1.INTRODUCTION
                                    Welcome to Mimshack Royal Services Limited (“MIMSHACK ROYAL”) Data Protection and
                                    Privacy Policy. MIMSHACK ROYAL respects the privacy of your personal data or
                                    personal information and is committed to protecting it in accordance with the
                                    relevant laws and regulations. 
 
                                    This Data Protection and Privacy Policy (the “Policy”) informs our customers and the
                                    public (hereinafter referred to as “you”, “your” or “data subject”) as to how we use
                                    and look after your personal data, your privacy rights and how we plan to protect
                                    them.
                                    Any reference to "we", "us", "our" and “the Company” is to MIMSHACK ROYAL.
                                
2.PURPOSE OF THIS PRIVACY POLICY
                                    This Policy aims to give you information on how MIMSHACK ROYAL collects and
                                    processes your personal data when you fill/complete any of our forms, access or
                                    create an account our website as well as other mediums and platforms through which
                                    you provide us with your personal data to enable us to perform a contract with you,
                                    including providing our products and services to you. 
                                    The Policy is intended to comply with our obligations to provide you with
                                    information about the Company's processing of your personal information under the
                                    relevant laws and regulations. It neither has a contractual status nor constitutes
                                    any agreement to contract with you or provide you with our products and services.
                                    
                                    It is important that you read and retain this Policy, together with any other
                                    privacy policy or fair processing policy we may provide on specific occasions when
                                    we are collecting or processing personal data about you so that you are fully aware
                                    of how and why we are using your data. 
                                    This privacy policy supplements other notices and privacy policies and is not
                                    intended to override them.
                                
3.CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
                                    MIMSHACK ROYAL reserves the right to update this Policy at any time, and we will
                                    provide you with the revised Policy when we make any updates. 
                                    We encourage you to frequently visit our website for any changes to this Policy, to
                                    stay informed about how we are helping to protect the personal information we
                                    collect. 
                                    It is also important that the personal data we hold about you is accurate and
                                    current. In view of this, always update your personal data and keep us informed if
                                    there are changes to your personal data during your relationship with us. 
                                
4.MIMSHACK ROYAL’S DATA PROTECTION PRINCIPLES
                                    In collecting and processing your personal data, MIMSHACK ROYAL will, in compliance
                                    with the relevant laws and regulations, ensure that your personal data is: 
                                    • collected and processed in accordance with specific, legitimate, and lawful
                                    purpose consented to by you. 
                                    • adequate, accurate and without prejudice to the dignity of human person. 
                                    • stored only for the period within which it is reasonably needed; and 
                                    • secured against all foreseeable hazards and breaches such as theft, cyber- attack,
                                    viral attack, dissemination, manipulations of any kind, damage by rain, fire, or
                                    exposure to other natural elements.
                                
5.DATA CONTROL
                                    MIMSHACK ROYAL is the data controller. This means that we are responsible for
                                    deciding how we hold and use personal information about you. 
                                    MIMSHACK ROYAL shall take all necessary steps and measures to ensure that if any
                                    third party handles your personal data, such party must do so in strict compliance
                                    with the applicable laws and regulations and under a written contract.
                                
6.DATA PROTECTION OFFICER
                                    To ensure that any concerns you may have regarding the protection of your personal
                                    data are addressed sufficiently and timeously, we have appointed a Data Protection
                                    Officer (DPO) who is responsible for overseeing questions in relation to this
                                    Policy.
                                    If you have any questions about this Policy or our privacy practices, including any
                                    requests to exercise your legal rights which have been specified in this Policy,
                                    please contact the DPO using the details set out below: 
                                    • Attention: The Data Protection Officer, MIMSHACK ROYAL 
                                    • Postal address:PLOT 8 QMB Builder Mart Road, F Bus Stop, 2nd, Roundabout, Lekki,
                                    Lagos. 
                                    • Email address: support@mimshackroyal.com 
                                    • Telephone number: +234906 909 9207
                                    
                                    Without prejudice to your right to make a complaint at any time to the National
                                    Information Technology Development Agency (NITDA), the supervisory authority for
                                    data protection issues (insert email address) for any alleged breach of your data
                                    privacy rights, we would appreciate that you contact us in the first instance
                                    through the DPO if you have any concerns regarding the protection of your data or
                                    this Policy.
                                
