PRIVACY POLICY OF KWALE HYDROCARBON NIGERIA LIMITED

This document constitutes the privacy policy (hereinafter referred to as “KHNL’s Privacy Policy” or “Policy”) of Kwale Hydrocarbon Nigeria Limited (hereinafter referred to as “KHNL” or the “Company”), a company having its registered office at 10, Maryland Business Plaza, Ikorodu Road, Lagos, Nigeria and a business office at No.252E, Muri Okunola Street, Victoria Island, Lagos, Nigeria.

KHNL (which term shall in the context of this Policy include its subsidiaries, affiliates, and related entities) shall collect information about a user of the Company’s Website, mobile applications, Software, and Services when such user of Services (“User”) utilises or avails of its Services and through other interactions and/or communications which such User has with the Company.

The Company is committed to ensuring that the User’s privacy is protected. Should the Company ask the User to provide certain information by which the User can be identified, the User can be assured that it will only be used in accordance with this Policy only.

The Company may change the Policy from time to time and the User is required to check the latest Policy accessible at www.khnl-ng.com from time to time to be up to date with the provisions of this Policy. This Policy is effective from 19th August, 2020 unless otherwise amended or replaced.

1 SCOPE OF PRIVACY POLICY

This Privacy Policy is incorporated into KHNL’s Terms and Conditions of Seller’s Website & Services Usage Agreement (“Terms of Service”), located at www.khnl-ng.com , and applies to the all the information (“Information”) obtained by the Company through the User’s use of KHNL’s Services.

Capitalised terms used in this Policy and not otherwise defined shall have the meanings provided for those terms in the Terms of Service.


2 COLLECTION& USE OF INFORMATION

2.1 The Company collects Information that the User provides directly to the Company, such as when the User creates or modifies its account, requests on-demand services, contacts customer support, or otherwise communicates with the Company. This information may include name, email address, phone number, postal address, payment method, delivery notes, order requests and other Information (including Personally Identifiable Information) User may provide or as may be requested.

2.2 The Company may collect any of the above-mentioned information using forms (physical and online), verbal instructions, emails, physical (in-person) requests, cookies (as defined below), JWT (JSON web token) and web tokens. Also, when a User accesses any Service, the Company’s servers may automatically record information that a User’s browser typically sends.

2.3 The Company’s primary goal in collecting Information shall include but not be limited to:

a keeping records and manage accounts;

b providing User with a requested service;

c monitoring, recording and storing telephone or email communication for the purpose of internal training, audit and compliance checking;

d improving quality of service(s);

e meeting legal or regulatory requirement(s);

f contacting User through email, SMS, phone call or mail for the purpose of account administration and/or processing and fulfilling orders and/or taking any payment for such order;

g customising the Service according to the User’s interest; and

h send promotional communication.

2.4 To help the Company to serve the User’s needs better, the Company uses “cookies” to store and sometimes track User’s information. A cookie is a small amount of data that is sent to the User’s browser from a web server and stored on the User’s computer’s hard drive or other forms of local storage drives or devices such as a solid state drive or hard drive. Cookies can be disabled or controlled by setting a preference within User’s web browser. There may, however, be some features of the Services that require the use of cookies in order to customise the delivery of information to the User.

2.5 The use of third-party cookies is not covered by this Policy. The Company does not have access or control over such third-party cookies.


3 SERVICE ANNOUNCEMENTS

The Company may send the User service-related announcements when it is necessary to do so. Generally, User may not opt-out of these communications, which are not promotional in nature. If the User however does not wish to receive them, User has the option to deactivate the account.

4 CUSTOMER SERVICE

Based on the Information User provides the Company, the Company will send Customer a welcoming email to verify User’s username and password. The Company will also communicate with User, in response to the inquiries, to provide the services requested by User and to manage User’s account. The Company may communicate with the User by SMS/text message, push notification, or email, or other electronic forms of communication.


5 DISCLOSURE OF INFORMATION

5.1 The Company does not and will not sell User’s Personally Identifiable Information. The Company does not help third parties advertise their products to the User.

5.2 The Company may however share aggregated information that includes non-identifying Information and log data with third parties for industry analysis, demographic profiling and to deliver targeted advertising about other products and services.

5.3 The Company may employ third party service providers and companies, and individuals to facilitate the Company’s services, including: providing the services; delivering product on the behalf of the Company; processing payments, providing customer support services, providing geo-location information to the drivers; providing Service-related support functions (e.g., without limitation, maintenance services, database management, web analytics and improvement of the website’s and software applications’ features); and assisting in analysing how the Company’s Services are used

5.4 These third parties have access to User’s Information only to perform these tasks on the Company’s behalf and are obligated not to disclose or use such Personally Identifiable Information for any other purpose. The Company may also provide Information to the Company’s business partners or other trusted entities for the purpose of providing User’s with information on goods or services the Company believes will be of interest to such User. A User can, at any time, opt out of receiving such communications by contacting those independent third parties service provider directly and KHNL does not assume the responsibility or liability for such independent third parties services provider.

