Privacy Policy
Last updated
This Privacy Policy (the "Policy") sets out the basis on which Excluvia ("Excluvia", the "Company", "we", "our" or "us") collects, uses, and discloses Personal Data (as defined below) from users of this website. This Policy is governed by the applicable data protection laws of the Federal Republic of Nigeria, England and Wales, amongst others, without prejudice to any mandatory provisions of data protection laws in other jurisdictions where users may be located.
Where required, we provide jurisdiction-specific disclosures to comply with the data protection laws applicable in certain countries or regions, including but not limited to the General Data Protection Regulation (GDPR) for users in the European Union and the Nigeria Data Protection Act (NDPA) for users in Nigeria (collectively referred to as the "Data Protection Laws").
This Policy applies to consumer users (individually referred to as "You") of our website, applications, and other online services to which this Policy is posted (collectively, our "Services"). This Policy does not cover any information that we may receive about you from sources other than our website. The Website may link out to other websites or applications, but this Policy does not and will not apply to any of those linked websites or applications. We are committed to the protection of your privacy while you use our website.
This Policy is part of our Terms of Use. By accessing or using our Services, you agree to this Policy and our Terms of Use. The provisions contained in this Policy supersede all previous notices and statements regarding our privacy practices with respect to our Services. If you do not agree to every provision of this Policy and our Terms of Use, you may not access or use our Services.
By continuing to use our Services, you acknowledge that you have had the chance to review and consider this Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Policy. If you do not understand the Policy or do not agree to it, then you agree to immediately cease your use of the Website.
1. Interpretation and Definitions
1.1. Definitions
For the purposes of this Policy:
"Account" means a unique account created for you to access our Service or parts of our Service.
"Affiliate" includes our subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
"Country" means where the Data Subject is residing or located at the time of using the platform.
"Device" means any device that can access the Website, such as a computer, a cellphone, or a digital tablet.
"Personal Data" is any information that relates to an identified or identifiable individual, as defined under the Data Protection Laws.
"Service Provider" means any natural or legal person who processes the data on behalf of 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.
"Usage Data" means 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).
“User” means any natural person or representative of a legal entity who accesses, uses, or interacts with Excluvia’s website, applications, platforms, products, or services.
"Website" refers to Excluvia's platform accessible at www.excluvia.com.
"You" means the individual accessing or using our Website, or the company, or other legal entity on behalf of which such individual is accessing or using the Website, as applicable.
The above definitions shall have the same meaning regardless of whether they appear in singular or in plural.
2. Information Collection and Use
2.1. Types of Data Collected
a. Personal Data: Personal Data comprises all the details we hold or collect from You, directly or indirectly, and includes any offline or online data that makes a person identifiable. While using Our Website, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. The personally identifiable information that we collect may include, but is not limited to: names, phone numbers, usernames, passwords, and Usage Data.
b. Usage Data: Usage Data is collected automatically when using the Website. 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 Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, cookies and other diagnostic data.
When You access the Website by or through a Device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device 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.
By abiding by this Policy, we gather, store, and handle data fairly, transparently, and with respect toward individual rights.
2.2. How We Handle Your Personal Data
The Personal Data You provide to Us is:
a. Processed fairly, lawfully, and in a transparent manner.
b. Collected for a specific purpose and is not processed in a way that is incompatible with the purpose for which Excluvia collected it.
c. Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
d. Kept accurate, secure, and, where necessary, kept up to date.
e. Kept no longer than is necessary for the purposes for which the Personal Information is processed.
f. Processed in accordance with the Data Protection Laws.
Please note that Excluvia or any of its Affiliates shall not sell your Personal Data, and We also will not permit the selling of customer data by any company who provides a service to us, as our Service Providers are bound by confidentiality agreements and are obligated to process data in accordance with the Data Protection Laws.
2.3. Use of Your Personal Data
The Company may use Personal Data for the following purposes:
a. To provide and maintain our Website, including monitoring the usage of our Website.
b. For the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Website.
c. 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.
d. 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.
e. To attend and manage Your requests to Us.
f. 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.
g. 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.
h. We may use cloud storage solutions within or outside the Country to store your Personal Data. We chose Our cloud storage service provider with the aim of ensuring efficiency and improved performance through up-to-date technology.
i. Where We have a legal or regulatory obligation to use such Personal Data, for example, when our data protection regulator of the Country, requires us to maintain certain records of our dealings with You.
j. To comply with local or foreign laws, regulations, voluntary codes, directives, judgments, court orders, and agreements between Excluvia and any authority, regulator, or enforcement agency; policies (including the Excluvia's policies), good practice, government sanctions or embargoes, reporting requirements under the Country’s laws;
k. Where We need to use your Personal Data to establish, exercise or defend Our legal rights, for example when We are faced with any legal claims or where We want to pursue any legal claims ourselves;
l. Where We need to use your Personal Data for reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud, credit and anti-money laundering checks, identification checks;
m. Where We need to communicate with You to resolve complaints or other issues;
n. Where We have an appropriate legitimate business need to use your Personal Data, such as maintaining our business records and developing and improving our products and services, all whilst ensuring that such a business need does not interfere with your rights and freedoms and does not cause You any harm.
