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Current as of 25 Dec. 2025

Pouchers Privacy and Cookie Notice

By accessing or using the Pouchers website, mobile application, or any related services, you agree to be bound by these Terms of Use and confirm that you are responsible for compliance with all applicable laws and regulations.

Contents

  1. Overview of this Policy
  2. Data Collection and What Constitutes your consent?
  3. Who Handles Your Personal Data?
  4. How we use Cookies
  5. Use of Your Personal Data
  6. Sharing Your Personal Data
  7. Record Retention
  8. Transferring Your Data to Other Countries
  9. What are Your Rights?
  10. How do we Protect Your Personal Data?
  11. Remedies for Violation of the Privacy Policy and Timeframe for Remedy
  12. Additional Details
  13. Changes to this Privacy Policy

1. Overview of this Policy

Pouchers (“we”, “us”, or “our”) take the personal data of our Data Subjects that we collect seriously. We understand the need to treat such information as confidential and to use it strictly for the purpose for which it was obtained and in accordance with applicable extant laws. We are therefore committed to treating personal data received through our product offerings, website, (pouchers.io), app and other platforms with due care and are dedicated to safeguarding the personal data of our Data Subjects.

More importantly, we are bound by the Nigeria Data Protection Act (NDPA) 2023. Therefore, in accordance with the obligations bestowed on Data Controllers and Data Processors under the NDPA, this document outlines the Privacy and Cookie Policy for Pouchers and how we collect and process your personal data when you use our website or mobile applications.

2. Data Collection and What Constitutes your consent?

2.1 Our aim in collecting personal data is to improve the quality of our products and services. We may collect, use, store and transfer the following types of personal data:

  • Information you provide to us, such as your contact data, identity data and financial data.
  • Information about your usage of our website and/or mobile applications, including downloads, searches, views and purchases.
  • Information obtained from third-party sources, such as carriers, payment service providers, merchants/brands, and advertising service providers.

Before collecting such data, we will seek your consent.

2.2 However, by providing your personal data to us, you have signified your acceptance of our Privacy Policy and agree that we may collect, use, and disclose your personal information for specified purposes as described in this Policy.

3. Who Handles Your Personal Data?

According to the NDPA, this responsibility rests upon the “Data Controller”, namely:

Pouchers (Pouchers Technology Ltd), Nigeria.

If you have any general questions or concerns about this Policy, as well as queries or complaints about the way in which we process your personal data, kindly contact our Data Protection Officer via the contact details above or through the following email addresses: [email protected].

4. How we use Cookies

We use cookies to improve your browsing experience and distinguish you from other users of our website and mobile applications. Cookies help us count visitors, track site usage, identify preferences and subscriptions, and send tailored commercial/advertising messages based on your interests. Our approved third parties may also set cookies when you use our marketplace.

Cookies also enable you to access our website faster and have a better experience online. The cookies can be disabled, if you wish, by clicking on the appropriate prompt. However, some parts of our websites or online services may not work if you do so.

5. Use of Your Personal Data

We collect your personal data for the sole purpose of providing, improving and enhancing our products and services. Your data enables us to perform tasks such as registering you as a new customer, managing your account, processing and delivering your orders, enhancing our website and applications, and preventing and detecting fraudulent activities.

We will also create a username (pouchers tag) for you at sign up and request access to your contact information to connect you with other users who have pouchers tag on your list.

6. Sharing Your Personal Data

To fulfill our services and obligations, we may share your personal data with third parties for purposes such as product and service delivery, third-party service providers, payment transfers, and fraud and abuse prevention; exchanges; regulators; law enforcement agencies; courts; public authorities; and potential purchasers of elements of our business. When sharing your data, we ensure that third parties use it according to our Privacy and Cookie Notice and applicable laws.

Additionally, we disclose that these third parties could be located outside Nigeria. However, where such disclosures are necessary it shall be in line with the provisions of the NDPR and other terms stated in this policy.

We may share information about you with a range of third parties for our business purposes or as permitted/required by law. Such third parties may include our service providers; professional advisors; background screening providers; health maintenance organizations; financial institutions.

7. Record Retention

In line with the record preservation requirements of the Money Laundering (Prevention and Prohibition) Act, 2022 (as amended), Pouchers will retain your personal data for a minimum period of five (5) years after your relationship with us has ended. This is to enable us to fulfil the relevant purposes set out in this Policy and to comply with our regulatory obligations.

However, we may retain personal data for longer periods where this is in our legitimate business interests or required to comply with applicable laws, regulatory requirements, litigation, investigations, or enforcement actions. We will continue to use and disclose such personal data in accordance with this Privacy Policy.

