5.     Cookie and Other Tracking Technologies

A cookie is a small text file that includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet-enabled device when you visit an on-line site. Cookies and other tracking technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”.

We also use web beacons—electronic images (or single-pixel gifs) that we use to help deliver cookies on the website. We may also use web beacons in our emails. So when we send emails to you, we may track behaviour such as who opened the emails. This allows us to measure the performance of our emails.

       i.      Withdraw Your Cookies Consent at Any Time

By consenting to this Privacy Notice, you also consent to the use of cookies on your devices. If you do not wish to accept cookies in connection with your use of our website, you may delete and block or disable cookies via your browser settings; see below for more information on how to do this. Please note that disabling cookies—especially strictly necessary cookies—will likely affect the functionality of our website.

       ii.      How to Manage and Delete Your Cookies

Most internet browsers are initially setup to automatically accept cookies.  Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you direct your browser to our website.  You can refuse to accept cookies by activating the appropriate setting on your browser. Depending on your browser, further information may be obtained via the following links:

• Firefox
• Internet Explorer
• Google Chrome
• Safari
• Opera

The information provided throughout this Privacy Notice about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of Cookies and other tracking technologies.

Change of purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6.     Disclosures of your Personal Information

We may share your Personal Information with the parties set out below for the purposes set out in the table [Purposes for which we will use your Personal Information] above.

• Internal Third Parties including our employees.
• External Third Parties including (x) service providers acting as processors based in Nigeria or any other country who provide IT and system administration services; (y) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Nigeria or any other country who provide consultancy, banking, legal, insurance and accounting services; and (z)such other third parties as may be necessary to us and the use, safety, security, and performance of the web

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

7.     International transfers

Bold Fusion is based in Nigeria and stores and processes your Personal Information on computers in Nigeria. However, please note that in order to provide a smooth and seamless digital service provision, we depend on hosting services and servers located outside Nigeria; thus, your interactions with our website may mean that your Personal Information will be stored, processed, and maintained in the ordinary course of business by our hosting providers. As a matter of course, we endeavour to ensure that foreign jurisdictions where your Personal Information is processed also have data protection legislation that is no less than the existing data protection regulations in force in Nigeria.

When you are accessing our website or services from outside Nigeria, please note that any information collected may be processed in accordance with Nigerian laws, which may be different from the laws applicable in your country of residence.

8.      Data security

We are very particular about preserving your privacy and protecting your data at Bold Fusion. Therefore, to avoid the loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction of your information, we have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

Despite this, we cannot completely guarantee the security of any information you transmit via the website, as the internet is not an entirely secure place. We have put in place procedures to deal with any suspected Personal Information breach and will notify you.

9.      Data retention

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements. We may retain your Personal Information 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.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal or regulatory.

10.  Your legal right as a Data Subject

Because we determine the purposes for and the manner in which your Personal Information may be processed, we are regarded as a data controller. Likewise, because you can be identified directly or indirectly through certain categories of data that is specific to your identity, the law regards you as a data subject.

As a data subject, the law vests you with certain rights—they include the right to:

• Request access to the Personal Information we hold about you, and request correction of such information where you believe it to be inaccurate.
• Obtain a copy of the Personal Information we hold about you.
• Restrict the processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: If you want us to establish the data’s accuracy; Should our use of the data be 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; or You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Object to the processing of your Personal Information 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Where feasible, receive all Personal Information you have provided to us—in a structured, commonly used, and machine-readable format—and to transmit the information to another data controller.
• Withdraw your consent at any time where we are relying on consent to process your Personal Information. 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.
• Request the erasure of your Personal Information (also known as the right to be forgotten.) This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, in the event your information has been processed unlawfully or where we are required to erase your Personal Information to comply with local law. 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.
• Lodge a complaint with a relevant authority, where you have reason to believe that we have violated the term(s) of this Privacy Notice. (You may lodge a complaint or seek redress from us within 30 days from the time you first detected the alleged violation.)

If you wish to exercise any of the rights set out above at any time, please send us an email at hello@boldfusion.space

No fee usually required

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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.

Time limit to respond

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

11.    Contact us

If you have any questions about this Privacy Notice or any suggestions on how we can improve its terms with respect to the Personal Information we collect, please email us at hello@boldfusion.space