PRIVACY POLICY

Our Privacy Policy was last updated on 3rd September, 2024.

This Privacy Policy (“Policy”) describes how Lothego collects, uses and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, and informs you about your privacy rights and how the law protects you.

We use your Personal data to provide the services we render to you. By using our online interfaces, you agree to the collection and use of information in accordance with this Privacy Policy. If you have any comments on this Policy, please email them to lothego@stemres.com

INTERPRETATION AND DEFINITIONS

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Policy:

• "Account" means a unique account created for you to access our Products or parts of our Products.
• "Company" (referred to as either "the Company", "We", "Us" or “Our" in this Agreement) refers to Lothego Limited.

For the purpose of the NDPR, the Company is the Data Controller.

• "Country" refers to Nigeria
• "Consumer", for the purpose of the NDPR means a natural person who is resident in Nigeria.
• "Cookies" are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
• "Data Controller", for the purposes of the NDPR refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• "Device" means any device that can access the Products such as a computer, a mobile phone or a digital tablet.
• "NDPR” means the Nigeria Data Protection Regulation (2019) and any amendment to it.
• “NITDA” means National Information Technology Development Agency • “Personal Data" is any information that relates to an identified or identifiable individual

For the purposes of NDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

• "Products" refers to the Company’s website and mobile application or related platforms
• "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 Products, to provide or improve the Products on behalf of the Company, to perform services related to the Products or to assist the Company in analyzing how the Products are used. For the purpose of the NDPR, Service Providers are considered Data Processors.
• "Usage Data" refers to data collected automatically, either generated by the use of the Products or from the Products’ infrastructure itself (for example, the duration of a page visit).
• "Website" refers to the Company’s website accessible from www.lothego.com

CONSENT

You hereby accept this Policy and give us consent to save, process and use your Personal Data, only to the extent allowed by law.

TYPE OF DATA COLLECTED

While using Our Products, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, ZIP/Postal code, City

We may also collect other information you provide to us when you use any of our services including those you provide when you fill forms, surveys or questionnaires, take advantage of a promotion, provide credit or debit card details, contact us with an enquiry, register an Account, attend any of our events or communicate with us via social media websites or third-party apps.

USAGE DATA

Usage Data is collected automatically when using the Products.

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 Products that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Products by or through a mobile 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.

TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on our Products and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Products. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Products. Unless you have adjusted your browser setting so that it will refuse Cookies, our Products may use Cookies.
• Web Beacons. Certain sections of our Products and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

USE OF YOUR PERSONAL DATA

The use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are:

• To run, grow and develop our business; including operating our Site and providing our services;
• To manage your Account: to manage your registration as a user of the Products;
• To build relationships with partners and academic institutions;
• To contact you: 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.
• To carry out research and statistical analysis; especially for internal administrative and auditing purposes.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests: To attend and manage your requests to Us.
• For business transfers: 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.
• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Products, for payment processing, to contact you
• For business transfers: 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.
• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with Us.
• With business partners: We may share your information with our business partners to offer You certain products, services or promotions.
• With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With your consent: We may disclose Your personal information for any other purpose with Your consent or where required to rely upon consent by local law.

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 Privacy 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.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or We are legally obligated to retain this data for longer time periods.

TRANSFER OF YOUR PERSONAL DATA

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 — and maintained on — computers located outside of your state, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy 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.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your information in the following circumstances:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
• To our service providers and business partners who assist us in operating our Website and providing services to you.
• In response to a legal request, such as a court order or government inquiry.
• If we believe disclosure is necessary to protect our rights, investigate potential violations, or prevent harm to ourselves or others.

In any case where we need to transfer your personal data to another country, such country must have an adequate data protection law actively in force. 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 internally with our employees and affiliated companies as defined under the Nigerian Companies and Allied Matters Act, Cap. C20, Laws of the Federation of Nigeria, 2004 and externally with third party service subject however to the rules of consent and confidentiality.

SECURITY OF YOUR PERSONAL DATA

The security of your Personal Data is important to us. Where you have chosen a password that allows you to access your Account or 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. However, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Email Marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards and requirements necessary to help ensure the secure handling of payment information.

NDPR PRIVACY POLICY

Legal Basis for Processing Personal Data under NDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the NDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy and by law if You are within Nigeria, to:

• Request access to your Personal Data. The rights to access updates or delete the information We have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist you.
• This also enables you to receive a copy of the Personal Data We hold about you.
• Request correction of the Personal Data that We hold about you. you have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
• Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If You withdraw your consent, We may not be able to provide you with access to certain specific functionalities of the Products.

Exercising of Your NDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, We will try our best to respond to you as soon as possible.

LINKS TO OTHER WEBSITES

Our Products may contain links to other websites that are not operated by us. If you click on a third-party link, You will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time.

We will notify you of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on our Products, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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, Filmmakers Mart on having knowledge of such breach report the details of the breach to NITDA. Furthermore, Filmmakers Mart 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

CONTACT US

If you have any questions about this Privacy Policy, You can contact us:

• By visiting this page on our website: www.lothego.com
• By sending us an email: lothego@stemres.com