Cabipa

Privacy Policy

Last updated: 25 February, 2025

Cabipa Nigeria Limited is committed to protecting Your privacy. This Privacy Policy explains how We collect, use, disclose, and safeguard Your information when You visit our website. Please read this policy carefully to understand Our views and practices regarding Your data.

By using Our Site and submitting any information, You acknowledge and consent to the collection, transfer, processing, storage of information, and other uses as described in Our Privacy Policy to the extent permitted by law. We recognize that information privacy is an ongoing responsibility, so We will update this Privacy Policy from time to time as We adopt new personal data practices or policies.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account: means a unique account created for You to access Our Service or parts of OurService.
  • Company: (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement)refers to Cabipa Nigeria Limited, at 39 Adeola Odeku Street, Victoria Island, Lagos.
  • Cookies: are small files that are placed on Your computer, mobile device, or any otherdevice by a website, containing the details of Your browsing history on that websiteamong its many uses.
  • Country: refers to Nigeria.
  • Device: means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
  • Personal Data: any information that relates to an identified or identifiable individual.This aligns with the Nigerian Data Protection Regulation (NDPR).
  • Service: refers to Our website and any related online services.
  • Service Provider: means any natural or legal person who processes the data on behalfof the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
  • Third-Party Social Media Service: refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data: refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website: refers to Cabipa Nigeria Limited, accessible from (www.cabipa.com.ng).
  • You: means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Individuals to Whom This Privacy Policy is Addressed

This Privacy Policy is addressed to:

  • Visitors to the Site.
  • Recipients of electronic or other communications that contain or refer to this Privacy Policy.
  • Individuals with whom Cabipa has a business relationship, such as customers, representatives of customers, and external stakeholders and their representatives.

Cabipa’s Compliance with Data Protection Laws

Cabipa is committed to collecting and using personal data in a lawful manner in accordance with the Nigerian Data Protection Regulation (NDPR) and other applicable Nigerian laws. Cabipa will ensure that when it collects or uses personal data, such collection or use is allowed under applicable data protection laws. For more information on data processing activities, the purposes of this processing, and a description of the specific personal data, please review the information in the next Section. Individuals may object to the processing of their personal data, and We will consider such objections carefully where required by law.

Collection and Use of Personal Data

This section describes the types of personal data We collect, how We use it, and the legal basis for processing it under the Nigerian Data Protection Regulation (NDPR).

Types of Data Collected

  • Personal Data: While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
    • Name: We collect Your name to personalize Your website experience and provide effective customer service. This processing is based on Our legitimate interest in providing a tailored user experience and, where applicable, for the performance of a contract (e.g., when You place an order).
    • Email Address: We collect Your email address to send You marketing communications and updates about Our products and services. We will only do this with Your explicit consent. You can withdraw Your consent at any time by contacting Us at privacy@cabipa.com.ng or by using the unsubscribe link in Our emails.
    • Phone Number: We collect Your phone number to contact You regarding Your orders and inquiries or to provide customer support. This processing is necessary for the performance of a contract and/or Our legitimate interest in providing timely and efficient customer service.
    • Location Data: If applicable, We collect Your location data to provide location-based services (e.g., suggesting nearby locations) and improve delivery efficiency. We will only collect location data with Your explicit consent, where required by law, or based on Our legitimate interests. You can withdraw Your consent at any time by adjusting Your device settings.
    • Cookies and Usage Data: We use cookies and similar technologies to collect information about Your browsing behavior on Our website. This data helps Us improve website functionality, personalize Your experience, and provide targeted advertising (with Your consent, where required). The legal basis for this processing is Your consent and Our legitimate interest in improving Our website and services.

Visitors wishing to withdraw their consent should notify Us at privacy@cabipa.com.ng, and We will stop the processing of Your personal data as soon as reasonably possible.

Usage Data

Like most websites, the Site collects certain information automatically when using the Site and stores it in log files.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic
data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile operating system, the type
of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device. We use this information to help Us design Our Site to better suit our users’ needs. We may also use Your IP address to help diagnose problems with Our server and to administer Our Site, detect potential security threats, analyze trends, track visitor movements, and gather broad demographic information that assists Us in identifying visitor preferences.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may
include:

  •  Cookies or Browser  A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Service may use Cookies.
  • Flash Cookies. Certain features of Our Service may use locally stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on Our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of Our Service and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies
    • Type: Session Cookies
    • Administered by: Us
    • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies
    • Type: Persistent Cookies
    • Administered by: Us
    • Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  •  Functionality Cookies
    • Type: Persistent Cookies
    • Administered by: Us
    • Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

For more information about the cookies We use and Your choices regarding cookies, please visit Our Cookies Policy or the Cookies section of Our Privacy Policy.

How We Use the Information We Collect

  • The Company may use Personal Data for the following purposes:
  •  To provide You with Our content and programs and to personalize Your experience;
  •  To process and fulfill Your requested transactions;
  • To provide and maintain Our Service, including monitoring the usage of Our Service.
  • To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers, and general information about other goods, services, and events that We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
  • To attend to and manage Your requests to Us.
  • To complete a transaction or order, to facilitate communication, to market and sell products and services, to deliver products/services, to bill for purchased products/services, and to provide ongoing service and support
  •  To Manage Your Account: To manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For Business Transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service users is among the assets transferred.
  • For Other Purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and evaluating and improving Our Service, products, services, marketing, and Your experience.
  • To comply with any applicable law and/or regulations.

 Legal Basis for Processing Data

Without prejudice to the principles set out in Section 5 and conditions set out in Sections 7 and 8 of the Nigeria Data Protection Regulation 2019 (NDPR 2019) and Sections 34(1)- Sections 37(1) of the Nigeria Data Protection Act 2023 (NDPA 2023), the Company reserves the lawful right to process personal data either received or submitted because of use of any of the Company’s services. Usage of any of Our services entails that at least one of the below is applicable and acts as a lawful basis to process personal data.

  • Getting consent from the Data Subject for the processing of personal data for one or more specific purposes.
  • Processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering a contract.
  • Processing is necessary for compliance with a legal obligation to which the Group is subject.
  • Processing is necessary to protect the vital interests of the Data Subject or of another natural person.
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official public mandate vested in the controller.

We may also share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of Our Service and to contact You.
  • For Business Transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Business Partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
  • With Other Users: When You share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and a description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You, and view Your profile.
  • With Your Consent: We may disclose Your personal information for any other purpose with Your consent.

 

Accountability for Onward Transfer:

Regarding the transfer of Personal Information to either an Agent or Controller, the Company strives to take reasonable and appropriate steps to:

  • Transfer such Personal Information only for specified purposes and limit the Agent or Controller’s use of that information for those specified purposes.
  • Obligate the Agent or Controller to provide at least the same level of privacy protection as is required by this Policy.
  • Help ensure that the Agent or Controller effectively processes the Personal Information in a manner consistent with its obligations under this Policy.
  • Require the Agent or Controller to notify the Group if the Agent or Controller determines it can no longer meet its obligation to provide the same level of protection as is required by this Policy, and
  • Upon notice from the Agent or Controller, take further steps to help stop and remediate any unauthorized Processing.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, adhering to the principles of data minimization and storage limitation as outlined in the NDPR. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy, followed by Your submission of such information, represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and that no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information. This includes ensuring that any international data transfers comply with the requirements of the NDPR.

Disclosure of Your Personal Data

Business Transaction

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice and comply with the applicable Nigerian law before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). This will always be done in accordance with Nigerian law.

Other legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including protection against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

Children’s Privacy

Our Service does not address minors. We do not knowingly collect personally identifiable information from minors. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from any minor without verification of parental consent, We will take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Data Subject Rights (In accordance with the NDPR)

Under the Nigerian Data Protection Regulation (NDPR), You have the following rights:

  • Right to Access: You have the right to request access to Your personal data held by us.
  • Right to Rectification: You have the right to request that We correct any inaccurate or incomplete personal data.
  • Right to Erasure (Right to be Forgotten): You have the right to request that We erase Your personal data under certain circumstances.
  • Right to Restriction of Processing: You have the right to request that We restrict the processing of Your personal data under certain circumstances.
  • Right to Data Portability: You have the right to receive Your personal data in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller.
  • Right to Object: You have the right to object to the processing of Your personal data under certain circumstances.
  • Right to Withdraw Consent: If We are processing Your personal data based on Your consent, You have the right to withdraw Your consent at any time.

To exercise any of these rights, please contact Us using the contact information provided below.

No Fee Usually Required

You will not have to pay a fee to access Your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive. Alternatively, We could refuse to comply with Your request in these circumstances.

What We May Need From You

We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access Your personal data (or to exercise any of Your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally, it could take Us longer than a month if Your request is particularly complex or if You have made a number of requests. In this case, We will notify You and keep You updated.

Accuracy of Personal Data

We endeavour to keep the personal data collected accurate and complete. We rely on the individuals to maintain the accuracy and completeness of their personal data. Please inform the Company if Your personal details change, including the context in which the personal data was provided (e.g., in connection with a specific product or service.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

We are committed to protecting Your personal data as described in this Privacy Policy and as required by applicable laws. If You have any questions about this notice or Our handling of Your personal data, or if You would like additional information, You can contact Us at: privacy@cabipa.com.ng