The following Book Me Innovations LTD. (this includes its affiliated companies

and subsidiaries, collectively, “Book Me” ,“our,” “we,” or “us”) is a service

provider platform which offers various services, including connecting users

with service providers in industries such as hair salons, nail salons,

barbershops, pet services, event planning, and more. At Book Me, we are

committed to protecting the privacy and security of our consumers’ and users’

personal data. We are committed to transparency, accountability and

confidentiality of your data. This is why our Privacy and Cookie Policy

(“Privacy Policy”) describes how we collect, use, store, share, and protect

personal data from Application Visitors, Book Me Users, and/or Vendors

(“Data Subjects”) who engage with our services. It applies to our Application

and all related sites, applications, services and tools (collectively, our

“Services”). While our services are primarily designed for businesses and

organisations (“Merchants”), we recognise that individual consumers may

interact with us through Merchants or website visits. We are committed to

responsibly processing personal data for everyone involved. We generally

process personal data at the direction of and on behalf of Merchants. When

we do, we do so as a service provider or a “Data Processor” to those

Merchants, but we do not control and are not responsible for the privacy

practices of those Merchants. If you are a Customer of a Book Me Merchant,

you should read that Merchant’s Privacy Policy and direct any privacy inquiries

to that Merchant. This Privacy Policy does not apply to services not owned or

controlled by Book Me, including third-party websites and the services of Book

Me’s Merchants. This Privacy Policy applies to all forms of systems,

operations and processes within the Book Me environment that involve

processing personal data. While offering the Services to you, Book Me may

create different products as part of the Services. When you opt in to use one

of our products, we will use your data for specific purposes, such as providing

and improving the service. We may also share your data with subprocessors

and partners, but only as necessary to offer the service you have opted into.

We will handle your personal data in line with the purposes and methods

outlined in this Privacy Policy.

1. THE INFORMATION WE COLLECT

The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We may collect information from different sources and in various ways, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.

1.1 Personal Data You Provide Directly

We collect personal data you provide to us. For example: Contact information: As part of our operations, Book Me may collect information such as your name, telephone number, email address, address, etc. to provide you with certain services. Payment information: If you make a purchase or other financial transaction, such as when you checkout with a third party or Merchant’s website, your credit card numbers, financial account information, and other payment details may be collected. Communications: If you contact us directly, for example, with an inquiry or a support request, we may receive additional personal data about you, including your email address and the content of your communications.

1.2 Personal Data We Collect Automatically

Automatically Device Information: We receive information about the device and software you use to access our Services, including Internet Protocol (IP) address, web browser type, operating system version, and device identifiers. Usage Information: To help us understand how you use our Services, including the Demo portion of our Application (if any), and to help us improve them, we automatically receive information about your interactions with our Services. This information includes records of your transactions and information about your other activities related to our services, such as the date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. Some of the data we gather through cookies and similar technologies as discussed below. Location Information: We may collect or infer your general location information when you use our Services. For example, your IP address may indicate your general geographic region, which will be matched against our IP whitelist.

1.3 Personal Data That We Receive from Others

Personal Data That We Receive from Other Partners: We may

retrieve additional personal data about you from third parties and other

identification/verification services, such as your financial institution and

payment processor. We may combine that data with other information we have about you. Publicly available sources: We may also gather additional data about you from public sources of information, such as open government

databases. Inferences: We may infer additional Personal Data based on the

Personal Data described above. For example, we may infer your interests for

website visitors based on the web pages you view. When you are asked to

provide personal data, you may decline. And you may use web browser or

operating system controls to prevent certain types of automatic data

collection. But if you choose not to provide or allow information necessary for certain services or features, those services or features may not be available or fully functional.

2. HOW WE USE PERSONAL INFORMATION

HOW WE USE PERSONAL INFORMATION We use the

Personal Data we collect to: i. Provide you with the required services in

addition to related products and services of interest, ii. Respond to your

questions or requests, iii. Improve features and Application content, and

analyse data to develop products and services, iv. Address inappropriate use

of our Application, v. Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools, vi. Send you marketing content, newsletters and service updates curated by Book Me (only with your explicit consent), vii. Verify your identity and the information you provide in line with Book Me’s statutory obligations using internal and third-party tools, viii. Maintain up-to-date records, ix. Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies, x. Any other purpose that we disclose to you in the course of providing Book Me services to you.