2.4. Circumstances Where We May Share Your Personal Data
We may share Your personal information in the following situations:
a. 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.
b. We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Policy.
c. 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.
d. We may disclose Your personal information for any other purpose with Your consent.
3. Methods of Collection of Personal Data
We collect Personal Information:
a. directly from you;
b. via enquiry, registration, claim forms, feedback forms and forums;
c. via cookies. You can find out more about this in our cookie policy;
d. via our telephone calls with you, which may be recorded;
e. via live chat, chatbot and profilers
f. through web analytics tags
g. third parties such as companies who provide consumer classification for marketing purposes e.g. market segmentation data.
Personal data collected is stored solely based on regulations governing each data retention period.
4. User-Generated Content (UGC)
When You upload, submit, or share content (e.g., videos, images, text) on Excluvia (‘User Content’), You retain ownership rights. However, by submitting User Content, You grant Excluvia a worldwide, non-exclusive, royalty-free license to host, store, reproduce, modify, and distribute such content solely for the purpose of operating, promoting and improving our Services. Metadata associated with User Content (e.g., timestamps, location tags) may be treated as Personal Data under this Policy.
5. Data Transfer
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 another jurisdiction where the data protection laws may differ from those in Your jurisdiction.
Please note that Your consent to this Policy followed by Your submission of such information represents Your agreement to that transfer. However, the Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Policy and 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. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards.
Where we make a transfer of your Personal Data outside the Country, in all cases where Personal Data is transferred to a country which is deemed not to have the same standards of protection for personal data as the Country, Excluvia will ensure appropriate safeguards have been implemented to ensure that your Personal Data is protected where standards are not the same or similar to those standards of the Country. We transfer Personal Data under contractual obligations to protect it up to the minimum adequate security standards. Occasionally, there may also be some circumstances where We are required to transfer your Personal Data outside of the Country and We shall rely on processing it for being necessary for the performance of your contract.
6. Third-Party Integrations (API/Logins)
Excluvia may integrate with third-party services (e.g., Google Login, PayPal) to enhance functionality. If You use these services, we may receive Personal Data (e.g., profile information, payment details) as permitted by Your settings with the third party. We do not control how third parties use Your data; review their privacy policies separately.
7. Copyright & DMCA Compliance
Excluvia respects intellectual property rights. If You believe Your copyrighted work was uploaded without permission, submit a DMCA-compliant notice to support@excluvia.com include:
a. Your contact information.
b. A description of the infringing material.
c. A statement that the claim is valid. We will respond to valid requests by removing or disabling access to the material
8. Privacy of Children
The services that we render through Our Website do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.
9. Disclosure of Your Personal Data
We might share your Personal Data with the Affiliates of the Company on a need-to-know basis and subject to confidentiality obligations.
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different policy.
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).
The Company may disclose Your Personal Data in good faith belief that such action is necessary to:
1. Comply with a legal obligation
2. Protect and defend the rights or property of the Company
3. Prevent or investigate possible wrongdoing in connection with the Service
4. Protect the personal safety of Users of the Service or the public
5. Protect against legal liability
Please note that we will not share any of your Data other than for the purposes described in this Policy. If we share anything outside of what is provided in this Policy, it will be kept strictly confidential and will only be used for the reasons that we have described.
10. 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 Policy. 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. For users who register on any of our platforms, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
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 to improve the functionality of Our Website, or We are legally obligated to retain this data for longer periods.
11. Your Rights Regarding Your Data
You can ask Us to do various things with your Personal Data. For example, at any time You can ask Us for a copy of your Personal Data, ask Us to correct mistakes, change the way We use your information, or even delete it. We will either do what You have asked or explain why We cannot - usually because of a legal or regulatory issue.
