Introduction

Welcome to the PXP Travel Ltd.'s Privacy Policy.

PXP Travel Ltd. respects your privacy and is committed to protecting the Personal Information (meaning, every bit of information that identifies or can identify you) shared with us. This Privacy Policy will inform you as to how we look after your Personal Information when you use or visit any website, app, or portal that posts a link to this Policy (collectively, “the Sites”)(regardless of where you visit from) and tell you about your privacy rights and how the law protects you. Please see our Terms of Use for more information about our online terms and policies in general

1. Important information and who we are

   Purpose of this Privacy Policy

   This Privacy Policy aims to give you information on how PXP Travel Ltd. collects and processes your Personal Information through your use of the Sites, including any data you may provide through the Sites.

   It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data.

   Data Controller

   PXP Travel Ltd. is the data controller and responsible for your Personal Information.

   If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please send us an email at hello@PXP Travel Ltd..com

   Changes to the Privacy Policy and your duty to inform us of changes

   We will continually assess our privacy and data protection practices to ensure that your privacy is guaranteed. To this end, we keep our Privacy Policy under regular review. In the event that changes are made, we will indicate at the top of this Privacy Policy when it was most recently updated or send you a notification that the Privacy Policy has been updated. Either way, your continued use of the Sites will signify that you agree to any such changes. Please be assured that we will not use any previously collected Personal Information, to the extent that it is not collected under the new Privacy Policy, in a manner materially different than represented at the time it was collected. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

   Third-party links

   The Sites may include links to third-party platforms, plug-ins, portals or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of the Sites, we encourage you to read the Privacy Policy of every platform you visit.

2. The data we collect about you

   Personal Information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

   We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped as follows:

   • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
   • Contact Data includes physical address, email address and telephone numbers.
   • Transaction Data includes includes financial data and details about payments to and from you and other details of products and services you have requested from us
   • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, type of device used and other technology on the devices you use to access this website.
   • Profile Data includes your username and password, requests or orders made by you, your interests, preferences, feedback and survey responses.
   • Usage Data includes information about how you use the Sites.
   • Communications Data includes your communication preferences

   We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Information but is not considered Personal Information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

   
   

   We do not collect any Special Categories of Personal Information about you—this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

   
   

   If you fail to provide Personal Information

   Where we need to collect Personal Information by law, or under the terms to provide a service or product to you, and you fail to provide that data when requested, we may not be able to provide the service or product we have or are trying to provide to you. In this case, we may have to cancel a product or service you have with us but may still notify you if this is the case at the time.

3. How is your Personal Information collected?

   We use different methods to collect data from and about you including through:

   • Direct interactions. You may give us your Identity, Contact, and Transaction Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes Personal Information you provide when you:
     • apply for or subscribe to our products or services;
     • create an account on any of the Sites; or
     • give us feedback or contact us.
   • Automated technologies or interactions. As you interact with the Sites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies.
   • Third parties or publicly available sources. We will receive Personal Information about you from various third parties and public sources as set out below:

     Technical Data from the following parties:

     1. analytics providers such as Google based inside or outside Nigeria;
     2. search information providers based inside or outside Nigeria.
     • Contact and Transaction Data from providers of technical, payment and delivery services such as Paystack based inside or outside Nigeria.
     • Identity and Contact Data from data brokers or aggregators based inside or outside Nigeria.
     • Identity and Contact Data from publicly available sources.

4. How we use your Personal Information

   We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

   • Where we need or about to provide a service or product to you.
   • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   • Where we need to comply with a legal obligation.

   Purposes for which we will use your Personal Information

   We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

   Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.

LAWFUL BASIS

• Legitimate Interest means the interest of our mandate, object, and services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Provision of a Service or Product means processing your data where it is necessary for the performance of a service or product you requested from us and to which we have agreed or obliged to provide to you.

• Comply with a legal obligation means processing your Personal Information where it is necessary for compliance with a legal obligation that we are subject to.

