Privacy Policy
A. INTRODUCTION
1. This Privacy Policy shall provide 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, EbonyLifeSocial Media, EbonyLife Wi-Fi, and other EbonyLife Services.)
2. For all relevant information as to the companies collectively referred to as ‘EBONYLIFE’ in this Privacy Policy, please see PART B.
3. For the definitions and interpretations of all terms used in this Privacy Policy, please see PART C.
4. Please take your time to read this Privacy Policy before providing any personal information to us. This is to ensure that you are aware of how, and why we are using your Personal Information. This Privacy Policy supplements the other notices and is not intended to override them
B. EBONYLIFE COMPANIES
8. 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 the companies listed above, to the extent that they are a controller for the respective service or provision referred to in the Privacy Policy.
The Controllers
9. These are the controllers for the purposes of the NDPR (i.e. is responsible for, and controls the processing of, your Personal Information):
| Controller Name | Nature of service |
|---|---|
| EbonyLife Cinemas Limited | This is a controller in respect of the Personal Information processed in connection with the sale of cinema tickets, food, drink and merchandise for its cinemas. It is also the controller in respect of the Personal Information processed in connection with the administration of, and transactions in respect of: The White Orchid Hotel, Popina Lagos, Túraká, EbonyLife Wi-Fi and EbonyLife Place. |
| The White Orchid Hospitality Limited | This is a controller in respect of the Personal Information processed in connection with the sale of food, drink and merchandise for The White Orchid Hotel, Popina Lagos, Túraká, EbonyLife Wi-Fi and EbonyLife Place. |
10. Please also be aware that Sponsor Associates are controllers as well. Further details about what we mean by “Sponsor Associates”, as well as the circumstances in which they are controllers, are shown in Paragraph 37.1 below.
10. Please also be aware that Sponsor Associates are controllers as well. Further details about what we mean by “Sponsor Associates”, as well as the circumstances in which they are controllers, are shown in Paragraph 37.1 below.
C. DEFINITIONS
11. The following terms have the accompanying definitions in this Privacy Policy:
– “Mobile Apps” shall mean our mobile application developed by us for different operating systems ie Apple, Android.
– “EbonyLife Services” shall mean any or all of the following (as applicable to you): Your use of the Website, Mobile Apps, EbonyLife Social Media or EbonyLife wifi, purchasing tickets, goods and services in EbonyLife Cinemas including hiring cinemas for events such as birthday parties, film screenings;
– “EbonyLife Social Media” shall mean the parts of social media provided by third parties (such as Facebook, Twitter, Instagram etc) through which EbonyLife provides services such as information, applications, advertisements and similar activities.
– “EbonyLife Wi-Fi” shall mean the wireless internet access provided by EbonyLife at its entertainment and hospitality centre, EbonyLife Place.
– “NDPR” means the Nigerian Data Protection Regulation and any amendments or updates that may come into force.
– “Personal Information” means any information about you or any person from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
– “Privacy Policy” means this Privacy Policy and any amended versions or updated created by us.
– “Website” means our website at www.ebonylifeplace.com as well as any other websites redirected from www.ebonylifeplace.com and other tabs created from www.ebonylifeplace.com and other websites operated by any EbonyLife Company for its entertainment and hospitality centre.
D. PERSONAL INFORMATION WHICH WE MAY COLLECT ABOUT YOU
12. Within the limit of the relevant laws, the Personal Information we may collect about you includes, but is not limited to the following:
12.1. Identity Information – this may include: first name; last name; title; date of birth; age; health, medical or disability status; photographs; and social media profile username.
12.2. Contact Information which may include: billing address; delivery address; email address; and telephone numbers.
12.3. Financial Information – this consists of financial information, and may include: bank account details; direct debit details; gift card details, credit and debit card details; and credit and debit card tokens.
12.4. Transactional Information – this consists of details about payments to, and from, you; usage of points, vouchers, promotions, memberships and gift cards; and other details of products and services which you have purchased from us.
12.5. Technical Information – this consists of technical browser or device related information, and may include: your device type; internet protocol (IP) address; your session data; browser type and version; time zone setting; and location data.
12.6. Profile Information – this consists of profile data about you, and may include: your interests; your preferences; your feedback; survey responses; information about how you use the EbonyLife Services.
12.7. Marketing Preferences Information – this consists of your preferences in receiving marketing from us and our third parties, and your communication preferences.
12.8. Other Information – this is other Personal Information which you voluntarily choose to share with us; as well as CCTV footage when you attend our premises.
14. If you make a purchase on our website, EbonyLife will collect the information which we need to fulfil your order and notify you of the status of your order. Where you pay by credit or debit card, we obtain a credit or debit card token relating to your credit or debit card as part of the payment authorisation process
E. EBONYLIFE SOCIAL MEDIA, MOBILE APPS, THIRD PARTY LINKS AND EBONYLIFE WI-FI
F. OUR USE OF YOUR INFORMATION AND LEGAL JUSTIFICATION
29. If you make a purchase, EbonyLife will use your information as provided by you to fulfil your order, which for online purchases will usually include sending you a booking or purchase confirmation email. Details of your purchases will be linked to you, as well as to generate a profile of the types of purchases which you prefer (again, pursuant to our legitimate interests), so that we can send you more targeted (and therefore relevant) advertising, information and offers. We may also use anonymised information derived from this, for statistical and trend analysis purposes.
