CTSNG Limited ("SAMU", “we”, “us”, “our”) provides a platform for its users to request and purchase items from service providers and have it delivered to their doorstep (“Services”). At SAMU, one of our core values is transparency and we owe you ('User') a duty to tell you how we collect, use and share your personal information. Personal information means information that identifies you and includes information such as your name, email address, telephone number as well as any other personal data collected. We recommend that you read this Privacy Policy ("Policy") carefully to understand your rights and our duties towards managing your personal data in addition to our Terms of Use. If you have any questions about either of these documents, please send us an email at admin@samuapp.com.
1. Notification of Changes to Privacy Policy
We are continually improving our methods of communication and adding new functionalities and features to our website and existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data protection practices will change from time to time. If and when our data protection practices change, we will update this Policy to describe our new practices and publish them on our website and applications.
2. Collecting your personal information
We are committed to informing and limiting the collection of essential personal information.
We can get your personal information when you:
2.1. Buy a product or service from us.
2.2. Register for a specific product or service (such as registering your name, phone number, email address and physical address details for any of our services).
2.3. Subscribe to newsletters or other services from us.
2.4. Ask us for more information about a product or service or contact us with a question or complaint.
2.5. Take part in a promo or survey.
2.6. Use our website and other services.
2.7. Visit or browse our website or other platforms.
2.8. With your permission or consent and/or as permitted by law, we may also collect information about you from other organizations or third parties if this is appropriate and allowed by law. These include fraud-prevention agencies, business directories, and credit reference agencies.
3. Understanding what you want (the use of cookies)
We might use cookies (small text files in your browser) and other techniques such as web beacons (small, clear picture files that follow your movements on our website). These collect information that makes the website remember you and tells us how you use our website, web-related products and services.
This, in turn, helps us make our website relevant to your interests and needs. They also help us find information once you have logged in or help us link your browsing information to you and your personal information, for example, when you choose to register for a service. We may use a persistent cookie (that stays linked to your browser) to record your details so we can recognise you if you visit our website again.
Cookies by themselves cannot be used to discover your identity. Cookies do not damage your computer. You can set your browser to notify you when you receive cookies. This enables you to decide if you want to accept it or not. If you choose not to accept cookies from our website, this may limit its functionalities or performance.
4. Use and analysis of your personal information
We may use and analyse your information to:
4.1. Provide delivery Services and facilitate the listing of service providers around you;
4.2. Keep you informed generally about new products and services (unless you choose not to receive our marketing messages);
4.3. Understand how you use our network, products and services. That way, we can develop more interesting and relevant products and services and personalise the products and services we offer you.
4.4. Comply with all applicable laws and regulations;
4.5. Develop, improve, enhance, modify, add to and further develop our services;
4.6. Authenticate users, verify identity, and ensure that the data provided is credible;
4.7. Prevent and detect fraud and illegal activities;
4.8. Provide customer support services, including responding to your enquiries or complaints;
4.9. Conduct customer surveys and research & development activities;
4.10. Fulfil our obligations or claim our rights in legal proceedings;
4.11. Process and facilitate payment for services provided on our platform;
4.12. Respond to any questions or concerns you may have about using our products and services;
4.13. Let you know about other companies' products and services we think may interest you (including offers and discounts we’ve specially negotiated for our customers)
4.14. Use or disclose it as otherwise authorised or permitted by law
4.15. Contact you at any time through your provided telephone number, email address or other contact.
4.16. Provide aggregated reports to our vendors to enable them to serve you better.
4.17. For any other purpose with your consent.
5. Consent
You accept this Notice when you sign our Consent Form here or click on the “accept” button to opt-in and use any of our Platforms and Services or visit any of our offices for official or non-official purposes. You also consent to the collection and processing of your personal information (which includes but is not limited to your name, date of birth, email address, address, telephone number, etc), your order details, order history and any other information for the purpose of providing the SAMU Services. If you decide to opt out of any of the SAMU Services or withdraw consent for the processing of your personal information, you can do so by reaching out to us at admin@samuapp.com or filling out our Data Subject Request Form. This Notice governs the use of the SAMU Services and if you are not comfortable with us processing your data, you may not use our Services.
