Privacy Policy | Cool Holdings

1

Introduction

Commitment to Privacy

COOL HOLDINGS LIMITED ("Cool Holdings", "we", "our", or "us") respects your privacy and is committed to protecting your personal data in accordance with the Nigeria Data Protection Act, 2023 ("NDPA"), applicable regulations, and international best practices [1]. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you access our website, engage with our subsidiaries, or interact with our services [1].

2

Information We Collect

Categories of Personal Data

We may collect the following categories of personal data [1]:

Personal Identification Information

Full name
Residential or business address
Email address
Telephone number
Date of birth

Business Information

Company name
Position or designation
Corporate contact information

Technical Information

IP address
Browser type
Device information
Website usage data
Location information

Communications Information

Enquiries submitted through our website
Feedback and correspondence

3

Purpose of Processing

How We Use Your Data

We process personal data for the following purposes [1]:

Responding to enquiries and requests

Providing information about our services and subsidiaries

Managing business relationships

Complying with legal and regulatory obligations

Website administration and security

Fraud prevention and risk management

Improving user experience

Legal Basis for Processing

Lawful Grounds

We process personal data based on the following legal grounds [1]:

Consent

Contractual necessity

Legal obligation

Legitimate business interests

Protection of vital interests

5

Data Sharing

Third-Party Disclosure

We may share personal data with the following parties [1]:

Subsidiaries

Affiliated companies within our group

Professional Advisers

Legal and financial consultants

Auditors

External audit firms and consultants

Government Authorities

Regulators and official bodies

Data Security

Protection Measures

We implement appropriate technical and organizational safeguards to protect personal data against unauthorized access, loss, misuse, alteration, and disclosure [1].

7

Data Retention

Storage Period

Personal data shall be retained only for as long as necessary to fulfil the purpose for which it was collected or as required by law [1].

Your Rights

Data Subject Rights

Subject to applicable law, you have the right to [1]:

Access your personal data

Request correction of inaccurate information

Request deletion of personal data

Withdraw consent

Restrict processing

Object to processing

Request portability of personal data

Lodge a complaint with the Nigeria Data Protection Commission (NDPC)

9

International Transfers

Cross-Border Data Protection

Where personal data is transferred outside Nigeria, we shall ensure adequate safeguards are implemented in accordance with the NDPA [1].

Contact Data Protection Officer

Privacy-Related Enquiries

Data Protection Officer

Barr Deborah Eroh

Organization

COOL HOLDINGS LIMITED

legal@coolgroup.com.ng

Email Support

[Use the glo number]

Phone Support

11

Changes to This Policy

Policy Updates

We reserve the right to amend this Privacy Policy from time to time [1].