Who we are
Horley Tech Limited (“Horley Tech”, “We”, “Us”, “Our”) is a leading retail company duly incorporated under the Laws of the Federal Republic of Nigeria (“Territory”) that provides a range of durable and affordable products and services including wholesale and retail mobile phones, wholesale and retail computers, wholesale and retail electronics, wholesale and retail accessories, repairs of electronic devices, among other services (our “Products and Services” or our “Products”).
Your data privacy and protection is important to us. This Data Privacy Policy (“Privacy Policy”) applies to Horley Tech’s online interface (i.e. website or mobile application) and any affiliate or subsidiary online interface that links to this Policy, (individually referred to as a “Site”, and, collectively, “Sites”). This Policy describes how the Sites may collect, use, and share information from or about you, and explains how information may be collected and used for advertising purposes.
Please read this Privacy Policy carefully. By using the Site and any services we offer via the Site, you are agreeing to be bound by this Privacy Policy in respect of the information collected about you via this Site.
Consent
We kindly request that you carefully read through this Privacy Policy. Take note that you must be of Age to use our Services or any of our Sites. As a customer, you accept this Privacy Policy when you click “I ACCEPT” or tick an icon or text signifying your agreement that you have read this Privacy Policy and accepted same, and fill in your personal details and other answers into the provided blank form or sign up for, access, or use our products, services, content, features, technologies or functions offered on our Sites and all related sites, applications, and services.
This Privacy Policy is intended to govern the use of the Site by users. Users reserve the right to exercise their data protection rights as listed below.
This Privacy Policy regulates how personal information will be used within the Company. To preserve the confidentiality of your data, we maintain the controls in place for privacy.
What Personal Information (PI) do we Collect?
This Privacy Statement applies to all personal information and data about an identifiable, living, natural person and, where it is applicable, an identifiable existing juristic person, including, but not limited to –
- your names and your images (where applicable);
- information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the Person;
- information relating to the education or the medical, financial, criminal or employment history of the Person;
- any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the Person;
- the biometric information of the Person;
- your preferences, such as consents for marketing and other communications;
- Investigations’ data. This may include; anti-money laundering and Combating Financing of Terrorism checks, Enhanced Due Diligence, Fraud or Convicted Criminal database, Politically Exposed Persons, external intelligence reports, and other due diligence checks;
- the personal opinions, views or preferences of the Person;
- correspondence sent by the Person that is implicitly or explicitly of a private or confidential nature, or further correspondence that would reveal the contents of the original correspondence;
- the views or opinions of another individual about the Person;
- the name of the Person if it appears with other Personal Information relating to the Person or if the disclosure of the name itself would reveal information about the Person; and
- and all other personal data that you share with us during your dealings with us.
Why we Need Your Data
We collect personal information directly from you, and where lawful and reasonable, we may collect personal information about you from third parties and publicly available sources, such as credit reporting and government agencies for the purposes set out below:
- meet our responsibilities to you;
- follow your instructions;
- process your personal information for ordinary business purposes (including processing your purchase of our Products and use of our services, give effect to transactions and your instructions, administer claims where applicable, manage our risks and maintain our overall relationship with you);
- carry out statistical and other analysis to identify potential markets and trends, evaluate and improve our business (this includes improving existing and developing new products and services);
- tell you about available services and products;
- make sure our business, Products and services suits your needs;
- comply with applicable regulations;
- responding to any feedback that you send to us, resolving complaints and troubleshooting problems;
- detecting, preventing and remediating fraud or other illegal activities;
- Without your personal information, we may not be able to provide or continue to provide you with the products or services that you need;
- tracking data breach and remediating such identified data breaches; and
- contacting you at needed times through your provided phone number, email address or any other contact details made available to us by you.
Our Legal Basis for Processing Your Data
The legal basis for processing your personal data is the legal requirement of your consent for us to process your personal data and our legitimate interest in providing our Services to you. We will process your personal information as stated above if you give us your consent willingly or in accordance with the law. You give your consent to us through our products and services agreements.