7.THE DATA WE COLLECT ABOUT YOU
                                    Personal data, or personal information, means any information about an individual
                                    from which that person can be identified. It does not include data where the
                                    identity has been removed (anonymous data). 
                                    We may collect, use, store and transfer different kinds of personal data about you
                                    which we have grouped together as follows: 
                                    • Identity Data includes first name, maiden name, middle name, last name, username
                                    or similar identifier, marital status, title, date of birth/age and gender. 
                                    • Contact Data includes billing address, delivery address, email address and
                                    telephone numbers. 
                                    • Financial Data includes bank account and payment card details. 
                                    • Transaction Data includes details about payments to and from you and other details
                                    of products and services you have purchased from us. 
                                    • Technical Data includes internet protocol (IP) address, your login data, browser
                                    type and version, time zone setting and location, browser plug-in types and
                                    versions, operating system and platform, and other technology on the devices you use
                                    to access this website. 
                                    • Profile Data includes your username and password, requests made by you, your
                                    interests, preferences, feedback, and survey responses. 
                                    • Profile Data includes information about how you use our website, products, and
                                    services. 
                                    • Marketing and Communications Data includes your preferences in receiving marketing
                                    from us and our third parties and your communication preferences. 
                                    We do not collect any Sensitive Personal Data about you (this includes details about
                                    your race or ethnicity, religious or philosophical beliefs, sexual orientation,
                                    political opinions and views, trade union membership, information about your health,
                                    and genetic and biometric data). Nor do we collect any information about criminal
                                    convictions and offences.
                                
8.COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
9.FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, or to provide our products and our services and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (including to provide you with our products and services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
10.HOW IS YOUR PERSONAL DATA COLLECTED?
                                    We use different methods to collect data from and about you including through:
                                    
                                    • Direct interactions. You may give us your Identity, Contact and Financial Data by
                                    filling in forms, accessing or creating an account on our website, corresponding
                                    with us by post, phone, email as well as other related medium/platforms. This
                                    particularly covers personal data you provide when you apply for our products or
                                    services, give us feedback, or contact us. 
                                    • Automated technologies or interactions. As you interact with our website, we will
                                    automatically collect Technical Data about your equipment, browsing actions and
                                    patterns. We collect this personal data by using cookies, server logs and other
                                    similar technologies. We may also receive Technical Data about you if you visit
                                    other websites employing our cookies. 
                                    • Third parties or publicly available sources. We will receive personal data about
                                    you from third parties.
                                
11. HOW WE USE YOUR PERSONAL DATA
                                    We will only use your personal data when the law allows us to. Most commonly, we
                                    will use your personal data in the following circumstances: 
                                    • Performance of Contract - means processing your data where it is necessary for the
                                    performance of a contract to which you are a party (including providing our products
                                    and services) or to take steps at your request before entering such a contract. 
                                    • Compliance with legal obligation - means processing your personal data where it is
                                    necessary for compliance with a legal obligation that we are subject to. 
                                    • Legitimate Interest - means the interest of our business in conducting and
                                    managing our business to enable us to give you the best products and services and
                                    most secure experience. 
                                    • Public Interest - means where processing your data is necessary to protect your
                                    interest, the interest of another data subject or for the performance of a task
                                    carried out in the public interest or in exercise of official public mandate vested
                                    in us. 
 
                                    Generally, we rely on your consent as the legal basis for processing your personal
                                    data. This covers cases where you require us to process your personal data for the
                                    purpose of performing a contract with you or accessing our products and services
                                    including but not limited to payment for services rendered; raising a complaint for
                                    services rendered; whistleblowing and accessing any of our customer care services.
                                    
                                    We do not generally use your data for marketing purposes. However, if the need ever
                                    arises, we will get your express opt-in consent before we share your personal data
                                    with any third party for marketing purposes. 
                                    With regards to what constitutes the data subject’s consent, in accordance with the
                                    applicable laws and regulations, MIMSHACK ROYAL shall ensure that consent is freely
                                    given and is obtained without fraud, coercion or undue influence. Accordingly,
                                    MIMSHACK ROYAL would typically collect and process your personal data where you
                                    require us to fulfil a contract, including the provision of our products and
                                    services to you. 
                                    Since the performance of a contract with you and provision of our products and
                                    services to you are conditional on your consent, we shall deem that you have granted
                                    us your voluntary, free and express consent to collect and process your personal
                                    data when you fill any of our forms, access or create an account on our website,
                                    correspond with us by post, phone, email as well as other related medium/platforms
                                    in order to enable us contract with you or provide you with our products and
                                    services. Please note that you have the right to withdraw consent at any time to the
                                    processing of your personal data by contacting us.
                                
