Privacy

3. What are your personal data rights?

You may exercise your rights free of charge at any time using the form available on our main website jolojolo.com>>Contact us>>Policies, or in the App, entering to: Help>>Not related to an order>>Policies.  

To exercise your rights click HERE. If you have any questions, you can write to us at dataprotection@jolojolo.com.

You may exercise the following rights:

1. The right of access to your personal data to know which data is being processed and the processing operations carried out thereon;
2. The right to correct any inaccuracies in relation to your personal data;
3. The right to the erasure of your personal data, where possible; by sending us a data erasure request
4. The right to request the restriction of processing of your personal data when the accuracy, legality or need for processing of the data is in question, in which case we may retain the data for the purpose of filing or defending claims.
5. The right to request portability of your data to another service provider. We will give you a copy of your data so that you can provide it to another service provider. If you request us to do so and it is technically possible, we will transfer the data directly to that other service provider on your behalf.
6. The right to object to the processing of your data in order to resolve any query you may have raised with us through the contact form (website: jolojolo.com>>Contact us>>Policies or on the Platform: Help>>Not related to an order>>Policies) and the right to object to the processing of your data on social media and/or for the purpose of processing your CV.
7. If you are the User, and you don’t want to receive any marketing communications, you have the right to unsubscribe to any marketing communication, by sending an e-mail or by using the link provided for this purpose in every commercial communication.

Please note that disabling push notifications will also prevent you from     receiving notifications about the status of any order.

You can, at anytime, object to profiling by sending an email to: dataprotection@jolojolo.com

If you believe that Jolojolo is in breach of data protection law, you may escalate to the relevant authorities in Nigeria.

Please take into account that there may be some situations where the above rights could not be exercised or effectively executed by Jolojolo, for example when asking us to erase all your personal data where there is contractual relationship with us. 

Notifications and Modifications

Due to the constant evolution of Jolojolo’s activities, this Privacy Policy, the Cookie Policy and the Terms of Use are also subject to change. 

Jolojolo will send all users/ couriers / Prospective Team Members/ Partners/ Investors/ Prospects/ Website Visitors notifications about substantial changes and modifications to such documents by email or through any other method that ensures their receipt. 

In any case, Jolojolo will, in no event, modify its policies or practices to make them less effective in the protection of our customers’ previously stored personal data.

4. Who is a Data Controller of your data? 

The Data Controller of your Personal Data in relation with the use of Jolojolo Platform and of the other forms is Jolojolo Logistics Limited. 

In addition to the information provided above, details of Jolojolo Logistics Limited can be found on its website – www.jolojolo.com. 

Furthermore, Jolojolo may share the data of those users (“Users”) or couriers (“Couriers”) who register on Jolojolo website or (the “Jolojolo Platform”) and of those persons who contact Jolojolo using the forms available on its Platform for the purpose of offering the services requested by Users through the Platform.

5. Useful information if you are a USER: 

5.1 What are the data processing purposes and the legitimate basis of the processing? 

Jolojolo will process your the personal data for the following purposes: 

1. For legal purposes.
2. For contractual purposes.
3. For security purposes.
4. For statistics and research purposes.
5. For marketing and commercial purposes.
6. For non-marketing purposes.

Legal purposes

Jolojolo processes your personal data to:

1. i)detect and investigate fraud and possible crimes committed against our  Platform and all the users,
2. ii)comply with the legislation in case any legal regulations oblige us to keep your data for a defined period of time (please check Annex I on data retention),

iii) manage and execute your request(s) to exercise the rights established in the  NDPR and other local regulations,

1. iv)file, submit and defend legal actions against any entity of our Group,
2. v) in any of the cases above-mentioned, Jolojolo shall be entitled to use any data obtained from you or arisen from your activity through our Platform (e.g. conversations between you and the Partner, you and the Courier, you and our Platform using the chat system) for the purpose of filing and/or defending any claims and/or legal actionsthat may be necessary, and to manage any incidents arising in connection with the user’s orders.