We will only disclose your personal information if:
- the law requires it;
- we have a public duty to disclose the information;
- our or your legitimate interests require disclosure; or
- you agreed that we may disclose your information.
How we get Your Consent
You accept this Privacy Policy when you give consent upon accessing our Sites or use our Services for official or non-official purposes. You give us consent to process your personal data when you click “I ACCEPT”, tick a box and/or fill in your personal details and other information into the provided blank form. You also give us consent when you fill in your details into any of the blank forms provided on our Sites for collection of personal data.
Your consent when given covers the processing of your personal data within Nigeria and in any country other than Nigeria wherein your personal data is transferred for processing or after processing.
How to Withdraw Your Consent
You may withdraw your consent by communicating such withdrawal to us via support@horleytech.com. However, such withdrawal of consent shall not affect the lawfulness of the hitherto processing of your personal data before consent was withdrawn.
How we Collect Your Data
We collect your data and personal information when you provide your Personal Information by filing forms and submitting such information on our Sites. We may also collect your data through approved third-parties provided that your consent is obtained.
Third parties
We ask third-party service providers to agree to our privacy policies if they need access to any Personal Information to carry out their services.
We will not disclose your personal information to external organisations that are not our service providers, unless you gave us your consent, or unless we are required to do so by law, or if it is necessary for the conclusion or performance of our agreement with you, and such disclosure shall be governed by a written contract between that third party and us.
Transfer Across Borders
Sometimes we will process your personal information in other countries, either to carry out your instructions or for ordinary business purposes. Some countries may not have the same level of protection. If necessary, we will ask the party to whom we transfer your personal information to agree to our privacy principles, associated policies and practices.
Storing Personal Information
We retain and store personal information as long as is required for the purpose for which you have given it and as required by law. Your information is destroyed or anonymised once they are no longer required for the purpose they were collected and no statutory requirement to retain them.
Our cross border and third-party policy as stated above will apply in instances where your personal information has been transferred outside of the country or to a third party.
Our Security Practices
Our security systems are designed to prevent loss, unauthorised destruction, damage and/or access to your personal information from unauthorised third parties.
The security of your personal data is important to us. We store and process your personal information on our computers in Nigeria, and where necessary transfer same outside for processing. We have information security standards which ensure that your personal data is secured against all foreseeable hazards and data breaches such as theft, cyberattacks, viral attacks, manipulations etc. We also have a data breach incident management procedure which documents our quick response to any reported personal data breach incident, and ensure all incidents are managed in accordance with legal and regulatory requirements and best practice guidelines. Where we need to transfer your data to another country, such country must have an adequate data protection law. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls.
You should read the security tips and updates on our Sites regularly to make sure that you benefit from our security systems and stay updated with the latest fraud scams and trends.
Marketing by Electronic Means
If you give us permission, we may use your personal information to tell you about products, services and special offers from us or other companies that may interest you. We will do this through email, text message (SMS), social media platforms or notify you on your mobile applications. If you later decide that you do not want us to do this, please contact us through our customer service channels to stop this service.
Access to your Personal Information
As our customer, you may:
- ask us to give you a description of your personal information that we hold; and
- ask us to correct or update your personal information through our customer service channels.
We may, where a customer requests for such personal information in a customized/specified format if allowed by law, charge a fee.
Our Use of Technology to Follow Your Use of our Sites
While you are using our Sites, we automatically process certain personal information, such as visits to our Sites. We use this information to find out which areas of our Sites people visit most and to monitor the use of our Sites. This helps us to add more value to our services. This information is gathered in such a way that we do not get personal information about any individual or their online behavior on other sites.