33. Survey information will be used for the purposes of understanding customer trends, monitoring or improving our services and, sometimes, to contact you with news and offers. This will be provided to you where you have opted into such surveys by way of consent
34. We will use the data which we collect when you use EbonyLife Wi-Fi, in order to provide you with access to the EbonyLife Wi-Fi service
35. We use CCTV systems in our premises, for our legitimate interests (and for those of our customers, visitors, business partners and service providers) of detecting, investigating and addressing incidents (including health and safety, civil or criminal unlawful acts). This is to safeguard our premises, business, goods and services, as well as our customers, visitors, business partners and service providers. Footage from CCTV may be used by: us; the third parties referred to above; by our representatives or those of our third parties; the police; or health and safety investigators; in detecting, investigating and addressing any incidents.
36. Where we work with Sponsor Associates in respect of Sponsored Screenings, we share your Personal Information with such Sponsor Associates for their legitimate interests. However, we only share such Personal Information with the Sponsor Associates, to the extent that it is relevant and relates to the particular Sponsored Screening.
G. SHARING YOUR INFORMATION WITH THIRD PARTIES
37. We may pass your Personal Information to the following third parties:
37.1. Our sponsors (“Sponsor Associates”) – these are organisations to whose customers we provide goods, services and events (we refer to such customers as the “Sponsor Customers”; and we refer to such goods, services and events made available to the Sponsor Customers as “Sponsored Screenings”). We make available your Personal Information to Sponsor Associates, if you are a Sponsor Customer, for the legitimate interests of Sponsor Associates to be able to:
(a) see the particular Sponsor Customers who participated in the respective Sponsored Screening; and
(b) allow the Sponsor Associate to obtain positive and negative feedback from the Sponsor Customers in respect of the Sponsored Screening.
In such circumstances, the Sponsor Associate is also a controller of your Personal Information. How they use your Personal Information will be governed by their privacy policy and terms and conditions, which you would have had the opportunity to consider and agree to, prior to participating in the respective Sponsored Screening which the Sponsor made you aware of.
37.2. Other companies and individuals in order for them to perform functions on our behalf (e.g. developing, maintaining and analysing customer databases; creating, sending out and analysing customer communications (including feedback on EbonyLife Social Media); administering competitions; developing, maintaining and analysing the EbonyLife Services and providing customer services).
37.3. Where we transfer your Personal Information to service providers which are acting as our processors, we will do so, on the basis that the respective third parties have agreed with us, that they with comply with the appropriate NDPR safeguards.
38. We also reserve the right to release Personal Information without your consent, or without consulting you, when we believe that this is appropriate to comply with our legal obligations, to enforce our terms and conditions or other legal rights, to protect the security of the EbonyLife Services, to prevent fraud, or otherwise to protect the legitimate interests of EbonyLife or its customers.
39. From time to time, we may share statistical information about customers with third parties such as advertisers, business partners and sponsors, to help us and them analyse, develop, manage and market our goods and services. This information will be shared in a way that ensures that your identity is not revealed to them.
40. If EbonyLife or any part of EbonyLife’s business is restructured, sold to, or integrated with, another business, we may transfer customer information (including your Personal Information) to other companies under the EbonyLife group of companies or the new owners or franchisees as the case may be.
H. SAFEGUARDS FOR YOUR INFORMATION
43. If you choose, or are provided with, a user name, user identification code, password, security question and answer, verification number or any other piece of security information as part of our security procedures, you must treat such information as confidential and not disclose it to any third party. If you become aware of any unauthorised use of your security information, you must inform us immediately. We have the right to disable any account and registration with us at any time, if in our opinion, you have failed to comply with your obligation to keep your security information secure.
I. HOW LONG WE WILL KEEP YOUR INFORMATION
44. We will only retain your Personal Information for as long as is necessary, to fulfil the purposes which we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
45. 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 requirements.
46. For tax and legal claims purposes, we retain Transactional Information (with the associated Identity Information and Contact Information to the extent required for such purposes) for seven years after an individual ceases being a customer.
47. In some circumstances we may anonymise your Personal Information for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
J. TRANSFER OF PERSONAL INFORMATION OUTSIDE NIGERIA
48. The Personal Information that we collect from you, may be transferred to, and processed at, a destination outside Nigeria. It may also be processed by staff operating outside Nigeria who work for us or one of our suppliers. Such staff may be engaged in, amongst other things, fulfilment of your order, provision of support or administration services, analysis of statistical data, or other functions as referred to in the Privacy Policy. By submitting your Personal Information, you agree to this transfer, storing or processing.
49. Whenever we transfer your Personal Information outside Nigeria, we ensure a similar degree of data protection safeguarding is afforded to it, by ensuring at least one of the following safeguards is implemented:
50. We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information.
K. UPDATING YOUR INFORMATION AND QUERIES
51. It is important that the Personal Information which we hold about you, is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
52. If you want to modify or update your registered details at any time, you can do this by informing us by any of the methods set out at below, of any changes in your Personal Information or marketing message preferences, and we will update or modify your Personal Information accordingly.
53. You can contact us with any queries or requests concerning your Personal Information or this Privacy Policy, by using the contact details shown on the Website “Contact Us” page and we will get back to you within 72 hours.54. If you wish to get in contact us about your Personal Information, kindly do so using the details below:
Contact email: enquiries@ebonylifeplace.com
Contact address: EbonyLife Place. 72B Ademola Adetokunbo Street, Victoria Island, Lagos, Nigeria