Thank you for choosing Ebeano Market.com Limited ("we," "us," or "our"). This Privacy Policy is designed to help you understand how we collect, use, disclose, and safeguard your personal information in connection with our website and mobile applications (collectively, the "Services").

Ebeano Market.com Limited respects the privacy of your personal information which should be protected through the use and interaction with these Applications and all our associated Applications, Products, and Services. We have prepared this Policy to notify you of the type of personal information we collect from you, how we will treat that personal information, and the circumstances under which we will share it with third parties.

Consent From You

We will not collect or process your personal information without obtaining your consent. Your consent is obtained by clicking on an “I AGREE” icon. You agree that such acceptance will have the same force and effect as if you had manually signed a paper version of this Policy.

By accepting the TOU you are accepting the terms and conditions of this Policy and providing us with consent for the processing of your personal information received and accepting the practices described in this Policy. Your personal information will be collected in two (2) phases during our KYC process prior to you being able to complete a transaction on Skillerman Applications.

Your data is collected for safety and security purposes. Should we ever wish to process any more than the minimum personal information needed to provide you with your Product or Service, we will ask you for your prior consent. The only time we will ever process any personal information without your consent is when the law clearly requires us to do.

Should we ever wish to also process any minor’s personal information, we will obtain your prior written consent as the parent or guardian, whichever is applicable.

Who does this Policy Apply To?

This Policy applies to:

a)   all vendors and/or Service Users who are natural persons; and

b)   all vendors and/or Service Users who are organizations.

What We Collect About You?

We will always only collect exactly what we need directly from you, subject to exceptional lawful circumstances, for us to provide you with the Product and or Service, which you have requested us to provide, and for KYC purposes.

We will also advise you if any personal information to be provided is voluntary or not and what will occur if we cannot process any of the personal information requested.

On some Applications, mobile Applications, Products, and Services that you are subscribing to and or purchasing, you may be requested to provide your personal information which is relevant to the type of Products or Services being applied for.

In general, personal information is information that identifies you as an individual or your organisation, such as: your first and last name, your organisation’s name and its directors’ names; your ID number or the organisation’s registration details and directors ID numbers; phone numbers and payment information and your, or the organisation’s communication preferences.

Personal information is information that identifies you as an individual and or the representatives or directors of an organisation, which includes -

a)   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 the birth of that person.

b)   Information relating to the education or the medical, financial, criminal, or employment history of the person.

c)    Any identifying number symbol such as cell phone number, account number, handset code, e-mail address, physical address, telephone number, location information, online identifier, or other assignment to the person.

d)   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 and the views or opinions of another individual about the person.

Whilst you are making use of any of our Applications we automatically collect certain personal information such as: your IP address; browser type; operating system; mobile carrier; your ISP, URLs of sites from which you arrive or leave the Applications and sites that have our platform technology embedded. Through cookies and other technologies, we can recognise you as an existing or registered user of our web application and/or mobile application and are able to better service you as a result.

A cookie is generally a tiny data file that resides on your computer, mobile phone, or other devices, and allows us to recognise you as a user when you return to our Applications using the same device and web browser.

There are different types of cookies. Here are two examples:

A "persistent" cookie - this cookie is set once you have logged onto a website. The next time you visit the website, the persistent cookie will allow the website to recognise you as an existing user or registered user, so you will not need to log in before using the services.

A "session" cookie - this cookie is used to identify a visit to a website. Session cookies expire after a short time or when you close your web browser.

You can remove or block cookies using the settings in your browser, but in some cases doing so may impact your ability to use the website.

The Use of Your Personal Information

a)   To provide you with the best online services, mobile Applications, products, and services, we will:

b)   Use your personal information to validate that you are who you say you are by conducting necessary verifications.

c)    Process the Products and Services you have bought from us, and keep you updated with your order progress.

d)   Provide the relevant Service or Product to you. This includes other services not included in your agreement with us, and services that use information about where you are when using your mobile equipment (location information) and to contact you with messages about changes to the service or product.

e)   Bill you for using our Products or Services.

f)     Understand how you use our Products and Services. That way, we can develop more interesting and relevant Products and Services, as well as personalise the Products and Services we offer you.

g)   Carry out research and statistical analysis to monitor how you use our Products and Services on an anonymous or personal basis.

h)   Conduct market research and perform statistical analyses of your behaviour. By being aware of your interest in and use of the various areas of our web application, mobile Applications, Products, and Services for us to better serve you.

i)     Share information with our third parties within our operations where we have an underlying contractual relationship with the third parties to provide a service to you on our behalf.

j)     Prevent and detect fraud, information security and privacy incidents, and other crimes, recover debts or trace those who owe us money.

k)    Send you promotional materials or details by SMS, e-mail, postal service, or electronic communication provided you have given your consent to receive such marketing from us or our authorised third parties.

l)     Let you know about other companies Products and Services (including offers and discounts we have specially negotiated for you) that we think may interest you if you have chosen to receive this information.

m)  Contact you in the event of a query and respond to any questions or concerns you may have about using our network, Products, or Services.

n)   Act in accordance with circumstances prescribed by law.

o)   The Safeguards for Your Personal Information

p)   Maintaining the security of your personal information is important to us. Reasonable security safeguards have been implemented to protect your personal information.

We use various methods to protect your information such as:

Encryption methods when transmitting payment information, such as your credit card information. An icon resembling a padlock is displayed on the bottom of most Internet browser windows during encrypted transactions.

Access to your personal information on our Applications will be password-protected.

Sensitive data (such as credit or debit card information) is protected by SSL (secure sockets layer)encryption when it is exchanged between your web browser and ours.