Cookies
We use cookie technology on some of our Sites. A cookie is small pieces of text that is saved on your Internet browser when you use our Sites. The cookie is sent to our computer each time you visit our Sites. Cookies make it easier for us to give you a better experience online. You can stop your browser from accepting cookies, but if you do, some parts of our Sites or online services may not work. We recommend that you allow cookies.
Links to other Sites
Our Sites, related Sites and mobile applications may have links to or from other Sites. Although we try to link only to Sites that also have high privacy standards, we are not responsible for their security, privacy practices or content. We recommend that you always read the privacy and security statements on these Sites.
Monitoring of Electronic Communications
We communicate with you through different methods and channels. If allowed by law, we may record and monitor electronic communications to make sure that they comply with our legal and regulatory responsibilities and internal policies.
Monitoring and Analysis
We will monitor and analyse your account for credit, fraud, compliance and other risk-related purposes as required by law.
Social Media
We operate and communicate through our designated channels, pages and accounts on some social media sites to inform, help and engage with our customers. We monitor and record comments and posts made about us on these channels so that we can improve our services.
The general public can access and read any information posted on these sites. We are not responsible for any information posted on those sites other than the information posted by our designated officials. We do not endorse the social media sites themselves, or any information posted on them by third parties or other users.
We do not give investment, tax or other professional advice on social media sites. You should always get independent advice before making any decisions.
When you engage with us through social media your personal information may be processed by the site owner; this process is outside our control and may be in a country outside Nigeria that may have different privacy principles.
Social media sites are not appropriate forums to discuss our customers’ products or financial arrangements. We will not ask you to share personal, account or security information on social media sites.
We regularly update and monitor our social media accounts and welcome feedback and ideas sent to us through these channels. We try to join conversations whenever possible but may not reply to all messages sent to official Horley Tech social media accounts.
Emerging themes and helpful suggestions will be given to the relevant staff for consideration, but we cannot guarantee that any themes or suggestions will be acted on.
Your Rights
We will take note of your rights under applicable privacy and data protection laws, especially your right to object, on reasonable grounds, to certain types of processing.
You have the right to query a decision that we make about a product or service that you have applied for and that was made solely by automated means.
You have the right to withdraw consent previously given and lodge a complaint with the relevant regulatory authority.
You have the right to contact the Data Protection Officer, report to a regulator or seek redress within the law whenever there is a violation of this policy.
Principles Guiding the Handling of Your Data
Your personal data shall be:
- collected and processed in accordance with specific, legitimate and lawful purposes;
- consented to by you; provided that: a further processing may be done only for archiving, scientific research, historical research or statistical purposes for public interest;
- restricted to you and shall not be transferred to any person or entity except when requested by you or required by law;
- adequate, accurate and without prejudice to the dignity of human person;
- deleted from our database and any other location where it is stored at your request;
- stored only for the period within which it is reasonably needed, and
- secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.
Right to change this Privacy Statement
We may change this privacy statement. We shall publish all changes on our Sites. The latest version of our privacy statement will replace all earlier versions, unless it says differently. We will notify you of material changes to the Privacy Policy by email as well as a notice on our Sites.
Queries and Complaints
If you have any queries or complaints about privacy, please contact:
Phone: +2348179974851
Instagram: @horleytech
Email: support@horleytech.com
We will ensure all complaints are resolved in a timely manner consistent with all relevant regulatory provisions.
Governing Law
This Privacy Policy is made pursuant to the NDPR and other relevant Nigerian laws, regulations, or international conventions applicable to Nigeria, the General Data Protection Regulation applicable in Europe and relevant data protection laws. Where any provision of this Privacy Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation, or convention.
Changes to this Policy
This Privacy Policy is subject to change. Please review it periodically. If we make changes to the Privacy Policy, we will revise the “Last Updated” date at the top of this Privacy Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.
You agree that it is your obligation to visit our Site from time to time and keep yourself abreast of any change or update that may be made to this Privacy Policy, and we are not obligated to notify you of any such change or update.
