental destruction, loss or unauthorized access to such information. However, please note that no electronic storage systems or the internet is completely secure. The personal data and any other information the Company have about customers may be stored for such period as the Company may determine until the customer terminate his/her account with the Company or withdraw consent. Note that customers can withdraw consent to store personal data at any time. Once this is done, all personal data and information the Company have about the customer will be deleted.

9. Purpose of Processing Personal Data

The Company collects and use the personal data that are collected for the following reasons:

To render services, maintain and make improvement to the service the Company provides.
To develop new products on the website.
To provide personalized service to customers including making recommendations and providing personalized content.
To provide analytics and measurement to understand how the Company’s service is used.

10. Protection of Personal Data

Lubumi Africa is built with strong security feature that continuously protects customer’s personal data. The security features helps to detect and block security threats. Once the Company detects any security risk, customers will be duly informed and guided through steps to stay protected.

11. Disclosure of Personal Data

The Company will not disclose customer’s personal data except for any of the following reasons:

If the customers grants the permission to do so: the Company will disclose personal data where customer’s consent and permission is granted. Such consent may be withdrawn at anytime.
For the purpose of processing customers personal data, the Company may disclose personal data to trusted businesses or persons for the purpose of processing personal data based on the Company’s instruction and in compliance with our terms of use and data protection policy.
Any other reasons as may be necessary for the operation of the Company’s website.

12. Links to Third Party Sites/Services

The website may contain links to other websites which we believe may offer useful information. The linked websites are not under our control and this privacy policy does not apply to these websites. The Company hereby suggest the customers’ contact those websites directly for information on their privacy policy, security, data collection and distribution policies.

13. Accessing, Modifying and Deleting Personal Data

Once a customer wishes to access, review, modify any information the Company has about you, you may do so by simply contacting the Company on the following email address: [email protected]. You may also request that we delete any information belonging to you that we have stored.

14. Business Transfers

The Company may in the nearest future sell or buy other business or services. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promise made in any pre-existing privacy policy (unless of course, the customer consents otherwise). Also, in the unlikely event that Lubumi Africa or substantially all of its assets are acquired, customers’ information will be one of the transferred assets.

15. Rights of Data Subject

Your rights in relation to your Personal Data are as follows:

The right to have access to your personal data.
The right to be informed about the processing of your personal data.
The right to rectify, modify or erase your personal data and any other information about you.
The right to restrict the processing of your personal data.
The right to block personal data processing in violation of any law.
The right to be informed about any rectification or erasure of personal data or restriction of any processing carried out.
The right to the portability of your personal data and
The right to lodge a complaint to a supervisory authority within Nigeria.

16. Limitation of Liability

In no event shall the Company or any of its officers, Directors, Employees or Agents be liable to you for any damages whatsoever, including without limitation, indirect incidental, special, punitive or consequential damages, arising out of or in connection with your use of the website or information gotten therewith including but not limited to the quality, accuracy or utility of the information provided as part of or through the Company’s or for any investment decision made on the basis of such information whether the damages are foreseeable and whether or not the Company has been advised of the possibility of such damages. The foregoing limitation of liability shall apply to the fullest extent permitted by law in the applicable jurisdiction and in no event shall the Company’s cumulative liability exceed the sum of Five Thousand Naira (₦5,000.00).

17. Contact Information

If you have any questions regarding this privacy policy or the personal data we collect or if you wish to make any comment or complaints about anything related to this privacy policy, please contact us at the following email address: [email protected].

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