Introduction

Phostine Ecommerce Limited, owner and operator of Naija Commerce, committed to safeguarding the privacy and security of users and customers. We recognize and respect the importance of maintaining the privacy of the information you provide through our website. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in compliance with the Nigeria Data Protection Commission (NDPC) guidelines. By visiting and using our website, you consent to the practices described herein.

Scope of the Privacy Policy

This Privacy Policy addresses the following areas:

• The types of information we collect from you.
• How we protect your personal information.
• How we use and share the personal information you provide.
• General information in accordance with applicable laws and regulations.

This policy does not apply to the practices of third-party entities or individuals over whom we do not have control, direct employment, or management.

1. Consent

By accessing and using our website, you agree to the terms of this Privacy Policy. You affirm that you have the legal capacity to consent to the collection and use of your personal information as described. If you do not agree with this policy, we advise you to discontinue your use of the site.

2. Collection of Personal Information

We collect personally identifiable information (such as your name, email address, phone number, physical address, location data, and banking details when you make purchases) when you create an account or engage in certain activities on our platform. While some areas of the site may be accessed without registration, other activities (such as placing an order) require registration. By providing your contact information, you authorize us to send you offers based on your interests and previous activities.

3. Use of Personal Information

We use your personal information to:

• Provide the products and services you request.
• Offer personalized recommendations and content based on your preferences.
• Resolve disputes, troubleshoot issues, and improve site functionality.
• Communicate promotional offers and updates about our products and services.
• Detect and prevent potential fraud or illegal activities.
• Analyze user behavior and preferences to enhance our product offerings.
• Enforce our terms and conditions.

Your IP address may be used to diagnose problems with our server, administer the website, and collect demographic information to tailor content to your preferences.

4. Use of Cookies

Cookies are small files that are stored on your browser to remember user preferences and enhance site performance. Phostine Ecommerce Limited uses cookies to collect information and improve your browsing experience. Cookies help us identify and track users’ activities on our site and provide personalized content. Please note that our cookies do not store personally identifiable information or sensitive data. You can choose to disable cookies through your browser settings, but this may limit your ability to use certain features on our site.

5. Data Processing Principles

Your personal data shall be collected and processed under the following principles:

• Lawful Processing: Data collection will be carried out for legitimate and lawful purposes, with your consent.
• Accuracy and Adequacy: Personal data shall be adequate, accurate, and relevant without prejudice to your dignity and rights.
• Data Retention: Data shall be stored for a period that is reasonably necessary for its purpose and secured against foreseeable hazards.
• Duty of Care: We owe a duty of care to ensure the protection of your personal information.
• Accountability: We will remain accountable for the personal information provided and ensure compliance with relevant laws.

6. Sharing of Personal Information

Phostine Ecommerce Limited may share your personal information with our affiliates and third-party partners to:

• Detect and prevent fraud and illegal activities.
• Facilitate joint or co-branded services you request.
• Comply with legal obligations, such as responding to subpoenas or court orders.

We do not permit our partners to market to you without your explicit consent. Should we merge or be acquired by another entity, your personal information will be shared with the new entity, subject to this Privacy Policy.

7. Personal Data Retention Period

Phostine Ecommerce Limited retains your personal information only as long as necessary for the purposes outlined in this policy, unless a longer retention period is required by law. Upon account closure, we will retain historical records as required by law, and further processing of your data will cease.

8. Your Privacy Rights

In accordance with the Nigeria Data Protection Commission (NDPC) guidelines and applicable laws, you have the right to:

• Access your personal information.
• Request the deletion of your personal data.
• Object to the processing of your personal information.

To exercise these rights, send an email with the subject line “Delete My Personal Data” to support@phostine.com. We will respond to your request in accordance with applicable laws.

9. Links to Other Websites

Our website may contain links to third-party websites. Phostine Ecommerce Limited is not responsible for the privacy practices or content of such external sites. We encourage you to read their privacy policies.

10. Security Precautions

We implement stringent security measures to protect your information from loss, misuse, and unauthorized access. However, no data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect your data, transmission is at your own risk. Please ensure that your account credentials are kept confidential.

11. Choice/Opt-Out

You can opt-out of receiving promotional communications by clicking the unsubscribe button in our emails. You can also update your preferences by logging into your account.

12. Advertisements

We use third-party advertising partners to display ads based on your activities on our website. These partners may use non-personally identifiable information, such as the types of pages you visit, to provide targeted advertisements that match your interests.