Cookie and Other Tracking Technologies

A cookie is a small text file that includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet-enabled device when you visit an on-line site. Cookies and other tracking technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as "cookies".

We also use web beacons—electronic images (or single-pixel gifs) that we use to help deliver cookies on the Sites. We may also use web beacons in our emails. So when we send emails to you, we may track behavior such as who opened the emails. This allows us to measure the performance of our emails.

1. Withdraw Your Cookies Consent at Any Time

By consenting to this Privacy Policy, you also consent to the use of cookies on your devices. If you do not wish to accept cookies in connection with your use of our website, you may delete and block or disable cookies via your browser settings; see below for more information on how to do this. Please note that disabling cookies—especially strictly necessary cookies—will likely affect the functionality of our website.

2. How to Manage and Delete Your Cookies

Most internet browsers are initially setup to automatically accept cookies. Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you direct your browser to our website. You can refuse to accept cookies by activating the appropriate setting on your browser. Depending on your browser, further information may be obtained via the following links:

• Firefox

• Internet Explorer

• Google Chrome

• Safari

• Opera

The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy or more details regarding our use of Cookies and Other Tracking Technologies.

Change of purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your Personal Information

We may share your Personal Information with the parties set out below for the purposes set out in the table [Purposes for which we will use your Personal Information] above.

• Internal Third Parties including our employees.

• External Third Parties including (x) service providers acting as processors based in Nigeria or any other country who provide IT and system administration services; (y) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Nigeria or any other country who provide consultancy, banking, legal, insurance and accounting services; and (z)such other third parties as may be necessary to us and the use, safety, security, and performance of the Sites.

We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

6. International transfer

PXP Travel Ltd. is based in Nigeria and stores and processes your Personal Information on computers in Nigeria. Where we need to transfer your Personal Information to another country, we will take all reasonable steps to ensure that any such transfers comply with applicable law. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of Nigeria.

Where you are accessing the Sites or services from outside Nigeria, please note that any information collected may be processed in accordance with Nigerian laws, which may be different from the laws applicable in your country of residence.

7. Data security

We are very particular about preserving your privacy and protecting your data at PXP Travel Ltd.. Therefore, to avoid the loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction of your information, we have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

Despite this, we cannot completely guarantee the security of any information you transmit via the Sites, as the internet is not an entirely secure place. We have put in place procedures to deal with any suspected Personal Information breach and will notify you.

8. Data retention

How long will you use my Personal Information?

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorized 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 or regulatory.

9. Your legal right as a Data Subject

Because we determine the purposes for and the manner in which your Personal Information may be processed, we are regarded as a data controller. Likewise, because you can be identified directly or indirectly through certain categories of data that is specific to your identity, the law regards you as a data subject.

As a data subject, the law vests you with certain rights—they include the right to:

• Request access to the Personal Information we hold about you, and request correction of such information where you believe it to be inaccurate.

• Obtain a copy of the Personal Information we hold about you.

• Restrict the processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: If you want us to establish the data's accuracy; Should our use of the data be unlawful but you do not want us to erase it; Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Object to the processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

• Where feasible, receive all Personal Information you have provided to us—in a structured, commonly used, and machine-readable format—and to transmit the information to another data controller.

• Withdraw your consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Request the erasure of your Personal Information (also known as the right to be forgotten.)This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, in the event your information has been processed unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Lodge a complaint with a relevant authority, where you have reason to believe that we have violated the term(s) of this Privacy Policy. (You may lodge a complaint or seek redress from us within 30 days from the time you first detected the alleged violation.)

If you wish to exercise any of the rights set out above at any time, please send us an email at at hello@PXP Travel Ltd..com

No fee usually required

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may notify you and keep you updated.

10. Contact us

If you have any questions about this Privacy Policy or any suggestions on how we can improve its terms with respect to the Personal Information we collect, please email us at hello@PXP Travel Ltd..com