3. HOW WE SHARE PERSONAL DATA

Book Me does not sell, trade or rent

personal data to anyone. Further, we will not share or disclose your data with

or to a third party without your consent except as necessary to provide the

Services or as described in this Privacy Policy. Service providers: We share

personal data with vendors or agents working on our behalf for the purposes

described in this statement. For example, companies we’ve hired to provide

customer service support, to protect and secure our systems and services, or

to perform sanctions screening and identity verification services may need

access to personal data to provide those functions. The processing by such

third parties shall be governed by a written contract with Book Me to ensure

adequate protection and security measures are put in place for the protection of personal data in accordance with the terms of this Privacy Policy. Financial services & payment processing: When you provide payment data, for example, to make a purchase, your payment and transactional data may be shared by the payment platforms with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services. Affiliates: We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide services and operate our business. Partners: We may share your data with companies we partner with for industry networking events, mixers, and other learning and development opportunities, but only with your explicit consent and with the option to opt out. Corporate transactions: We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, transfer, divestiture, or sale of all or a portion of our business or assets. Legal and law enforcement: We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies. Security, safety, and protecting rights: We will disclose personal data if we believe it is necessary to: i. Protect our Users and others, for example, to prevent fraud or to help prevent the loss of life or serious injury of anyone; ii. Operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or iii. protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies. We leverage third-party analytics to analyse personal data collected through our application, including account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. This data is aggregated and enables us to perform analytics and track the performance of our Application. Finally, we may share de-identified information in accordance with applicable law. Please note that merchants, sellers, and other Users you buy from or contract with have their respective privacy policies, and although Book Me’s Terms of Use does not allow the other transacting party to use your information for anything other than as authorised by you, Book Me is not responsible for their actions, including their data protection practices. If you provide personal data to any of those third parties or allow us to share

personal data with them, that data is governed by their privacy policies.

4. COOKIES

We and our partners use cookies and similar technologies on our

Application to help collect information and operate the Application. We use

cookies to remember Users and make your user experience easier; customise

our services, content and advertising; help you ensure that your account

security is not compromised; mitigate risk and prevent fraud; and to promote

trust and safety on our Application. Cookies are small text files placed by a

website/application and stored by your Application on your device. You can

learn more about the types of cookies we use through the Cookie Banner on

our Application. Our cookies hold a unique random reference to you so that

once you visit our platform, we can recognise who you are and provide certain content to you. Most web browsers are set to accept cookies by default. You can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this may impact your experience using our website.

5. HOW WE PROTECT YOUR INFORMATION

Book Me has established adequate technical and organisational controls to protect the integrity and confidentiality of personal data, both in digital and physical format and to prevent personal data from being accidentally or deliberately compromised. Book Me is committed to managing your data in line with applicable data protection laws and best practices. We protect your data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration, we also use industry recommended security protocols to safeguard your data. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files. They only grant access to personal data to employees who require it to fulfil their job responsibilities. Employees may have access to personal data only as is appropriate for the type and scope of the task in question and are contractually forbidden to use personal data for their own private or commercial purposes or to disclose them to unauthorised persons, or to make them available in any other way. Personal Data Breach At Book Me, we take the security of personal data seriously and have implemented measures to prevent data breaches from occurring. However, in the event of a data breach, we have established procedures for reporting and managing incidents. Book Me also maintains a data breach procedure to deal with incidents concerning personal data or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. You may contact our Data Protection Officer (DPO) upon becoming aware of any breach of personal data or if your access credentials have been compromised to enable us to take the necessary steps towards ensuring the security of your data or account. When we become aware of a data breach that affects personal data, we will notify the affected individuals and relevant authorities in accordance with applicable data protection laws and regulations. The notification will include the following information: The notification will include the following information: i. A description of the nature of the data breach, including the categories of personal data involved ii. The likely consequences of the data breach iii. The measures taken or proposed to be taken by Book Me to address the data breach, including any measures to mitigate its possible adverse effects We will notify affected individuals without undue delay, but no later than 72 hours after becoming aware of the data breach, unless there are exceptional circumstances that prevent us from doing so. We will also record any data breaches and provide this information to the relevant authorities upon request. We encourage all users and customers to take reasonable steps to protect their data, such as using strong passwords, regularly updating their account information, and reporting any suspicious activity to us immediately. We will report any breaches that will compromise your rights and freedoms to the Relevant Authority within 72 hours of discovery.

6. STORAGE LIMITATION

STORAGE LIMITATION

We will retain your information for the following periods: i. As long as

reasonably necessary for providing our services to you ii. For the duration

your account is active (if applicable) and we have your consent iii. For the

period needed to comply with our legal and statutory obligations iv. As needed to verify your information with a financial institution Upon expiration of the applicable storage limitation periods, we will delete, erase, anonymise or pseudonymise any information we hold about you. This Privacy Policy also

applies when we retain your Personal Information after our relationship ends.