13. HOW WE USE YOUR PERSONAL DATA
                                    We will only use your personal data for the purposes for which we collected it,
                                    unless we reasonably consider that we need to use it for another reason and that
                                    reason is compatible with the original purpose. If you wish to get an explanation as
                                    to how the processing for the new purpose is compatible with the original purpose,
                                    please contact us through our DPO. 
                                    If we need to use your personal data for an unrelated purpose, we will notify you
                                    and we will explain the legal basis which allows us to do so.
                                    Please note that we may process your personal data without your knowledge or
                                    consent, in compliance with the above rules, where this is required or permitted by
                                    law.
                                
14.DISCLOSURES OF YOUR PERSONAL DATA
                                    We may share your personal data with the parties set out below for the purposes set
                                    out in the table [Purposes for which we will use your personal data] above and in
                                    compliance with the applicable laws and regulations. 
                                    • Service providers who provide IT and system administration services, revenue
                                    collection services, gateway channel services, and workforce management services.
                                    
                                    • Professional advisers including consultants, lawyers, bankers, auditors, and
                                    insurers who provide consultancy, banking, legal, insurance and accounting services.
                                    
                                    • Regulatory agencies and authorities who require reporting of processing activities
                                    in certain circumstances. 
                                    We require all third parties to respect the security of your personal data and to
                                    treat it in accordance with the law. We do not allow our third-party service
                                    providers to use your personal data for their own purposes and only permit them to
                                    process your personal data for specified purposes and in accordance with our
                                    instructions as stipulated in a written contract.
                                
15.INTERNATIONAL TRANSFER
Generally, we do not transfer your personal data outside Nigeria or to an international organisation. However, whenever there is a need to transfer your personal data out of Nigeria or to an international organisation arises, we shall ensure that we comply with the relevant laws and regulations.
16.DATA SECURITY AND PROTECTION
                                    We have put in place appropriate security measures to prevent your personal data
                                    from being accidentally lost, used, or accessed in an unauthorised way, altered, or
                                    disclosed. In addition, we limit access to your personal data to those employees,
                                    agents, contractors and other third parties who have a business need to know same.
                                    They will only process your personal data on our instructions, and they are subject
                                    to a duty of confidentiality as governed by a written contract. 
                                    We have put in place procedures to deal with any suspected personal data breach and
                                    will notify you and any applicable regulator of a breach where we are legally
                                    required to do so.
                                
17.DATA RETENTION
                                    We will only retain your personal data for as long as reasonably necessary to fulfil
                                    the purposes we collected it for, including for the purposes of satisfying any
                                    legal, regulatory, tax, accounting or reporting requirements. We may retain your
                                    personal data for a longer period in the event of a complaint or if we reasonably
                                    believe there is a prospect of litigation in respect to our relationship with you.
                                    
                                    To determine the appropriate retention period for personal data, we consider the
                                    amount, nature and sensitivity of the personal data, the potential risk of harm from
                                    unauthorised use or disclosure of your personal data, the purposes for which we
                                    process your personal data and whether we can achieve those purposes through other
                                    means, and the applicable legal, regulatory, tax, accounting, or other requirements.
                                
18.YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
                                    Under certain circumstances, you have rights under data protection laws and
                                    regulations in relation to your personal data. You have the right to the following:
                                    
                                    • Request access to your personal data (commonly known as a “Data Subject Access
                                    Request”). This enables you to receive a copy of the personal data we hold about you
                                    and to check that we are lawfully processing it. 
                                    • Request correction/rectification of the personal data that we hold about you. This
                                    enables you to have any incomplete or inaccurate data we hold about you corrected,
                                    though we may need to verify the accuracy of the new data you provide to us. 
                                    • Request erasure of your personal data. This enables you to ask us to delete or
                                    remove personal data where there is no good reason for us continuing to process it.
                                    You also have the right to ask us to delete or remove your personal data where you
                                    have successfully exercised your right to object to processing (see below), where we
                                    may have processed your information unlawfully or where we are required to erase
                                    your personal data to comply with a legal obligation in Nigeria. Note, however, that
                                    we may not always be able to comply with your request of erasure for specific legal
                                    reasons which will be notified to you, if applicable, at the time of your request.
                                    