5.5 KHNL cooperates with the government and law enforcement officials, as well as private persons to enforce and comply with the requirements of law. The Company will disclose any Information to government or law enforcement officials or private persons as it, in the Company’s sole discretion, believes is necessary or appropriate to respond to legal claims, process (including but not limited to subpoenas) and directives in order to protect the property and rights of KHNL or a third party, to protect the safety of the public or any person, to prevent or stop any activity that the Company may consider to be, or to pose a risk of being, an illegal, unethical or unlawful activity or to ensure adherence with the requirements of lawful authority

5.6 If the Company is involved in a merger, acquisition, or a sale of its services, User will be notified via email and/or via a prominent notice on any of the applicable Services of any change in ownership or uses of User Information, as well as any rights User may have regarding such Information.

5.7 The Company may use a third party web-hosting or cloud based infrastructure and services provider who hosts the Company’s Site, Software and Services and associated databases. Information collected within this section of this Policy is governed by the Company’s privacy policy. The Company’s third party service provider does not have access to this information.


6 USER’S RIGHTS

6.1 User’s consent is required for the processing of Personally Identifiable Information, and User shall be entitled to provide such consent in accordance with the Terms of Service.

6.2 User may correct or cancel its Information at any time by following the due procedure as prescribed by the Company. Please note that in some cases the Company may retain certain information about a User as is required by law, or for legitimate business purposes to the extent permitted by law.

6.3 The Company will comply with User’s requests regarding access, correction, and/or deletion of the Information stored, in accordance with applicable law and procedure as prescribed by the Company.

6.4 The Company requests User’s permission for the relevant Service’s collection of User’s precise location from User’s device as per the permission system used by User’s mobile device and its operating system or such other relevant software . If User initially permits the collection of this information, User can later disable it by changing the location settings on its mobile device. However, this will limit User’s ability to use certain features of the Company’s Services, including, but not limited to, limiting User’s ability to make orders.

6.5 The Company may also seek User’s permission for the Service’s collection and syncing of contact information from User’s device per the permission system used by User’s mobile device and its operating system or other relevant software. If User initially permits the collection of this information, an iOS or an Android device user can later disable it by changing the “contacts” settings on its mobile device..

6.6 The Company does not provide services or sell products to children below eighteen (18) years of age. If a User is below the age of 18, or where such User is not competent to enter into a contract then such User is not allowed to use the Services.


7 USER NAMES AND PASSWORDS

7.1 User’s access to parts of the Services may be protected by a user-name and a password. User shall not provide its password to anyone. If User enters any section of the Service that requires a password, User should log out when it leaves such section. As a safety precaution, User should also close their web browser completely and re-open it before re-accessing the Internet.


8 SECURITY

The Information the Company collects is securely stored in the Company’s databases, and the Company uses standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting Information. However, as effective as encryption technology is, no security system is impenetrable. The Company, therefore, cannot guarantee the security of the Company’s databases, nor can it guarantee that Information supplied won’t be intercepted while being transmitted to the Company or being transmitted by the Company over the Internet. As such, any Information transmitted by a User to KHNL is done at such User’s risk. The Company recommends that User does not disclose its password to anyone.


9 POLICY IS PART OF TERMS OF SERVICE

This Policy is an inseverable part of Terms of Service and therefore the two should be considered and read in conjunction with each other. User may view the Terms of Service on the Company’s website located at [●]


10 CHANGES TO THIS POLICY

The Company may change this Policy from time to time on need basis and/or to comply with relevant laws and/or regulations. If the Company makes significant changes in the way it treats User Information, or to the Policy, KHNL will provide notice through the Services or by some other means, such as SMS/text message or email. User’s continued use of the Services after such notice constitutes implied consent to and acceptance of the changes effected in the Policy. The Company encourages User to periodically review the Policy for the latest information on its privacy practices.


11 VIOLATION OF PRIVACY

11.1. The Company has put in place procedures to deal with any suspected Information breach. The Company will notify affected Users of any of such breach as well as the steps taken to remedy the breach and the security measures the Company has applied to render User Information unintelligible as applicable.

11.2. All suspected Information breach will be remedied within a reasonable period from the date of the report of the breach.

11.3. If a User knows or suspects that an Information breach has occurred, such User should immediately contact KHNL at: customer@khnl-ng.com.

11.3. The Company will not be responsible for any breach of Information which occurs as a result of:

(a) events which are beyond its control;

(b) acts or threats of terrorism;

(c) acts of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises Company’s data protection measures;

(d) war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo;

(e) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises Our data protection measures;

(f) the transfer of User’s Information to a third party on such User’s instructions; and

(g) the use of User’s Information by a third party designated by such User.


12 CONTACT

For questions regarding the terms of this Policy, contact: customer@khnl-ng.com .