We may also retain your Personal Information for the duration of any period

necessary to establish, exercise or defend any legal rights. We may keep

Personal Information indefinitely in a de-identified format for statistical

purposes, which may include, for example, statistics of how you use the

Services.

7. TRANSFER OF DATA

As part of our service provision, we may rely on third-party servers, resident in foreign jurisdictions, which constitutes transferring your data to computers or servers in foreign countries. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law, wherever the data is located. At Book Me, we take the security of personal data seriously. When personal data needs to be transferred to a country outside of Nigeria, we implement adequate measures to ensure the data remains secure. We comply with all relevant data protection regulations and guidelines to ensure that personal data is always protected. Specifically, we use contractual terms to ensure that the personal data is adequately protected or that the country to which the data is being transferred has adequate data protection laws in place. We take additional measures to ensure that the country to which the data is being transferred meets our standards for data protection. Should you wish to transfer your personal data to a country deemed to have inadequate data protection laws, Book Me will take all necessary steps to ensure that it is transferred under relevant, appropriate safeguards, and where relevant, with your informed consent, and  that you are made aware of the risks associated with such a transfer. In any instance, Book Me will ensure personal data is transmitted safely and securely. Details of the protection given when your data is transferred abroad and details of the basis of such transfers shall be provided to you upon request.

8. GROUNDS FOR PROCESSING OF PERSONAL DATA

Processing of Personal Information by Book Me will be lawful if one of the

following applies: i. The Data Subject has given consent to the processing of

his/her Personal Information for one or more specific purposes. You can

revoke your consent by closing your Book Me account (where applicable)

and/or by emailing us; ii. The processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering into a contract; iii. Processing is necessary for compliance with a legal obligation to which Book Me is subject; iv. Processing is necessary for legitimate interests pursued by Book Me or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data; and v. Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Book Me.

9. CHOICES AND RIGHTS

At Book Me we respect the rights of our customers and users, and we allow
you to exercise them under the applicable data protection laws and
regulations. Individuals who have Personal Information held by Book Me are
entitled to reach out to Book Me to exercise the following rights:
i. Right to request for and access any Personal Information collected and
stored by Book Me. This right allows you to request a copy of your
personal information held by Book Me. To exercise this right, you can
submit a request to the Data Protection Officer (DPO) or to our Data
Subject Rights Team at Support@bookmebusiness.com;
ii. Right to be informed regarding the use of your Personal Information;
iii. Right to be informed about appropriate safeguards in place whenever
your personal information is transferred abroad;
iv. Right to object to automated decision making and processing. You have
the right to object to the processing of your personal information and to
exercise this right you can submit a request to the DPO or our Data
Subject Rights Team;
v. Right to request rectification and modification of Personal Information
whenever you want us to correct your inaccurate or incomplete
personal information which Book Me keeps;
vi. Right to request the deletion of their personal information;
vii. Right to request the movement of your personal information from Book
Me to a third party – this is the right to the portability of data;
viii. Right to revoke consent;
ix. Right to object to direct marketing, and to request that Book Me restricts
the processing of their information; and
x. Right to submit a complaint to the Nigeria Data Protection Commission
(NDPC).
Your request will be reviewed and answered by Book Me’s Data Protection
Officer within a 30-day period.

10. COMPLIANCE TO CHILDREN’S PRIVACY

Our Services are all directed to people at least 18 years old or older.
We do not knowingly collect any “personal data” (as defined by the Nigeria
Data Protection Regulation) from anyone under 18 without valid parental
consent. If we become aware that we have collected such personal data
without parental consent, we will take reasonable steps to delete it as soon as
possible.

11. CHANGES TO THIS PRIVACY POLICY

We may need to update, modify or amend our Privacy Policy as our
technology evolves and as required by law. If we materially change how we
use or share personal data previously collected from you through our
Services, we will provide notice or obtain consent regarding such changes as
may be required by law. The Privacy Policy will apply from the effective date
provided on our website.

12. POLICY VIOLATIONS

Any violation of this Privacy Policy should be brought to the attention of the
Data Protection Officer (details below) for appropriate sanctioning and
treatment.

13. CONTACT PAYSTACK’S DATA PROTECTION OFFICER (DPO)

If you have any questions relating to this Privacy Policy or would like to find
out more about exercising your data protection rights, please reach out to our
DPO via email at Support@bookmebusiness.com