Privacy policy

Effective date: October, 2024

Mealtrips Foods (“we,” “us,” or “our”) values your privacy. This Privacy Policy explains how we collect, use, disclose, and protect information that identifies you directly or indirectly (“Personal Data”) when you use our services. This policy is in line with the Nigeria Data Protection Act, 2023 and other applicable Nigerian laws.

It is very important that you read this Policy so that you are fully aware of how and why we are processing your personal data and your rights as a data subject under the Nigerian data protection regime.

Third parties to whom we outsource all or part of Personal Data Processing activities (“Processing”) must also comply with this Policy. We impose similar obligations for compliance on third parties we engage for further data processing data subjects.

Our Data Processing Principles

We process data on a fair, transparent and accountable manner in strict accordance with relevant data protection laws in Nigeria including the Nigerian Data Protection Act, 2023 or subsequent replacement or modifications thereto and ensure that your personal data:

  • Collected and processed in accordance with specific, legitimate, and/or lawful purpose consented to by you.
  • Adequate, accurate and procured without prejudice to any of your privacy rights.
  • Stored only for the period within which it is reasonably needed; and
  • Secured against all foreseeable hazards, breaches, or such other unlawful purpose such as theft, cyber-attack, viral attack, dissemination, manipulations of any kind, damage by rain, fire, or exposure to other natural elements

Data We Collect

We collect Personal Data necessary to provide our services, including:

  • Personal Identification Information: such as name, contact details, and identification numbers.
  • Financial Information: bank account details, payment card information, and billing information.
  • Technical Information: IP address, device information, and browsing behavior.

Purpose of Data Collection

We collect your data for the following purposes:

  1. To provide, personalize, and improve our services.
  2. To process transactions and send notifications about your account.
  3. To comply with regulatory obligations and enforce our agreements.
  4. To analyze website usage for system administration and development.

How we Collect Your Data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, accessing or creating an account on our website, corresponding with us by post, phone, email as well as other related medium/platforms. This particularly covers personal data you provide when you apply for our products or services, give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Data proportionality and minimization.

We will only collect the data we need for the purposes of our interaction with you and to achieve the specific objective for which you are providing the data and we will not ask for or store irrelevant personal or Sensitive data.

Limited Retention Periods

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

For data provided further contractual obligations 6 years after the last transaction further to that contract. For your account login details, we may retain user account and login details for longer periods to preserve your right to return to and use your account as you elect. You may close your account with us at any time, in which case, we shall archive your Personal Data and delete same after 3 years subject to your rights under the NDPA.

For other categories of personal data, to determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We will only collect the data we need for the purposes of our interaction with you and to achieve the specific objective for which you are providing the data and we will not ask for or store irrelevant personal or Sensitive data.

Data Subject’s Information

Your Personal Data, Sensitive Personal Data or personal information, means any information about you from which that person can be identified directly or indirectly. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, middle name, last name, username or similar identifier, marital status, title, date of birth/age and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
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  • Transaction Data includes details about payments to and from you and other details of products and serviced you have purchased from us
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

In the event that we collect any Sensitive Personal Data (i.e. details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions and views, trade union membership, information about your health, and genetic and biometric data) we shall process same in accordance with this Policy and applicable laws.

Data Subject’s Consent

Generally, we rely on your clear, unequivocal and comprehensible consent as the legal basis for processing your data. This covers cases where you require us to process your data for the purpose of performing a contract with you, or accessing our products and services, raising a complaint for clearance of faults; whistleblowing and accessing any of our customer care services.

We may, in accordance with relevant laws and this Policy, use your data in our marketing and advertising services. In such instances, we will seek your consent before we share your personal data with any third party for such purposes. With regards to what constitutes data subject’s consent, in accordance with the applicable laws and regulations, We shall ensure that consent is freely given and is obtained without fraud, coercion or undue influence.

Since the performance of a contract with you and provision of our products and services to you are conditional on your consent, we shall deem that you have granted us the free and express consent to collect and process your personal data when you fill any of our forms, access or create an account on our website, corresponding with us by post, phone, email as well as other related medium/platforms.

PLEASE NOTE THAT YOU HAVE THE RIGHT TO WITHDRAW CONSENT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA BY CONTACTING THE DPO.