Contractual purposes

Jolojolo processes your personal data for:

1. i)grant you the possibility to create your own account,
2. ii)provide you with the services you have requested and any additional features on the Platform,

iii) locate the nearest partners and courier to the delivery point informed by you (which may involve using geolocation services, if you agreed to them when asked to by the Platform, as described above),

1. iv)perform payment processing and collection on behalf of you,
2. v)communicate your order to the partner selected by you and update you on the status of your order,

vii) assist you in your decisions and use of the service, including the possibility to quickly reorder from the stores, where you have ordered in the past or suggest you stores based on your past orders or “popularity” among new users. Additionally, we could assist you in your decisions through automatically determined filters by the historical order you have placed in the past, providing in each case specific contents in the Platform tailored for you, 

viii) send you the receipt corresponding to your orders,

1. ix)provide you with a customer service to manage any incident related to you orders and being able to answer your questions or consultations,
2. x)allow your direct contact with the courier in charge of your order,
3. xi)be contacted by our Partners in case of any incident with your orders,

xii) process reimbursements and refunds both via promo-codes or bank refunds,

xiii) notify you concerning changes or updates to our services, terms and conditions, privacy policy, cookies policy and any other corporate document that may affect you in a substantial way.

Security purposes

Jolojolo processes your personal data for:

1. i)use device, location (including geolocation data, if you agreed to), profile, usage, and other data to prevent and detect malicious or unsafe activities (e.g. payment fraud, identity fraud, account hacking, phishing, incentive abuses). In particular, Jolojolo uses your device’s IP address to detect fraudulent activity on your device and to keep the platform away from attackers who may try to access your account by impersonating you; 
2. ii)monitor all actions that could cause fraud or in the commission of a criminal offence related to the payment method employed by you; if any irregularities are detected, Jolojolo reserves the right to retain the data provided and share it with the competent Authorities in order to carry out the relevant investigation,

iii) make sure that you follow the legal requirements related to specific products you may order through the Platform (e.g. legal age for alcoholic beverages).

For statistics and research purposes

Jolojolo processes your statistics based on your Personal data to:

1. i)analyse trends, purchase behaviour and characteristics,
2. ii)understand how you use our Platform,

iii) manage and improve the services offered, including the possibility of adding new or different features and services to improve the quality of the services.

Marketing and commercial purposes 

Jolojolo processes your personal data to:

1. i) carry out marketing, communications, research and development activities,
2. ii) analyse and research how to improve our services both offline and on the Platform, by using the data provided by you (such as in focus groups, reviews, valuations of the services, satisfaction survey, feedback or any kind, etc.),

iii) provide you with personalised offers, promotions, discounts, suggestions, views and options on Jolojolo Platform, by email or by any other communication means, including the use of cookies or other technologies for advertising in third party websites or apps, according to our Cookie Policy and only if you have agreed to.

1. iv)carry out promotional activities for the delivery of samples or free products inside the order placed by you, which may be of your interest to promote Jolojolo’s and our partner’s products or services.
2. v)carry out promotional activities such as contests, raffles, tenders, quizzes, competitions between users when they have subscribed and/or sent their data for such campaigns,
3. vi)create custom audiences with Facebook or other providers to reach out to you or other people with similar characteristics, who might be interested in using Jolojolo services; you can manage your privacy in your Facebook or other third party platform settings,

vii) use as commercial or marketing material published by you on your social networks profiles when Jolojolo has been expressly mentioned by you (i.e. via hashtag or @).

We may personalize the marketing communications by using the user activity on Jolojolo Platform (including your past orders) and the interaction with Platform, online advertising, previous emails, promotions, etc. However, this personalization is not made only by automated means, nor have any legal effect or affect the user similarly.

