This document sets forth the privacy policy of Artee Industries Limited (“Artee” or the “company”) in collecting, storing and processing Personal Data received from shoppers (“customers”) on its stores, including Spar online, Barman online and any other affiliated online stores, its employees (“employees”), its mobile App users, job applicants and other members of the general public that interacts with or uses the services of company.
For purposes of this Privacy Policy, “Personal Data” shall mean any information provided to the company that relates to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier.
Unless otherwise stated in this Privacy Policy, this policy shall be deemed to apply to Artee and its affiliated businesses, and all references to “we”, “us” and/or “our” shall refer to Artee and those affiliates.
Personal Data Collected
We may collect, process and/or store your Personal Data from a number of sources, primarily to provide products and services under our contracts with you and to improve those products and services.
Sometimes we collect data, such as name, residential address, phone number and email directly from you when you provide contact and other information to us through an Artee affiliated website (a “Site”), or mobile application (an “App”) or when you submit an application for employment or in connection with your enrollment as an employee of Artee or any of its affiliates. By voluntarily providing us with your Personal Data, you consent to our use of that information in accordance with this Privacy Policy. If you provide Personal Data to us electronically, you acknowledge and agree that such Personal Data may be transferred from their current location to offices and servers belonging to us and or our subcontractors as the case may be in order to provide our services to you, consistent with applicable law.
We may also obtain Personal Data by recording how you use our products, for example through error reports or other usage data on a Site or an App (collectively referred to as “online platforms”). When you visit any of these platforms, certain Personal Data may be collected by recording how you interact with those platforms via cookies or web beacons. Specifically, we collect:
- From Artee job applicants and employees:
We collect Personal Data from job applicants to conduct our applicant review and hiring activities. We collect Personal Data from our employees for the purposes of fulfilling our human resources obligations to our employees, such as conducting employee performance evaluations, administering payroll and benefits (and related record keeping), filing government reports, performing company network management and authentication, security, emergency notification management, and enhancing employee health and safety.
- From visitors to our websites:
- Non-identifiable Information
When you utilize a Site, we may receive certain personally non-identifiable information about your use of the Site. We may store such information ourselves or it may be included in databases owned and maintained by us, our subcontractors, agents or our business partners. We may use such information to track, for instance, the total number of visitors to the Site.
- Information collected via Cookies and Similar Technologies
We collect and/or log specific Site visitor information, which may include both non-identifiable information and Personal Data, including what kind of browser visitors are on, what operating system they are using, their IP address, cookie information, time stamp and clickstream information. This data is collected through the use of log files, “cookies,” “web beacon” or other similar technologies. “Cookies” are small files of data that may be sent to your web browser and stored on your computer. With “web beacons,” when a visitor accesses certain pages on a Site, an anonymous notice of that visit is generated which may be processed by us. Web beacons work in conjunction with cookies to let us know what portions of our Sites are of interest to you. and to help us provide you with tailored information from our Sites.
Social Media Features and Widgets
Our Sites may include social media features, such as video links, “Like” buttons, and widgets such as “Share” buttons or interactive mini-programs. These features may collect your Personal Data such as your IP address and which website page you are visiting, and may set a cookie to enable the feature to function. Social media features and widgets may be hosted by a third party or hosted directly on our Sites. Your use and interactions with these features are at your option and are governed by the published privacy policy of the companies providing them.
How we use your Personal Data
We use the Personal Data you provide to us in a manner that is consistent with the Nigerian Data Protection Regulation 2019 (the “Regulation”).
If you visit our online store: We may use your Personal Data in the manner described in Section 1 above. If you shop on a Site, your Personal Data are used for the purpose of processing your order and delivering the service you have ordered including the purchase of goods and delivery of purchased items.
If you register on our App: We may use your Personal Data to create a personal account for you to access the features of the App and to benefit from the reason the feature was provided.
Other instances of collection: We may use your Personal Data provided in circumstances other than when shopping on a Site or when using an App in connection with the reason for which it was provided; for example, to provide answers to your enquiry or complaints or diagnose a technical support issue.
Research: In our ongoing effort to better understand and serve our customers and for purposes of effective online marketing, we may conduct research on user demographics and interests based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated data with our affiliates, agents and business partners. This aggregate information does not identify you personally in any way.
Our Disclosure of Your Personal Data
Artee does not sell or rent your Personal Data to third parties for promotional purposes.