Where we need to collect personal data by law, or under the terms of a contract we have with you, or to provide our products and our services and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including to provide you with our products and services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Data Confidentiality and Security

We recognise the importance of protecting data from unauthorised access and the attendant effects of data corruption hence, the company shall:

  • Develop security measures including but not limited to protecting systems from hackers and unauthorised access.
  • Activate firewalls and protect email systems and servers.
  • Store data securely with access to specific authorised individuals.
  • Develop and maintain an organisational policy for handling personal data and other sensitive or confidential data.

We have put in place reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised or illegal way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know same. They will only process your data on our instructions and they are subject to a duty of confidentiality as governed by a written contract.

We have put in place reasonable procedures to deal with any suspected data breach and will notify you, the NDPC and any applicable regulator of a breach where we are legally required to do so.

Generally, we do not transfer your personal data outside Nigeria or to an international organisation. However, whenever the need to transfer your personal data out of Nigeria or to an international organisation arises, we shall ensure that we comply with the relevant laws and regulations.

We may share your personal data with the parties set forth herein, and in compliance with the applicable laws and regulations:

  • Service providers who provide IT and system administration services, revenue collection services, electricity billing and printing services, gateway channel services, workforce management services and vending services.
  • Professional advisers including consultants, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Regulatory agencies and authorities who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions as stipulated in a written contract

Legal Basis for Processing

We process your data based on:

  1. Your consent.
  2. The necessity for the performance of a contract to which you are a party.
  3. Compliance with legal obligations.
  4. Over riding public interest.
  5. Legitimate interest.
  6. Your vital interest
  7. Legitimate business interests, except where overridden by your rights.

Data Sharing and Disclosure

We do not share your Personal Data with third parties except as necessary for:

  1. Service provision by trusted third parties who follow our privacy policies.
  2. Legal compliance, law enforcement requests, and protection against harm.
  3. Business transfers if our company or assets are acquired.

Data Subjects’ Rights

Under certain circumstances, you have rights under data protection laws and regulations in relation to your personal data. You have the right to the following:

  • Access: Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Correction: Request correction/rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Erasure: Request erasure of your personal data. You have a right to delete or remove your personal data after same has been collected by us. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with a legal obligation in Nigeria. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Objection: Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Restriction of Processing: Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request Transfer: Request the transfer (commonly known as “Data Portability”) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Consent Withdrawal: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Report: you have the right to report any concerns or potential breaches regarding the processing of your personal data. If you believe that your data protection rights have been violated or that your personal data has been misused, mishandled, or otherwise breached, you may file a complaint with us directly at dataprivacy@mealtrips.com to seek resolution. Additionally, you have the right to report the matter to the Nigerian Data Protection Commission (NDPC), which is responsible for overseeing and enforcing data protection regulations in Nigeria

To exercise any of these rights, please contact us at dataprivacy@mealtrips.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you wish to exercise any of the rights set out above, please contact us using the contact details provided herein.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request, subject to applicable laws, and in such instance, we shall furnish you with a formal notification in this regard. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within a reasonable time. Occasionally, it could take us longer time if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to Data Privacy Policy

This Policy may be updated from time to time and we shall notify you of any changes thereon via a notice on our website. It is also important that the personal data we hold about you is accurate and current. In view of this, we encourage you to always update your personal data and keep us informed if there are changes to your personal data during your relationship with us.

Cookies

We use cookies and similar tracking technologies to enhance your experience. You may set your browser to refuse cookies, but this may affect your access to certain services.

No Automated Decision Making

We do not use automated decision-making processes, including profiling, that have legal or similarly significant effects on you. All decisions regarding your personal data are made through human intervention.

If you believe that you have been subject to any automated decision-making on our Platform, you have the right to object to such processing. You may request a review of the decision by a human by contacting us directly at dataprivacy@mealtrips.com We will investigate and ensure that any automated processing, if identified, is reviewed with human oversight.

Links to Third-Party Sites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at:

Email: dataprivacy@mealtrips.com

Address: Railway Market Road, Makurdi, Benue State

Phone: 07057635407

Mealtrips Foods Ltd is limited liability company registered and existing under the laws of the federal republic of Nigeria.

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