8. Transferring Your Data to Other Countries

Where necessary, information relating to you may be transferred to countries outside Nigeria (i.e. third countries). However, where we engage service providers located in a third country, such service providers will be obligated to apply the same level of protection to your personal data as would be required under Nigerian law. We enforce this through the inclusion of standard data protection clauses in our agreements with such service providers and by conducting vendor security and due diligence assessments.

Above all, we will only transfer your personal data to a third country in a manner that is permitted under the Nigeria Data Protection Act (NDPA)

We may also share your information with our affiliates. Affiliates include our parent company (if any) and any subsidiaries, joint venture partners, or other entities that we control or that are under common control with us.

9. What are Your Rights?

Subject to data protection laws, you are entitled to the following rights:

9.1 Request to Access, Rectify, or Erase

Access Request:
You have the right to access personal data relating to you. This enables you to receive a copy of the personal data we hold about you in electronic form, unless you request a paper copy, which may attract a fee.

Rectification Request:
You have the right to ask us to correct your personal data where it is inaccurate and to have incomplete personal data updated without undue delay.

Erasure Request:
You have the right to ask us to erase your personal data where:

  • Your personal data are no longer necessary for the purpose(s) for which they were collected;
  • Your personal data have been unlawfully processed;
  • Your personal data must be erased to comply with a legal or regulatory obligation;
  • You withdraw your consent to the processing of your personal data (where consent is the sole legal basis for processing);
  • You object to processing based on our legitimate interests and there are no overriding legitimate grounds for continued processing; or
  • You object to the processing of your personal data for direct marketing purposes.

Where we have made the relevant personal data public, we will take reasonable steps to inform other data controllers processing such data so that they may erase any links to, or copies of, your personal data.

9.2 Request to Object

You have the right to object at any time to the processing of your personal data where such processing is based on our legitimate interests or where we are acting in the public interest. This includes any form of “profiling”. Our Privacy Policy identifies circumstances in which we rely on legitimate interests to process your personal data.

In such cases, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds for continuing the processing. We may, however, reject your request where the processing is necessary to establish, exercise, or defend legal claims.

You also have the right to object at any time where we process your personal data for direct marketing purposes, including profiling related to such marketing. In these circumstances, we will stop processing your personal data upon receipt of your objection.

9.3 Request to Restrict Processing

You have the right to request that we restrict the processing of your personal data where:

  • You contest the accuracy of your personal data and we are verifying the data we hold;
  • The processing is unlawful and you prefer restriction to erasure;
  • We no longer require your personal data for the original purpose(s) of processing, but you require the data to establish, exercise, or defend legal claims; or
  • You have objected to processing based on our legitimate interests while we assess whether our legitimate grounds override your rights.

9.4 Request for Data Portability

You have the right to request that personal data you have provided to us be transferred to another third party in a commonly used electronic format. Once transferred, the receiving party will be responsible for safeguarding such personal data.

9.5 Request to Object to Automated Decisions

You have the right to object to decisions that produce legal effects concerning you or otherwise significantly affect you where such decisions are based solely on automated processing of your personal data, including profiling.

We may refuse such a request where the automated decision is:

  • Necessary for entering into, or the performance of, a contract between you and Pouchers; or
  • Permitted under applicable laws or regulations.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 3 above.

9.6 Withdrawal of Consent

You have the right to withdraw your consent to the processing of your personal data at any time. Pouchers ensures that the process for withdrawing consent is clear, accessible, and easy for Data Subjects to use.

10. How do we Protect Your Personal Data?

We store personal data as required by law, and such data is held in Nigeria, electronically. Our security systems are designed to prevent the loss, unauthorized destruction, damage, and/or access to your personal data by unauthorized third parties. Some of our security measures include physical access controls to our premises, cybersecurity controls, and information access authorization controls.

We will also publish security tips and updates from time to time on our website (pouchers.io) to help you benefit from our security systems and stay informed of the latest fraud scams and trends. While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information, and for verifying that the personal data we maintain about you is accurate and up to date.

We will duly inform you of any breaches that may threaten the security and confidentiality of your personal data.

11. Remedies for Violation of the Privacy Policy and Timeframe for Remedy

In the event of a violation of this Policy, our Data Protection Officer shall take steps to redress the violation within 7 days. Where the violation pertains to the disclosure of your personal data without your consent, such information shall be retracted immediately, and confirmation of the retraction will be sent to you within 48 hours of the redress.

12. Additional Details

If you require additional information regarding the processing of your personal data or wish to exercise your legal rights, please contact us at [email protected].

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time in order to address amendments in the NDPA or our business operations. We will notify you, by email, if we make any significant updates.

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