To protect any data, you store on our servers, we also regularly audit our systems for possible vulnerabilities and attacks.

We maintain an Information Security Programme internally to ensure that your personal information is protected against unauthorised access, accidental loss, or destruction.

Sharing of your Personal Information

We do share your personal information with third parties where it is necessary to perform certain functions to provide our Services to you. We will only share your information in the following instances:

a)   where disclosure is made with your consent; and

b)   where we are obliged to disclose information as required by law, without consent.

There may be circumstances where we are obliged to disclose your information by law and are prohibited from informing you when we have received a request for your personal information in relation to any suspected or alleged criminal activity.

In addition, third parties chosen by us are assessed to ensure that they handle your information securely. Third parties are companies that we employ to perform functions on our behalf. Some of our third parties perform the following functions:

Receiving payments, user verification, insurance providers, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing market assistance, providing search results and links (including paid listings and links), processing credit and debit card payments, and providing customer service such as assisting in upgrading customer contracts, conducting direct marketing activities subject to compliance with the laws relating to consent.

By performing online services on our Applications these third parties have access to personal information needed to perform their functions but may not use it for any other purposes that have not been clearly defined by us.

We shall not transfer your personal information to a country or territory outside of Nigeria unless that country or territory ensures an adequate level of protection of such personal information in relation to the processing of personal information as adopted within Nigeria and unless an agreement setting out the terms and conditions of securing the integrity and protection of data commensurate to Nigeria legislation is concluded between us and the third party to which the personal information is transferred.

Similarly, this third party may not transfer your personal information to another third party within that country or territory if they need to do so as part of their processing which they are authorised to do on our behalf, without our prior written authorisation. This will ensure that all authorised third parties apply the same level of data security and protection as we do for you.

Your Information Choices

If you are a corporate user, you must go through your authorised corporate representative who will engage with Skillerman App on your behalf, subject to the corporate’s approval.

Accessing and Changing your Information

You can review the personal information which you provided to us and make any necessary changes to the information you have provided, subject to it not impacting our continued ability to deliver your Products and Services which you have mandated us to provide.

Please be aware that even after your request for a change is processed, we may, for a time, retain residual information about you in its backup and/or archival copies of its database.

Right to Request Copies of Your Personal Information on Record

You are entitled to request us to confirm what personal information we have on record of you at no cost. This will be completed within a reasonable timeframe, subject to any restrictions imposed by Law.

Thereafter you may request copies of these records if you need to see them physically. They will be provided in electronic format. If you wish to receive them in hard copy, we will be obliged to quote in advance how much it will cost you and you will need to confirm this in writing before we will process the request, again within a reasonable period.

Right to Object to Processing

Once you have confirmed what personal information we have on record of you, you are entitled to object to us processing any personal information and can follow the same process mentioned above. You will be advised of whether it is possible to cease the processing subject to the fact that we may need to tell you that it means that we cannot continue to provide you with your product or service. For example, if you no longer wish us to have access to your bank details, then we will not be able to complete a product or service fee debit order, which means we will have to cancel your product or service.

Deletion or destruction of your Information

You may request that we delete and or destroy any of your personal information provided, that you have finalised your relationship with us, meaning your contract has come to an end and you are no longer using our Products or Services. We will however retain and use your personal information for as long as is necessary to comply with our legal and business obligations, resolve disputes and enforce this Policy. The same process as mentioned above will be followed with all requests being confirmed in prescribed formats as required by the Information Regulator and we will provide you with a certificate of compliance at the end.

Direct Marketing

You have the right to choose whether you wish to receive marketing material or not.

We may send you marketing materials on related services, products, and offerings provided by us or authorised third parties from time to time, subject to your having consented to receive it at the point of your first engaging with us or the authorised third party. We will always provide you with the option to opt-out of receiving such direct marketing materials at the subsequent points of communicating.

On occasion, if we wish to market a new Product or Service and we have no record of your consent preferences, we or our authorised third party will contact you once to establish this and update our records.

Please note, if you are a member of a corporate and they own your contract, it is the prerogative of the corporate that holds the master services agreement with us, to determine what direct marketing may be permitted to be sent to its users.

Your Obligations

a)   You have certain obligations. Some of these obligations are imposed by applicable law and regulations, and others have become commonplace for us:

b)   You must, always abide by the terms and conditions of this Policy which may be updated from time to time, and any agreement relating to our Products and Services that you have subscribed to. This includes respecting all intellectual property rights that may belong to third parties (such as trademarks or photographs).

c)    You must not download or otherwise disseminate any information that may be deemed to be injurious, violent, offensive, racist, or xenophobic, discriminates against people on the basis of gender and sexual orientation, threatens the rights and safety of others, or which may otherwise violate our purpose and spirit and our community of users on our web and/or mobile applications.

d)   You must not provide us with information that you believe might be false or misleading. You must keep your username and password confidential and not share them with others. This particularly relates to any minors or partners who may get access to your device.

Reporting incidents

a)   Please let us know via email: contact@ebeanomarket.com

b)   If you believe your Skillerman web and/or mobile application account has been compromised.

c)    If you have been contacted by someone about your Skillerman Applications, account asking for a password, birth date, or other personal information.

d)   If you believe your personal information has been used for fraudulent activity.

e)   If you are a member of the security community and need to report a technical vulnerability.

f)     If you have any other enquiry relating to information privacy and security.

Right to amend this Notice

Ebeanomarket.com Limited may, at any time, change this Policy by posting the amended Policy on www.skillerman.ng. Unless otherwise stated, the current version will apply each time you access these Applications.

Date of Publishing

Last updated 09/11/2023