Privacy
Policy

This Privacy Policy provides you with information about EbonyLife's collection and processing of your Personal Information through your use of EbonyLife's online and offline services — including the Website, Contact Services, Mobile Apps, EbonyLife Social Media, EbonyLife Wi-Fi, and all other EbonyLife Services.

For information about the companies collectively referred to as 'EbonyLife' in this Policy, see Part B. For definitions of all terms used, see Part C.

Please read this Privacy Policy carefully before providing any personal information to us. This Policy supplements other notices and is not intended to override them.

When you do any of the following, you acknowledge that you have read and agree to this Privacy Policy:

• Access or use our Website or EbonyLife Social Media
• Download, use or register on a Mobile App
• Contact EbonyLife for any reason
• Use EbonyLife Wi-Fi
• Apply for, sign up for, or use any EbonyLife Services

EbonyLife reserves the right to amend this Privacy Policy at any time. Amendments take effect when posted on our platforms. Please check our "Privacy and Legal" section regularly. Continued use of our services after any amendment constitutes your agreement to the updated Policy.

We will only use your Personal Information for the purposes for which it was collected and other compatible purposes. We may process your Personal Information without your knowledge or consent where required or permitted by law.

EbonyLife Cinemas Limited and The White Orchid Hospitality Limited provide hospitality and entertainment services under the EbonyLife brand in Nigeria. "EbonyLife / we / our / us" refers to these companies as controllers for the respective service referred to in this Policy.

Controllers under the NDPR

Sponsor Associates may also be controllers in certain circumstances — see Paragraph 37.1.

Aggregated Data

We also collect, use and share aggregated data (e.g. statistical or demographic data). This is not considered Personal Information as it does not identify you. However, if aggregated data is combined with your Personal Information in a way that identifies you, we treat the combined data as Personal Information and use it accordingly.

Purchases: If you make a purchase, EbonyLife collects the information needed to fulfil your order and notify you of its status. Where you pay by card, we obtain a card token as part of the payment authorisation process.

Competitions & Surveys: We collect Personal Information you submit when entering competitions or promotions, and may invite you (with your consent) to participate in surveys. Participation in surveys is entirely voluntary.

If you contact us for any reason, we may keep a record of that correspondence.

Mobile Apps: Certain app functions require location data from your device (e.g. finding your nearest cinema). If you do not want the app to use your location data, please change the settings on your device.

Social Media: EbonyLife Social Media is provided via third-party social media sites which have their own terms, cookies and privacy policies. You should read these carefully and check your personal settings before using social media integrations.

We may upload your name and contact details into social media platforms to create targeted advertising campaigns. We rely upon your consent for marketing for such purposes.

Wi-Fi: When you use EbonyLife Wi-Fi, we may collect information about your device and its location, the volume of data you use, and the websites and applications you access.

If you do not want EbonyLife Wi-Fi to use your location data, please change your device settings. Disabling location access may result in loss of certain functionality.

Purchases: We use your information to fulfil your order, send booking confirmations, and generate a profile of your purchase preferences so we can send you more relevant advertising and offers. We may also use anonymised data for statistical and trend analysis.

If you are over 18 and have consented, or have transacted with us, we may send you marketing communications about related or similar EbonyLife products and services.

EbonyLife marketing communications may cover film times, cinema news, promotions, loyalty schemes, competitions, special offers, and information about EbonyLife products and services. We will communicate through the channels you have opted into.

EbonyLife Wi-Fi: Data collected during your Wi-Fi session is used only to provide you with access to the Wi-Fi service — not for marketing or profiling.

We use CCTV systems in our premises for our legitimate interests — and those of our customers, visitors, business partners and service providers — in detecting, investigating and addressing incidents including health and safety issues and unlawful acts.

CCTV footage may be used by us, relevant third parties, our representatives, the police, or health and safety investigators, in detecting and addressing any incidents.

We may share your Personal Information with the following third parties:

• Sponsor Associates — organisations to whose customers we provide goods, services and events. We share your data only to the extent relevant to the specific Sponsored Screening, and only if you are a Sponsor Customer. Sponsor Associates may be independent controllers of your data in such cases, governed by their own privacy policy.
• Service Providers — third parties performing functions on our behalf (e.g. developing and maintaining databases, creating and analysing customer communications, administering competitions, providing customer services).
• Processors — where we transfer data to service providers acting as processors, they are required to comply with appropriate NDPR safeguards.

We reserve the right to release Personal Information without your consent where this is appropriate to comply with legal obligations, enforce our terms, protect the security of our services, prevent fraud, or protect the legitimate interests of EbonyLife or its customers.

We may share statistical (anonymised) information about customers with advertisers, business partners and sponsors. This information is always shared in a way that ensures your identity is not revealed.

If EbonyLife or any part of our business is restructured, sold, or integrated with another business, we may transfer customer information (including your Personal Information) to other companies in the EbonyLife group or to the new owners, as appropriate.

We follow strict security procedures, processing Personal Information in a manner that ensures appropriate security — including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.

We have procedures in place to deal with any suspected Personal Information breach. We will notify you and any applicable supervisory authority of a breach where legally required to do so.

If you are provided with a username, password, or other security information, you must treat it as strictly confidential and not disclose it to any third party. Notify us immediately of any suspected unauthorised use. We reserve the right to disable any account if we believe you have failed to keep your security information secure.

We will only retain your Personal Information for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

Types of Cookies We Use

• Strictly Necessary Cookies — essential for the operation of our Website (e.g. enabling you to log in and make purchases)
• Analytical / Performance Cookies — allow us to recognise and count visitors and understand how they navigate our Website, helping us improve it
• Functionality Cookies — used to recognise you when you return and to personalise content for you
• Targeting Cookies — record your visit, pages viewed and links followed to deliver advertising more relevant to your interests

You can block cookies through your browser settings. However, blocking some or all cookies may affect your ability to use parts of our Website. For more information, visit www.allaboutcookies.org.