1. Introduction

This Privacy Policy is developed by Cotton Technology Solutions Limited (the “Company“) in compliance with theNigerian Data Protection Regulation 2019 and other similar regulations. It demonstrates the Company"s commitment to providing customers and other stakeholders with the highest level of protection for their personal data, which may be obtained during interactions with the Company.

2. Objectives

• Inform data subjects of their rights, responsibilities, and privileges.
• Ensure the protection of Clients' and other Stakeholders" information.
• Guarantee confidentiality as much as possible.
• Address and correct wrongdoing when discovered.

3. Scope and Applicability

This Policy applies to all employees, clients, and stakeholders of the Company. It highlights the basis upon which personal data collected from Clients and other stakeholders will be processed.

The Policy applies to both the Company"s website and any physical interactions with the Company, regardless of how such access or use occurs.

4. Interpretation

Personal Data:

Any information relating to an identified or identifiable natural person (Data Subject).

Data Subject:

A person who can be identified, directly or indirectly, via an identifier such as a name, ID Number, or location data.

Service Provider Data:

Details about service providers, including contact information and service details.

Processing:

Any operation or set of operations performed on personal data, such as collection, recording, or transmission.

5. Policy

This Privacy Policy describes your privacy rights with respect to personal information the Company may collect, use, store, or otherwise process when you engage our services. It applies to the Company"s website, database, applications, products, and any physical contact with us.

6. Responsibility of Data Subject

• Usernames, passwords, or other access credentials must be kept confidential and not disclosed to third parties.
• The Company reserves the right to disable access credentials if there is non-compliance with this Privacy Policy.
• All enquiries, complaints, or reports of data breaches should be forwarded to [email protected].

7. Consent

You accept this Privacy Policy when you give consent upon accessing the Company"s platforms, using its services, or visiting its office. The Company may amend this Privacy Policy by posting a revised version on its website or displaying notices in its office.

8. Use/Processing of Data

During onboarding and while using our website, we may collect personal information such as identification documents, name, address, phone number, and occupation. We may also use data from third parties for due diligence purposes.

We use your information to:

• Provide services and support.
• Recommend service providers.
• Verify your identity.
• Manage risks and prevent fraud.
• Detect and remediate violations of laws or regulations.
• Improve our services and infrastructure.