Jolojolo may use push services on the user’s mobile device to provide marketing communications. If the user does not want to receive these marketing communications, he / she shall unsubscribe in the notifications centre. Please note that disabling push notifications will also prevent the user from receiving notifications about the status of any order.

Non-marketing purposes

Jolojolo processes your personal data to:

1. i)generate and provide you with receipts from each of your orders placed through Jolojolo Platform.
2. ii)inform you about any incident on the Platform or the operation of the services, including incidents related to your orders. This information can be sent by e-mail or SMS messages, and any other messaging application, that may be used by you and Jolojolo at any moment,

iii) inform you about any changes to our Terms and Conditions, privacy policy, cookies policy, services, and more generally to inform you about any relevant non-marketing communications,

1. iv)process incidents and claims with insurance companies in the event you report the occurrence of any damages or unforeseen events that may be covered by Jolojolo’s insurance policy.

5.2 What kind of data do we hold about you and how is your personal data collected?

Jolojolo holds the following data about you: 

1. Information supplied directly by you:

1.1. Registration Data: the information provided by you when you create an account on the Jolojolo Platform: username and e-mail.

1.2. User Profile Information: the information added by you on the Platform in order to be able to use Jolojolo’s service e.g. your mobile phone number and delivery address. You can view and edit the personal data on your profile whenever you wish. 

1.3. Payment information: payment information when processing your orders; card data will be processed by our electronic payment service providers, who will receive the data directly from you. Jolojolo will have access to this information only for complying with the request of any competent authority,  

Jolojolo offers its users to store the payment information or card details. In this case, the card details are tokenized (converted in a unique code). This token is usable Jolojolo Platform, allowing Jolojolo to facilitate the use of the Platform by preventing the introduction of the card details each time you want to perform a payment and provide additional security, as the details of the card are never stored in our systems. You can erase this token at any moment in your profile area.

1.4. Additional information: any information that you could supply to Jolojolo for other purposes, e.g. your photograph or the billing address in the case if you have asked to receive invoices from Jolojolo.

1.5. Information about previous communications with Jolojolo: information supplied by you for the resolution of any queries or complaints about the use of the platform, whether through the contact form (website: jolojolo.com>>Contact us>>Policies, App: Help>>Not related to an order>>Policies), by e-mail or by phone through the customer service.

1.6. Information regarding any accidents: information of any of the parties involved in the provision of services through the Platform for the purpose of making insurance claims or carrying out any other actions with the insurance companies contracted by Jolojolo.

1.7. Information of conversations held with Jolojolo: Transcription and recording of conversations for the processing of incidents, queries or other consultations that may be made to guarantee and improve the quality of our services and for security reasons.

1.8. Information on Communications: communications exchanged between you and the couriers on the chat system provided on Jolojolo Platform whenever it is necessary to address any incident or discussion between users and couriers, or to comply with any request made by authorities. Jolojolo will never access the communications if it is not strictly necessary and will always ensure the privacy of its users and the confidentiality of all information exchanged on its platform.

1.9. Any additional information that you provide in your requests, comments or questions.

2. Information indirectly supplied by Users:

2.1. Data arising from the use of Jolojolo Platform: Jolojolo collects the data arising from your use of the Platform every time you interact with Jolojolo Platform.

2.2. Data on the application and the device: Jolojolo stores data on the device and the Application used by you to access the services: 

1.  i)the IP address used by you to connect to the internet using your  computer or mobile phone, and to prevent fraudulent misappropriation or unauthorized access to your account by third parties.
2.  ii)information about your computer or mobile phone, such as your internet connection, browser type, version and operating system, and type of device.

   iii) the full uniform resource locator (URL) clickstream (the information related with your navigation through our website or the application, links followed, etc.), including date and time,

1.  iv)data from your account: information on the orders made by you, as well as feedback and/or comments made by you,
2.  v)your browsing history and preferences.