You have the following rights in relation to our use of your Personal Data as guaranteed under the Data Protection Laws.
a. The right to access your Personal Data
You are entitled to a copy of the Personal Data We hold about You and certain details of how We use it. Your Personal Data will usually be provided to You in writing unless otherwise requested. We may charge You a reasonable fee to cover the cost.
b. The right to rectification
We take reasonable steps to ensure that the Personal Data We hold about You is accurate and complete. However, if You do not believe this is the case, please contact us by using the details below, and You can ask Us to update or amend it.
c. The right to erasure
In certain circumstances, You have the right to ask Us to erase your Personal Data, for example where the Personal Data We collected is no longer necessary for the original purpose or where You withdraw your consent. However, this will need to be balanced against other factors, for example, according to the type of Personal Data We hold about You and why We have collected it, there may be some legal and regulatory obligations that preclude Us from complying with your request.
d. Right to restriction of processing
In certain circumstances, You are entitled to ask Us to stop using your Personal Data, for example, where You think that the Personal Data We hold about You may be inaccurate or where You think that We no longer need to process your Personal Data.
e. Right to data portability
In certain circumstances, You have the right to ask that We transfer any Personal Data that You have provided to Us to another third party of your choice. Once transferred, the other party will be responsible for your Personal Data.
f. The right to withdraw consent
For certain uses of your Personal Data, We will ask for your consent. Where We do this, You have the right to withdraw your consent to further use of your Personal Data. Please note that in some cases We may not be able to process your insurance if You withdraw your consent.
g. The Right to Data Portability
Creators may request a copy of their uploaded content in a machine-readable format. To initiate a data export, contact [Support Email]. Note: Shared comments or interactions with other users cannot be exported without their consent.
12. Modification and Access to Personal Data
To the extent required by Data Protection Laws, You may be able to request that We inform You about the Personal Data We maintain about You and, where appropriate, withdraw your consent for certain data processing activity and/or request that We update, correct, delete, and/or stop processing your Personal Data. We will respond to your access requests within a reasonable time and make all required updates and changes within the time specified by the Data Protection Laws.
When permitted by the Data Protection Laws, We may charge an appropriate fee to cover the costs of responding to the request. Where the timeline specified in the Data Protection Laws cannot be met, We will communicate same to You and take steps to notify You where We require an extension.
13. Protection of Personal Data
We take reasonable measures to protect Personal Data from unauthorized access, disclosure, alteration, or destruction. We have put in place strict measures and technologies to prevent fraud and intrusion.
Our employees are trained in data protection and security to respect and preserve confidentiality, integrity, and availability of information held by us.
14. 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, personal information, Excluvia shall, within 72 (seventy-two) hours of knowing about such breach, report the details of the breach to the Country’s Data Protection Commission. Furthermore, Excluvia shall within 7 (seven) days of knowing the occurrence of such breach, take steps to inform the Data Subject (as defined under the Data Protection Laws) 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 said breach.
15. Marketing
We may share information with Affiliates of Excluvia in order to inform You of other products and services that may be of interest to You, but We will only do this where You have provided Your consent. You can always change your mind by contacting us using the details below and telling Us You no longer wish to be contacted.
If you wish to unsubscribe from emails sent by Us, You may do so at any time by following the unsubscribe instructions that appear in all emails. Otherwise, You can always contact us using the details below to update your contact preferences. In such circumstances, We will continue to send You service-related (non-marketing) communications where necessary.
We would like to keep You informed, from time to time, about relevant products and services. We may do this by email, telephone or other electronic methods such as text messages. In order to help Us get to know You and identify what products and services may interest You, We obtain information about You from other sources inside and outside Excluvia, for example, companies that provide consumer classification and market segmentation data for marketing purposes.
From time to time, We may run specific marketing campaigns through social media and digital advertising that You may see, which are based on general demographics and interests. Individual personal information is not used for these campaigns. If You do not want to see any campaigns, then You will need to adjust your preferences within social media settings and your browser cookie settings.
We may also share information that We collect about You for marketing with Affiliates. If You do not want to receive such promotional materials from Us, You can opt-out at any time by sending an email to support@excluvia.com
16. Prohibited Jurisdictions
Excluvia is not available in jurisdictions where our Services may violate local laws. By using Excluvia, You confirm You are not located in such regions. VPN usage to circumvent this is prohibited.
17. Changes to this Policy
We reserve the right to modify, revise, or otherwise amend this Policy at any time and in any manner. We will notify you of any changes by posting the new Policy on this Website. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective.
You are advised to review this Policy periodically for any changes. Please note that changes to this Policy are effective when they are posted on this Website.
18. Our Contact Information
If You would like any more information about the way We use Your information, or if You wish to exercise the rights listed above, please contact us using the details below: Email: support@excluvia.com