Privacy Policy

INTRODUCTION

Welcome to Njem. This Privacy Policy sets out how Njem uses and protects your personal data, depending on how you interface with us including when you access our website, communicate with us via any of our social media addresses, sign up for any of our newsletters, or use any of our services. Here at Njem, we care about your privacy.

We understand that it's an eyeful so we have provided our Privacy Policy in a layered format so you can click through to the specific areas set out below. That way you're able to navigate the different sections. Alternatively, you can view the full version of the Privacy Policy here.

• Types Of Personal Data We Collect from You
• How Is Your Personal Data Collected?
• How We Use Your Personal Data
• Disclosures Of Your Personal Data
• International Transfers
• Data Security
• Data Retention
• Your Legal Rights to control your Personal Data
• Contact Details
• Complaints
• Changes to the Privacy Policy and our duty to inform you of any changes
• Third Party Links

TYPES OF PERSONAL DATA WE COLLECT FROM YOU.

Personal data is any data about you, or through which you may be identified, directly or indirectly. We may collect the following types of Personal Data from you:

• Identity Data: This is data through which you may be identified. This includes your name, National Identity number, address, passport details, or any other data of this kind.
• Contact Data: includes billing address, delivery address, email address and telephone numbers.
• Financial Data: includes bank and card details. We require this data for payments on our platform, or potential refunds.
• 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, device ID and other technology on the devices you use to access this website.
• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data: includes information about how you interact with and 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 also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

HOW IS YOUR PERSONAL DATA COLLECTED?

• Digital Interaction with us: We collect your name, contact information, location or other personal information when you create an account, we also collect information relating to the actions that you perform while logged into your account. Additionally, If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. When you participate in surveys from us, we collect information that you provide through the survey. When you provide feedback or demand support, we will collect your name and email address, as well as any other content that you send to us, in order to reply.
• Use of our website: We use technology to monitor how you interact with our websites. This may include which links you click on, or information that you type into our online forms. Some of these technologies may use "cookies." Cookies are small pieces of information that a website sends to a computer's hard drive while a website is viewed. Other types of data we track include your IP address, the website that referred you to our website, and data about the device you use to visit our website. We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.
• Third Party tech for targeted advertising: We may allow third parties to place technology on our websites (e.g., a cookie or a pixel) that allows them to track you. The third party might also collect data over time and across other websites. They use this data to serve advertisements tailored to your interests, which may include advertisements about our products or services.
• Contests: When you participate in any of our raffles or contests, we collect information about you which includes contact information to notify you if you are selected.
• Partner Promotion: We collect information that you provide as part of a co-branded promotion with another company.
• Newsletters or mailing lists: When you sign up to receive information from us through mediums including but not limited to newsletters or mailing lists, we obtain your personal data for that reason.
• Job Applications: If you apply for a job posting, we collect information necessary to process your application. Providing this information is required to be considered for employment.

HOW WE USE YOUR PERSONAL DATA AND OUR LEGAL BASES FOR COLLECTING AND USING YOUR PERSONAL DATA.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we enter into with you or to provide any of our services to you in exchange for consideration.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
• Compliance with a legal obligation: We may provide your data to regulators or any governmental bodies when mandated to do so.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA, AND RETENTION PERIODS.

We have set out below, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

DIRECT MARKETING

During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Njem via Email OR You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

THIRD-PARTY MARKETING

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

OPTING OUT OF MARKETING

You can ask to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links within any marketing communication sent to you or by contacting us [Insert Link Here].

If you opt out of receiving marketing communications, you will still receive service-related communications that are necessary for administrative or customer service purposes [for example relating to order confirmations for a product/service warranty registration, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct].

COOKIES

For more information about the cookies we use and how to change your cookie preferences, please see [gonjem.com/cookies].

DISCLOSURE OF YOUR PERSONAL DATA

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.

INTERNATIONAL TRANSFERS.

Whenever we transfer your personal data out of Nigeria to countries which have laws that do not provide the same level of data protection as the Nigerian Data Protection Act and other regulatory framework, we always ensure that a similar degree of protection is afforded to it. Additionally, we will only transfer your data internationally under the following conditions:

(a) You provided and have not withdrawn consent to such transfer after having been informed of the possible risks of such transfers for the data subject due to the absence of adequate protections – By doing business with Njem, you consent to having your data transferred internationally.

(b) the transfer 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 – in order to provide the services you pay for, we may need to liaise with international third parties. These may include other service providers.

(c) the transfer is for your sole benefit and it is not reasonably practicable to obtain your consent to the transfer, and (ii) if it were reasonably practicable to obtain such consent, you would likely give it;

(d) the transfer is necessary for important reasons of public interest;

(e) the transfer is necessary for the establishment, exercise, or defense of legal claims;

(f) the transfer is necessary to protect your vital interests or the interests of other persons, where you are physically or legally incapable of giving consent.

DATA SECURITY

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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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.

RECIPIENTS OF YOUR PERSONAL DATA

In the course of our business, we may need to share your personal data with regulators and other third parties. The third parties and our reasons for sharing your data with them are listed below:

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

Details of retention periods for different aspects of your personal data are set out in the table above.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a "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 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 in certain circumstances. You can 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 local law. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see [link] for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us -see Contact details under the Contact details subheading.

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, typically for administrative costs of processing a request that 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 you have made a number of requests. In this case, we will notify you and keep you updated.

CONTACT DETAILS

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our Data Protection Team in the following ways:

• Email address: support@gonjem.com

COMPLAINTS

You have the right to make a complaint at any time to the Nigerian Data Protection Commission, or the Data Protection regulator of your Country, where you are a non-Nigerian living outside of Nigeria.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on [ May 25th, 2025 ].

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example, a new postal address or email address.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.