Artee and its affiliates will not use, share or distribute your Personal Data except as follows: (i) as may be necessary to provide our service to you on your request (ii) required by applicable law (iii) for employees, as described in a contract of employment (iv) or as otherwise set forth in the subsequent paragraphs of this Section directly below:
- Business Transfers: In the event of a sale, merger, reorganization, dissolution or similar event relating to all or a portion of our business, assets or a Site, Personal Data may be part of the transferred assets.
- Service providers, subcontractors, agents: We sometimes hire other companies to perform certain business-related functions. Examples include hosting and/or maintaining databases, mailing information on our behalf and processing payments. When we employ another party to perform a service or function, we may need to provide them with access to certain Personal Data. In that event, we only provide them with the information that they need to perform their specific service or function. Artee is accountable for any Personal Data that it receives from you and subsequently transfers to these third parties, in accordance with the Regulation. We remain responsible if a third-party that we engage to process Personal Data on our behalf does so in a manner inconsistent with applicable law, unless we can prove that we are not responsible for the activities or circumstances giving rise to the claim.
- Legal Requirements: We also may disclose your Personal Data if required to do so by law or in good faith where we belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of a Site or the public, or (iv) protect others against legal liability.
Access and Control of Personal Data
Visitors to Our Sites:
You will be required to provide your Personal Data at the checkout webpage on our website. You may choose to checkout as a guest without storing your Personal Data on our database or create an account with your Personal Data at checkout. You may access the information about you retained in this process by writing to Artee on the below contact details:
Artee Industries Limited
feedback@sparnigeria.com
Employees of Artee:
Artee employees should reach out to their human resources contact to understand, access, change and/or control Personal Data that has been provided to Artee in the employment context.
Job Applicants:
Job applicants should reach out to the human resources contact, as applicable, to understand, access, change and/or control Personal Data that has been provided to Artee in the job application context.
Privacy Policy Exclusions
Publicly Available Information: Please also note that any Personal Data or other information you provide to be displayed in your publicly available online profile, or post in Site forums, will be displayed for others to see and thus will not be subject to the terms of this Privacy Policy. We cannot and will not be responsible for what third parties do with any Personal Data or other information that you choose to make publicly available. As such, we advise that you exercise great care in determining what Personal Data or other information you choose to make publicly available.
Links to Other Websites:
Our Sites may frame or contain references or links to other websites not owned, operated or controlled by Artee (the “External Sites”), and their privacy policies may differ from ours. Artee is not responsible for the privacy policies and procedures of External Sites and the privacy policies and procedures we describe here do not apply to External Sites. We recommend that you read and understand the privacy policies of External Sites before using them.
Security
We utilize commercially reasonable physical, technical, and administrative controls and procedures to safeguard the Personal Data provided to Artee and protect it from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from Artee may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to us or our service providers electronically. Users of our Sites and App are responsible for maintaining the security of their passwords, user name or ID or other form of authentication needed to access secure areas or services. We may suspend your access to a Site or any of our services, without notice and pending our investigation, if we suspect a security breach in relation to you or your use thereof.
Security Breach and Remedy
We will take immediate step to remedy any security breach on our database. In line with remedying a breach of data security, we will investigate the source of the breach, assess the damage, notify person who may be affected by the breach and conduct a security audit in conjunction with a licenced Data Protection Compliance Organisation to confirm the remediation of the breach.
Retention of information:
As a customer, we will retain your Personal Data where you have opted to save the information at checkout for as long as your account is used within a period of 3 years.
As an employee, we will retain the Personal Data you have provided in the context of your employment or in the context of your use of the employee mobile App for the duration of your employment and for the period of time thereafter as may be provided by contract of employment.
Opt-Outs
If at any time after providing contact or other Personal Data to us your Personal Data changes, or if you change your mind about receiving information, (e.g., types of marketing materials, newsletters and the like) from us, or wish to change any other use of your Personal Data described above which we control, send us your request with your updated information and/or your new choices. Send your request to feedback@sparnigeria.com or by postal mail sent to Privacy Officer, 58 Town Planning Way, Ilupeju, Lagos, Nigeria. We will respond to your request to access, change or delete your Personal Data within 30 days. Of course, we will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Contacting Us with Questions:
You may contact us in the event you have questions about this Privacy Policy or any of our information practices, or if you have a question concerning the handling of your Personal Data, at: feedback@sparnigeria.com, or by postal mail sent to:
Privacy Officer
Data Team
+234 708 065 3800
58 Town Planning Way, Ilupeju, Lagos, Nigeria
Changes to Our Privacy Policy
From time to time, it may be necessary for us to make changes to this Privacy Policy. Accordingly, we reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data to us on our Sites. Your continued disclosure of Personal Data to us after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.