6. Lawful Basis for Processing Data
The lawful basis for processing your data is the performance of our contractual obligations to you. The personal data we collect and process in order to fulfil our contractual obligations to you include but are not limited to your name, address, and phone numbers for the fulfilment of your orders and completion of your deliveries.
7. How we collect your personal information
We collect information directly from you as well as automatically through your use of our Services, and in some cases, from third parties subject to your authorisation.
When you fill out a form, participate in a contest or promotion, request customer service, or otherwise communicate with us we need your information to understand your needs and to provide relevant services to you.
We may also receive information about you from other sources and combine that information with the information we collect directly. Examples of information we may receive from other sources include updated delivery or payment information used to correct our records, purchase or redemption information, as well as customer support and enrollment information.
8. The Personal Information we collect
The information we collect about you depends on the services you use and subscribe to. We collect only the information essential for you to create an account with SAMU and use our Services. The information we collect includes:
8.1. your personal information in relation to your account such as your name, age, date of birth, gender, physical address, account information, email address and phone number. We may also collect the name, physical address, phone number, email address and other information about third parties related to you or their use of our services if you provide that information to us. We shall process this information on the assumption that you have obtained the prior consent of the third parties and we shall not be liable for any breach of data information in this regard;
8.2. details relating to when and where you request our Services and the details of any orders made or received by you in relation to our Services, including your geographical location (which may be calculated from information collected in section 10 below);
8.3. details of the device on which any of our Platforms or applications have been installed or accessed, which may include your operating system and versions, unique device identifiers, serial numbers, mobile network and Wi-Fi information;
8.4. personal information collected and held via financial or third-party payment systems about the payment mechanism or method that you might use (including credit card details) and the payments you may make for our Services or other goods or services you request or receive that are related to the Services we provide;
8.5. our connection to other individuals whose personal information we may collect or hold, for example, family members, friends, or referrals;
8.6. details about your participation in any loyalty programs linked or available through us or any of our business partners or affiliates;
8.7. If you use social media platforms to interact with us or other services provided by third parties through SAMU, any information that you allow the social media platform and/or the other third-party site to share with us;
8.8. any address that you may use, for delivery services;
8.9. if you respond to optional survey requests, demographic information including age, marriage status, ethnicity, profession and income.
9. Third party technologies
Occasionally, at our discretion, we may include or offer third-party products or services on our Platform. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Platform and welcome any feedback about these sites.
We may also use third-party websites such as Facebook and Twitter for interactive information sharing and to connect with Users. We recommend that you read any terms and conditions (including any privacy statements or policies) that apply to any third-party web service relating to the handling and management of your personal information as they may use your personal information in ways and for purposes that are different from the way SAMU uses and processes your personal information.
We encourage you to keep your personal information confidential by contacting them through direct or private messages, email or the customer service hotline.
10. Location Services
Before you can use our Platform for the first time, we will ask you to choose whether to allow SAMU access to your location and in what circumstances. Location services must be enabled for us to provide our Services to you. You may change these settings at any time on your device. Once you allow us access your location, we will obtain your location through IP address, GPS, and other sensors that provide necessary information for the provision of our Services.
We may collect Wi-Fi metadata from your device including whether your device is Wi-Fi and GPS enabled and connected to Wi-Fi, the Media Access Control (MAC) address of your device, the Set Service Identifier (SSID) and signal level of Wi-Fi networks within the range of your device, the GPS location of your device in relation to Wi-Fi networks in the range of your device, and the time the metadata was collected. We use the information primarily so that we can recommend service providers closest to you.
11. Communication
The SAMU Platform allows you to contact us via call or message anonymously once the product has been purchased from the chosen service provider to facilitate the provision of delivery services. If you use this functionality, SAMU will record all communications (voice and text) made and received through the SAMU Platform for safety, monitoring and quality assurance purposes, fraud prevention, and analytical purposes to improve our services, including our customer service, policies and procedures and/or to investigate and deal with disputes and complaints. By using this functionality, you consent to SAMU recording and using these communications as stated in this Notice.
12. Surveys
We may request that you complete a survey to allow us to have a better understanding of our Services and to improve them. If you choose to participate in any optional survey, we may collect demographic information about you, including age, marriage status, ethnicity, profession and income, which could include your sensitive information. We may also collect information about the way you use our Services, and your experiences with it. By participating in any survey, you consent to our collection and use of the information you provide in accordance with this privacy notice.