                                    • Object to processing of your personal data where we are relying on a legitimate
                                    interest (or those of a third party) and there is something about your situation
                                    which makes you want to object to processing on this ground as you feel it impacts
                                    on your fundamental rights and freedoms. You also have the right to object to where
                                    we are processing your personal data for direct marketing purposes. In some cases,
                                    we may demonstrate that we have compelling legitimate grounds to process your
                                    information which overrides your rights and freedoms. 
                                    • Request restriction of processing of your personal data. This enables you to ask
                                    us to suspend the processing of your personal data in the following scenarios: If
                                    you want us to establish the data’s accuracy; where our use of the data is unlawful
                                    but you do not want us to erase it; where you need us to hold the data even if we no
                                    longer require it as you need it to establish, exercise or defend legal claims; and
                                    when you have objected to our use of your data but we need to verify whether we have
                                    overriding legitimate grounds to use it. 
                                    • Request the transfer (commonly known as “Data Portability”) of your personal data
                                    to you or to a third party. We will provide you, or a third party you have chosen,
                                    with your personal data in a structured, commonly used, machine-readable format.
                                    Note that this right only applies to automated information which you initially
                                    provided with your consent for us to use or where we used the information to carry
                                    out a contract with you. 
                                    • Withdraw consent at any time where we are relying on consent to process your
                                    personal data. However, this will not affect the lawfulness of any processing
                                    carried out before you withdraw your consent. If you withdraw your consent, we may
                                    not be able to provide certain products or services to you. We will advise you if
                                    this is the case at the time you withdraw your consent. Once we have received
                                    notification that you have withdrawn your consent, we will no longer process your
                                    information for the purpose or purposes you originally agreed to, unless we have
                                    another legitimate basis for doing so in law. 
                                    If you wish to exercise any of the rights set out above, that is, to review, verify,
                                    correct, or request erasure of your personal information, object to the processing
                                    of your personal data, or request that we transfer a copy of your personal
                                    information to another party, please contact the DPO.
                                
19. FEE FOR PROCESSING REQUEST & TIMELINE
                                    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 by writing to you and copying
                                    Nigerian Data Protection Bureau (NDPB). 
                                    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. 
                                    We try to respond to all legitimate requests within a reasonable time. Occasionally,
                                    it could take us a longer time if your request is particularly complex, or you have
                                    made several requests. In this case, we will notify you and keep you updated.
                                
20. BREACH
                                    In the event of a personal data breach leading to the accidental or unlawful
                                    destruction, loss, alteration, unauthorised disclosure of, or access to, personal
                                    data, MIMSHACK ROYAL shall within a reasonable time of becoming aware of the breach:
                                    
                                    • promptly assess the risk. 
                                    • promptly notify the affected data subject. 
                                    • take all necessary measures and steps to ensure that further damage is not caused
                                    by the breach. 
                                    • take all steps to retract the data (in cases of unauthorised access or
                                    disclosure); and 
                                    • if appropriate, report the breach to NITDA.
                                
21. DATA CONSENT CLAUSE
As a condition for MIMSHACK ROYAL implementing, administering, and managing the services provided, you hereby explicitly and voluntarily consent to the collection, use, processing, and storage, in electronic or other form, of the personal data provided to MIMSHACK ROYAL under and or pursuant to this Policy. You understand that the personal data could also be shared with other service providers, government bodies or regulatory authorities in Nigeria for the purpose of implementing, administering, and managing our services to you or other lawful purposes in accordance with the applicable laws. You accordingly by extension also authorize such service providers, government bodies or regulatory authorities to receive, use, process and retain such personal data, in electronic or other form, in connection with the purposes as mentioned earlier. You further acknowledge to have read, understood, and accepted the detailed rules connected with MIMSHACK ROYAL’s collection, use, processing, and storage of the personal data as detailed in this Data Protection Policy.