Effective Date: 01 January 2021
Purpose and scope
Optimum Exposures Limited and its related entities protect the personal information you supply us in compliance with the Nigeria Data Protection Regulation and the National Data Protection Regulation. Optimum Exposures will collect, use, disclose and protect the personal information given or sent to us by those outside of Optimum Exposures as set out in this policy.
By visiting our website and entering into business or other dealings with us, you expressly consent to our collection, use and disclosure of your personal information as set out in this policy.
What is personal information?
In this policy, ‘personal information’ has the meaning given in the Privacy Acts and Principles. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information or an opinion, whether true or not, that Optimum Exposures collects identifies you personally, or you are reasonably identifiable from it, that information or opinion will be considered personal information – including if it is part of a database. This policy does not apply to the information we collect and hold about Optimum Exposures’ employees and former employees in the course of their employment with us.
What personal information does Optimum Exposures collect and hold?
The personal information Optimum Exposures collects may include:
your name (or internet user name), address, phone and facsimile numbers and email addresses;
your age, birth date, gender, occupation, profession or job title; information contained in your resume or CV sent to us, including employers’ and referees’ details; and your interactions with Optimum Exposures- related websites; the products and services you have enquired about or purchased from Optimum Exposures, together with any additional information needed to respond to your enquiries and deliver those products services;
information that you provide to Optimum Exposures directly through our websites or indirectly through the use of Optimum Exposures’ websites or online presence, through our representatives or otherwise;
your image or voice recording; social networking data; and
information you provide through customer surveys or visits by Optimum Exposures’ representatives from time to time.
We may also collect information that is not personal information because it does not identify you or anyone else, such as anonymous survey answers or aggregate data, including about how people use our websites.
Wherever permitted and useful, you will have the option of not identifying yourself when entering into transactions with Optimum Exposures.
How do we collect your personal information?
Optimum Exposures collects your personal information directly from you, except it is irrational or unfeasible, or by other means permitted or required under the Privacy Acts and Principles. We collect personal information that you provide us:
when you engage with our products or services, including our website and digital media platforms; over the phone, in correspondence, in person, via our websites and related social media platforms; during conversations between you and our representatives;
during any written communications between you and our representatives;
when we engage you to provide us with goods/services;
when you apply for a position with us or send us an expression of interest, directly or via a third party or third party service;
when you register to enter any competitions on our websites, social media sites or via our digital platforms or assets;
when you register your details at any of our promotional sampling events;
when you register for any of our services, including advert platforms bookings, alerts, blogs, or other subscription services; and
when conducting due diligence on entities you are affiliated with.
Optimum Exposures may also collect personal information from third parties including recruitment agencies, credit reporting agencies, law enforcement agencies and other government entities.
The majority of web browsers accept cookies automatically. You can disable cookies, but it might restrict your ability to access certain areas of our websites. We may log IP addresses (the electronic addresses of computers connected to the internet), MAC addresses, Bluetooth numbers, NFC numbers and IMEI numbers to analyse trends, administer our websites or digital platforms, track users’ online movements, and gather broad demographic information.
If tracking code is used, held or disclosed by us so that you are reasonably identifiable as a person associated with information derived through the use of that tracking code, this information will be personal information about you under this policy.
Where tracking code is used, held or disclosed by us so that you are not reasonably identifiable as a person associated with information derived through the use of that tracking code, this de-identified information is not treated as personal information under this policy.
The majority of web browsers accept cookies automatically. You can disable cookies, but it might restrict your ability to access certain areas of our websites.
Why do we collect, hold, use and disclose your personal information?