13. Remedies and Contact Information

If you believe that your privacy rights have been violated or have any questions about this policy, please contact us at support@phostine.com. Our Data Protection Officer will address your concerns in a timely manner.

14. Changes to the Privacy Policy

Phostine Ecommerce Limited reserves the right to update this Privacy Policy at any time without prior notice. The latest version will be posted on our website, and we encourage you to review it periodically. Changes are effective immediately upon posting.

15. Transfer of Personal Data

Phostine Ecommerce Limited may transfer your personal information to countries outside Nigeria in order to process, store, or support our business operations. Whenever your data is transferred internationally, we will ensure it is protected and transferred in compliance with the Nigeria Data Protection Commission (NDPC) regulations and other applicable data protection laws. We will use appropriate safeguards, such as standard contractual clauses, to protect your personal information during cross-border transfers.

16. Children’s Privacy

Our services are not intended for use by children under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently received personal data from a user under the age of 18, we will delete such information from our records as quickly as possible. If you believe that a child under 18 has provided us with personal information, please contact us at support@phostine.com.

17. Data Protection Officer

Phostine Ecommerce Limited has appointed a Data Protection Officer (DPO) to oversee our data protection compliance. If you have any questions, concerns, or complaints regarding our data handling practices or your rights, please reach out to the DPO via email at support@phostine.com. We will address your concerns in accordance with applicable regulations and provide you with relevant guidance.

18. Compliance with Nigeria Data Protection Commission (NDPC)

Phostine Ecommerce Limited adheres strictly to the provisions of the Nigeria Data Protection Commission (NDPC) and any other applicable data privacy laws. We are committed to ensuring that your personal information is processed lawfully, fairly, and transparently. Our compliance framework includes data protection impact assessments, continuous monitoring, and training of staff on data privacy practices. You can find more information about NDPC at Nigeria Data Protection Commission.

19. Data Subject Rights

As a data subject, you have the following rights under the Nigeria Data Protection Regulation (NDPR) and other applicable data protection laws:

• Right of Access: You have the right to access the personal data we hold about you.
• Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal information.
• Right to Erasure (“Right to be Forgotten”): You can request the deletion of your personal data under certain conditions.
• Right to Restriction of Processing: You have the right to request a restriction on the processing of your personal data.
• Right to Data Portability: You can request that your personal data be provided to you in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes.

To exercise any of these rights, contact us at support@phostine.com. We will respond to your request in compliance with applicable data protection laws.

20. Data Breach Notification

In the unlikely event of a data breach, Phostine Ecommerce Limited will promptly notify you and the Nigeria Data Protection Commission (NDPC) in accordance with the requirements of the Nigeria Data Protection Regulation (NDPR). We will provide information on the nature of the breach, the affected data categories, the steps we are taking to mitigate the impact, and recommended actions you can take to protect yourself from potential harm.

21. Legal Basis for Data Processing

Phostine Ecommerce Limited processes personal data based on one or more of the following legal grounds:

• Consent: We process your data with your explicit consent, which you may withdraw at any time.
• Contractual Necessity: Processing is necessary to fulfill the contract you have entered into with us.
• Legal Obligation: We process your data as required by applicable laws and regulations.
• Legitimate Interests: We process your data to pursue our legitimate business interests, provided it does not override your rights and freedoms.

22. How to Contact Us

If you have any questions, concerns, or comments about this Privacy Policy or our data protection practices, please contact us at:

Phostine Ecommerce Limited
Phone: +2348069041019
Email: support@naijacommerce.com

We are committed to protecting your personal information and your privacy rights.

23. Disclaimer

Although we strive to protect your personal information through stringent security measures, no method of transmission over the internet or method of electronic storage is 100% secure. While we are committed to protecting your personal data, we cannot guarantee its absolute security. By using our services, you acknowledge and agree that Phostine Ecommerce Limited, owner and operator of Naija Commerce, will not be held responsible for any unauthorized access to, or loss of, your personal data due to circumstances beyond our control.

24. Final Provisions

This Privacy Policy constitutes the entire agreement between you and Phostine Ecommerce Limited concerning the use of your personal data. Any amendments or modifications to this policy will be posted on our website, and such changes will be effective immediately upon posting.

Effective Date: 1st November 2025
Last Updated: 1st November 2025