2.3. Data arising from the User’s origin: if you arrive at the Jolojolo Platform through an external source (such as a link from another website or a social network, as long as you have authorised it on those websites), Jolojolo collects data on the source from which you arrived. 

2.4. Data resulting from the management of incidents: if you contact Jolojolo Platform through the Contact Form ( website: jolojolo.com>>Contact us>>Policies or Jolojolo Platform: Help>>Not related to an order>>Policies), Jolojolo chat or on Jolojolo’s phone number, Jolojolo will collect the messages received in the format used by you and may use and store them to manage current or future incidents.

2.5. Data arising from “cookies”: Jolojolo uses its own and third-party cookies to facilitate browsing by its users and for statistical purposes, among others (please refer to the Cookie Policy for more details).

2.6. Geolocation Data: provided that you have authorised this, Jolojolo will collect data relating to your location, including the real-time geographic location of your computer or mobile device.

2.7. Data resulting from external third parties

1.  i)Jolojolo collects personal data or information from external third parties only if you authorise such third parties to share that information with Jolojolo. For example, if you create an account through your Facebook or Google account, these platforms could disclose to us your personal data that can be found on your Facebook/Google profile (such as name, gender or age).

      ii) If you choose to send messages to us from social media networks (including X, Facebook and WhatsApp), we will collect that information you provide to us for the purposes set out in this privacy policy, including responding to your inquiry, providing you with customer support and resolving issues.

5.3. What are the recipients of your data and why are we communicating it?

Jolojolo warrants that all commercial partners, technicians, suppliers or independent third parties are bound by contractually binding promises to process the information shared with them in accordance with Jolojolo’s indications, this Privacy Policy and the applicable data protection legislation. 

We will not disclose your personal data to any third party who does not act under our instructions and no communication will involve selling, renting, sharing or in any other way revealing customers’ personal information for commercial purposes in breach of the commitments made in this Privacy Policy.

When carrying out an order, data may be shared with:

1. The Courierwho carries out the task of collecting and delivering the product.
2. The establishment or venue in charge of selling the product, if you have requested the purchase of a product. If you contact the above-mentioned providers directly and give them your data directly, Jolojolo will not be responsible for the providers’ use of such data.
3. The Customer Care Servicescontracted by Jolojolo for the purpose of warning you of any possible incidents or asking why negative feedback has been given; data will be used to manage any incidents that may occur during the provision of the services.
4. The payment Platformand payment service providers so that the amount can be charged to your account.
5. Telecommunications service providers, when they are used to send communications regarding orders or incidents relating to orders.
6. Providersrendering satisfaction survey services on Jolojolo’s behalf.

Sharing your data with third parties:

To continue providing the services offered through Jolojolo Platform, the Platform may share your certain personal data with:

1. Service providers:service providers that send parcels, carry out orders and/or resolve incidents with deliveries have access to your personal information as may be necessary only to carry out their functions. They must process the said personal information as provided in this Privacy Policy and in the applicable data protection legislation.
2. Pharmacies:Jolojolo may provide your name and phone number to pharmacists dispensing products to those users, to ensure the provision of pharmaceutical advice according to the current applicable legislation.
3. Payment Service Providers:When you enter your card number on Jolojolo Platform, this is stored directly by the Payment Platforms contracted by Jolojolo, which allows payment to be charged to your account. Payment service providers have been chosen based on their security measures and in any event complying with the security measures stipulated in the payment service legislation, and they are PCI Compliant under the Payment Card Industry Data Security Standard or PCI DSS. Jolojolo does not store such data in any event.
4. Service providers for fraud control purposes:Jolojolo will share your data with fraud control service providers to assess the risk of the transactions carried out.
5. Service providers for the anonymisation of some data:In order to prevent the misuse of your data by third-party service providers, your data may be being anonymised so that it can be used solely for the provision of the service. For example, Jolojolo may assign your telephone numbers to third parties in order to anonymise them and provide them in this format to the providers used to carry out the services contracted by you.
6. Security companies and Law Enforcement Forces and Agencies:Jolojolo may disclose personal data on its customers’ accounts if such disclosure is necessary to comply with the law, to enforce or apply the “Terms of Use” or to protect Jolojolo’s, its users’ or third parties’ rights, property or safety. It includes the exchange of information with other companies (for example, Jolojolo uses Google’s reCAPTCHA Enterprise service to protect users from cyber attacks or threats to their accounts)  and organisations and with Law Enforcement Forces and Agencies to protect against fraud and reduce credit risk.
7. Call centre and incident management services:In order to provide a Customer Service and call centres, actions to measure your degree of satisfaction and the provision of administrative support services, your data may be disclosed to companies located outside the European Economic Area.
8. Telecommunications services:In order to be able to provide you with telephone contact services, Jolojolo may contact telecommunications companies that provide secure lines and systems for the purpose of contacting you.
9. Social media connected by Users:If you connect your Jolojolo account to other social media or to a third-party platform, Jolojolo may use the information provided to such social media or third party in compliance with the privacy policy of the social media or third-party platform in question.
10. Third parties associated with Jolojolo for the purposes of commercial communications:Jolojolo may transfer your personal data to third parties associated with Jolojolo, provided that you have given your consentto such transfer of data and that you are aware of the purpose and recipient of such transfer.
11. Changes of ownership:If Jolojolo’s ownership changes or the majority of its assets are acquired by a third party, you are informed that Jolojolo will transfer your data to the acquiring organisations to continue to provide the services subject to the processing of data. As Jolojolo keeps growing continuously, we may buy or sell business units, assets, shares or legal entities, so data subjects’ information may also be transferred. That information, when acquired by Jolojolo, shall be processed as any other information as described in our privacy policy. You acknowledge that such transfer may occur and that we will be allowed to use your personal information for any of the purposes described in this Privacy Policy. The new file controller will inform users of its identification data. Jolojolo states that it will comply with its duty of information and it shall inform users of the change of file controller if and when this happens. This processing shall be carried out under the contract entered into with Jolojolo.
12. Insurance companies:Jolojolo may provide your data to those insurers and insurance brokers it collaborates with,  for the management and processing of claims and losses arising from the activity carried out by Jolojolo and the parties that collaborate with it.

Your data will not be disclosed to any third parties unless: 

1. i)this is necessary to provide the services requested if Jolojolo is collaborating with third parties ; 
2. ii)if Jolojolo has your express and unambiguous authorisation; 

iii) where this has been requested by a competent authority pursuant to its functions (in order to investigate, prevent or take action in relation to illegal actions);

1. iv)finally, where required by law.

Sharing your data with Jolojolo Partners

Jolojolo may share your data also with some of it’s top partners and only under some certain conditions: 

1. i)having obtained your expressed consent via consent checkbox which may appear (a) at the first order made by you or (b) in each order made by you previously to proceed with the check-out when placing an order through the partner store.

Once giving your consent, you will be able to withdraw it at any time, using Contact Form (website: jolojolo.com>>Contact us>>Policies or App: Help>>Not related to an order>>Policies). 

1. ii)having signed a Data Sharing Agreement with the Partner and ensuring that all legal, safety and technical measures are met.

5.4 How long will we keep your data? 

Jolojolo shall retain your data for the duration of the contractual relationship and, after this has come to an end, for the period established by law for filing or defending the appropriate legal actions. This is established at a maximum of fifteen (15) years in order to comply with Jolojolo’s legal obligations – which include the duty to assist the security forces as necessary in the investigation and prosecution of crimes pursuant to the higher interest of public safety – and defend itself or take any action in relation to criminal, tax and social security matters.

The said period may be shorter depending on the legal provision applicable to each purpose of data processing, as established in the table of retention periods set forth in Annex II.

ANNEX I – GENERAL RETENTION PERIODS

GENERAL