Optimum Exposures collects personal information about you in order to provide products and services to you and otherwise and to operate and administer our organisation, including for the following related purposes:
Providing products, services, deals and competitions offered by us and/or our commercial associates, partners and sponsors to you and sending communications requested by you;
Answering enquiries and providing information or advice about our business, existing and new products, assets, services and in relation to technical matters;
Providing you with access to protected areas of our websites;
Assessing the performance of our websites and digital platforms and assets and improving the operation of those websites and digital platforms and assets;
Tailoring and personalising website content and deals offered by us and/or our commercial associates, partners and sponsors, depending on your location and interests;
Conducting business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
Conducting research from time to time based on the information Optimum Exposures collects from you;
Supply of marketing lists and associated data to third parties;
Administrative, marketing (including direct marketing), recruitment, planning, product or service development, quality control and research purposes of Optimum Exposures and our contractors, service providers or other third parties;
Updating our records and keeping your contact details up to date;
Providing your updated personal information to our related bodies corporate, contractors or service providers;
Processing and responding to any complaint made by you; and
Complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
We may not be able to provide products or services request, either to the same standard or at all, or assess any application you have made to us;
We may not be able to provide you with information about products or services that you want, including discounts, sales, special promotions or competitions; or
We may be unable to tailor the content of our websites to your preferences; your experience of our websites may not be as enjoyable or useful.
To whom may Optimum Exposures disclose your information?
Optimum Exposures may disclose and transfer your personal information:
To our employees, related bodies corporate, members of our online community, contractors, or service providers located in Nigeria and overseas including without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants, for the purposes of providing services in connection with the operation of our websites or our business, fulfilling your requests or enquiries, and to otherwise provide products and services to you;
To our agents, affiliates and related bodies corporate located in Nigeria and overseas;
To suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes where you have consented; and
As required or authorised by law, including law enforcement, government or other organisations or where permitted under the Privacy Acts and Principles.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate within Nigeria.
What if Optimum Exposures shares personal information outside of Nigeria?
Optimum Exposures may disclose personal information to our services providers, related bodies corporate, agents and their service providers located overseas, for some of the purposes listed above.
Optimum Exposures will take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
Direct marketing materials
Optimum Exposures may send you direct marketing communications and information about our products and services and those of our sponsors and commercial partners that we think may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws in Nigeria. If you indicate a preference for a method of communication, Optimum Exposures will try to use that method whenever practical. At any time, you may opt-out of receiving marketing communications from us by contacting our Privacy Officer at the contact details below or by using the opt-out facilities in our marketing communications. Optimum Exposures will ensure that your name is removed from our mailing list.
Unless stated in the relevant terms and conditions, Optimum Exposures does not provide your personal information to other organisations for the purposes of allowing them to send you direct marketing.
How can you get and correct your personal information?
You have certain rights to access the personal information we hold about you. To request access or to find out what information we have about you, please contact our Privacy Officer at the details below. Where Optimum Exposures holds information that you are entitled to access, we will try to provide you with suitable means of accessing it(for example, by mailing or emailing it to you). Optimum Exposures may charge you a reasonable fee to cover our administrative and other reasonable costs in providing you the information. Optimum Exposures will not charge you for making the request, nor for making any corrections to your personal information.
Sometimes, Optimum Exposures cannot grant access to personal information (for example, if it interferes with the privacy of others or would breach confidentiality). If that happens, we will send you the written reasons for any refusal.
If we provide you with access to the personal information we hold about you, and you believe the information is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to amend it. Optimum Exposures will consider if the information requires amendment. Even if we do not agree that there are grounds for amendment, we will add a note to the personal information stating that you disagree with it.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please email a full description of the issue to our Privacy Officer at the details below. We will treat your requests or complaints confidentially. Our Privacy Officer will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options to resolve them. Optimum Exposures aims to ensure that your complaint is resolved in a timely and appropriate manner.
Optimum Exposures takes reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either hard copy or electronic form on our servers and secured third-party servers. We destroy or de-identify personal information when it is no longer needed.
As our websites are linked to the internet, and the internet is inherently insecure, however, Optimum Exposures cannot provide any assurance regarding the secure transmission of information you communicate to us online. Similarly, we cannot guarantee that information you supply will not be intercepted during its transmission over the internet. Because of this, any information you send to us online is at your own risk.
Our websites may contain links to other websites operated by third parties. Optimum Exposures makes no representations or warranties in relation to the privacy practices of any third party websites. Optimum Exposures is not responsible for the privacy policies or the content of any third party websites. Third-party websites are responsible for informing you about their own privacy practices.
For more information
If you have any questions about the content of this policy, please contact our Privacy Officer: