INTRODUCTION

This Privacy Policy (“Policy”) and any other document referred to in this Policy sets out the basis on which any Personal Data that FilmOne Limited (“FilmOne”, “we” or “us”) collects from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. If you have any comments on this Policy, please email them to info@filmoneng.com.

CONSENT

You accept this Policy and hereby give us consent to save, process and use your Personal Data to the extent as allowed by law when you provide us with details of your Personal Data or by clicking on the “accept” button. We may request for further consent in the event that your Personal Data is required to be transferred to a third party for marketing purposes or when it is to be further processed in a manner which would require your further consent.

You may withdraw your consent at any time before, during and after we process your Personal Data. Personal Data is information that can be directly used to identify you and includes but is not limited to your name, address, telephone number, email address and any other information of like nature.

We may use and transfer your Personal Data either with your consent, for compliance with a legal obligation to which we are subject or when we have assessed that it is necessary for the purposes of the legitimate interests pursued by us or by a third party to whom it may be necessary to disclose information. We may also use your Personal Data to further develop the quality of our services.

WHAT WE MAY COLLECT

We will collect and process the following data about you:

Information and Content you provide

We collect the content, communication and other information you provide to us when you use any of our services. These include when you:

fill forms, questionnaires or surveys;

enter a competition or take advantage of a promotion;

provide credit card details (such as when purchasing products from us);

contact us with an enquiry or ask us to provide you with information;

register on our website or app or leave any comments or reviews;

attend any of our promotional events;

inform us of your marketing preferences; and/or communicate with us via social media websites, third party apps or similar technologies.

Information we collect about you

With regard to each of your visits to our website, office or the use of our products, we may collect the following information:

technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type, time zone setting, browser plug-in types and versions, operating system and platform;

information about your use of our website and mobile application (including date and time), details of transactions you carry out, interaction information, record of any correspondence between us and any phone number used to call our customer service number;

information about your visit(s) from your IP address, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.

Information we receive from other sources

This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will inform you at the point of data collection, if we intend to share your data internally and combine it with data collected on http://filmhouseng.com/. We will also tell you for what purpose we will share and combine your data. We may work with third parties from time to time and shall notify when we receive information about you from them and the purposes for which we intend to use that information.

USE OF COOKIES

Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. We use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of our website. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/.

HOW WE USE YOUR PERSONAL DATA

We use information held about you in the following ways, that is to:

tailor the content we display to you;

carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;

notify you about changes to our service;

ensure that content from our product is presented in the most effective manner for you and for your computer;

administer our product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

improve our product to ensure that content is presented in the most effective manner for you and for your device;

help you to participate in interactive features of our service, when you choose to do so;

measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

make suggestions and recommendations to you and other users of our product about goods or services that may interest you or them.

We will use information provided by you to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those, which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you may unsubscribe from promotional emails via a link provided in each email.

LEGAL BASIS FOR PROCESSING OF PERSONAL DATA

We will only process your Personal Data where we have a legal basis to do so. The legal basis will depend on the purpose for which we have collected and use your Personal Data.

The legal basis for processing is any of the following:

Consent: This will apply where you have provided your consent to the processing of your Personal Data for one or more specific purposes;

Performance of Contract: This will apply where processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract with you;

Vital interests: This is where processing is required for the protection of your vital interests.

Compliance with legal obligation: Where we are subject to a legal obligation and need to use your Personal Data in order to comply with that obligation.

Public interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public.

Legitimate Interest - means the interest of our business in conducting and managing our business to enable us give you the best services and most secure experience.

PRIVACY BY DESIGN

When designing and implementing a new business or technological process involving the collection or use of Personal Data, we will take into consideration, among its other consideration, the need for structured privacy planning for this process. For example, the company will consider collecting only the types of information required for the business process in the first place.

SECURITY

We adopt robust technologies and policies to ensure the Personal Data we hold about you is suitably protected. We take steps to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We have also taken measures to comply with global Information Security Management Systems (ISMS). We therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.

DISCLOSURE OF YOUR PERSONAL DATA

We will usually not share your Personal Data with other third parties without your consent. Where we need to transfer your data to another country, such country must have an adequate data protection law. Where we need to send your data to a country without an adequate data protection law, we shall ensure that such transfer is subject only to the exceptions contained in Article 2.12 of the Nigeria Data Protection Regulation 2019.

You agree that we have the right to share your Personal Data with:

any member of our group, which means our subsidiaries, as defined under the Nigerian Companies and Allied Matters Act, Cap. C20, Laws of the Federation of Nigeria, 2004.

authorized employees of FilmOne only, for the purpose of resolving issues associated with the use of our products.

selected third parties including:

business partners, suppliers or sub-contractors for the performance of any contract we enter into with them;

advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;

analytics and search engine providers that assist us in the improvement and optimisation of our corporate and products website.

We may share your Personal Data without your consent in any of the following situations:

if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of FilmOne, our clients, or others;

where we are requested to provide information by authorized third parties or regulatory/governmental agencies investigating illegal activities;

in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets;

if FilmOne or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its clients will be one of the transferred assets;

we may hold events including seminars and conferences which are sponsored by third parties or have third party speakers. Where you register for one of these events, we may share your details with those third parties;

WHERE WE STORE YOUR PERSONAL DATA

The Personal Data that we collect from you will be transferred to and stored at destinations within Nigeria. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy.

DATA RETENTION

Your Personal Data will not be retained for longer than is necessary for the purposes for which it was processed unless a longer retention period is required or permitted by law.

YOUR RIGHTS

The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights, which do not however constitute a complete, exhaustive statement of your rights in respect of your Personal Data:

You have a right to consent to this Policy and to withdraw your consent at any time.

You have a right to a copy of the Personal Data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that Personal Data in the case of unfounded and excessive requests.

You have a right to freely transfer your Personal Data received from us to any other person.

You have the right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose by sending a mail to onlinesupport@filmhouseng.com.

In some circumstances, you have the right to the deletion of the information that we hold about you.

You have a right to lodge a complaint about the handling of your Personal Data with the National Information Technology Development Agency ("NITDA").

You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes.

You have the right to be informed about the existence of automated decision-making processes, including profiling as well as meaningful information about the logic involved, the significance and the envisaged consequences of such processing.

NITDA’s website (https://nitda.gov.ng/nit/) has a wealth of useful information in respect of your rights over your Personal Data.

If you wish to exercise your rights, you may contact the office of our Data Protection Officer at onlinesupport@filmhouseng.com

Where we do not act on your request to exercise any of your rights, we shall inform you within one month of the receipt of your request, of the reasons for not taking action and on the possibility of lodging a complaint with NITDA.

BREACH/ PRIVACY VIOLATION

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data, FilmOne shall within 72 (seventy-two) hours of having knowledge of such breach report the details of the breach to NITDA. Furthermore, Filmhouse shall within 7 (seven) days of having knowledge of the occurrence of such breach take steps to inform the Data Subject of the breach incident, the risk to the rights and freedoms of the Data Subject resulting from such breach and any course of action to remedy the said breach.

If you feel that your Personal Data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your Personal Data, you have a right to lodge a complaint with the NITDA. The contact details are:

National Information Technology Development Agency

Tel: +234929220263, +2348168401851, +2347052420189

Email: info@nitda.gov.ng

Website: www.nitda.gov.ng

CHANGES TO OUR PRIVACY POLICY

Any changes we make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to info@fimoneng.com or our offices at: 1378 Joseph Nahman Close, VI Lagos.

Her Excellency

Her Excellency

Her Excellency