13. Disclosures of your personal information
13.1. SAMU will not sell or rent your information to third parties. However, we may disclose your information to:
13.2. SAMU will comply with its obligations under the relevant data protection law in relation to any such disclosures, including using reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with the privacy legislation. For example, (where commercially practicable) by including suitable privacy and confidentiality clauses in our agreement with those third parties.
13.3. Your privacy and information permissions and settings can be updated at any time on the SAMU mobile application when you are logged into your account.
14. Disclaimer
SAMU has no prior relationship or representation with the service providers whose services are listed on SAMU’s Platform. SAMU is solely responsible for the purchase of the customer’s order and the delivery of the order to the customer’s provided address upon confirmation of payment.
SAMU will not be responsible for any breach in the representations made by the service provider concerning any order made by you and does not guarantee that the representations will be fit for purpose, true and accurate.
15. Storage and Security
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, and unauthorised access.
Personal information is collected on servers in electronic databases which are located in Ireland and managed by our related entities and/or service providers. We will ensure that your information is protected and that they only process your information in the way we have authorised them to. These organisations will not be entitled to use your personal information for their own purposes.
We have put in place suitable physical, and electronic administrative procedures and measures to safeguard and protect the information about you that we collect, and to reduce the risks of loss, misuse, disclosure, alteration and unauthorised access to your personal information within our custody. Personal information and associated data stored on servers are encrypted and stored through data isolation technology.
We limit access to personal information to individuals within our employ or that of our related entities or contracted service providers who we believe reasonably need access to such information to provide products or services to you, or to us, or to perform their duties. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. To prevent unauthorised access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. Our website uses a Secure Sockets Layer (SSL) to ensure secure transmission of your Personal Data. You should see the padlock symbol in your URL address bar when browsing through our website. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.
We will never ask for your secure personal or account information by unsolicited means of communication. You are responsible for keeping your personal and account information secure and not sharing it with others. We shall not be liable for any unauthorised access or loss or personal information beyond our control.
16. Retention period
Subject to the provisions of the NDPR 2019, the retention period for the personal information of users of SAMU shall be as follows:
16.1. seven (7) years after the last active use of our digital platform;
16.2. upon presentation of evidence of death by a deceased’s relative, personal information of such User would be discarded;
16.3. immediately upon request by the User of SAMU or his/her legal guardian where:
17. Direct marketing
We may occasionally contact you directly with related point-to-point restaurants, information, and special offers from us and other service providers. You consent to us sending you such information including by means of telemarketing, email, SMS and other digital channels when you "Subscribe" to receive marketing communications from SAMU.
If at any time you decide you do not wish to receive marketing communications from us, you may click the “Unsubscribe” button in the marketing emails and messages or by emailing us. If you opt out of receiving marketing communications from us, we may still contact you or send you messages that are not of promotional nature, such as receipts for service provider's directory and delivery services booked through SAMU.
18. Links to other websites
Our website may contain hyperlinks to websites or web addresses of third parties and third-party services that we do not operate. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. While we take appropriate care when publishing links to any third-party services, you shall, at your own discretion, decide whether to access such links or accept such services. SAMU gives no undertakings or warranties with respect to the accuracy, completeness, adequacy and reliability of any information, data, opinions, pictures, statements or suggestions provided by such links. SAMU does not have control over or assume any liability for third-party websites, their content or their data use and retention policies or practices. We urge you to review any privacy statement posted on any site you visit before using the site or providing any personal information about yourself and others.
19. Access and corrections to personal information
19.1. Under the law, you have the right to access, correct, amend, and delete your personal information or object to processing your personal information.
19.2. You may make any of the following requests in respect of your personal information within our custody:
19.3. You can make any of the above requests by contacting us via email or filling out our Data Subject Request Form. We may ask you to provide suitable identification when you seek to make any of these requests, to verify your identity.
19.4. We will provide you with a response as soon as possible. If we are unable to comply with your request for any reason (such as, not being permitted or required to do such an act under the privacy legislation in force) we will inform you of this.
19.5. If the personal information we provide in response to your request includes information that is the personal information of a third party, or that is confidential, or in which we own the copyright (such as transcripts or recordings of customer service call records), we may redact such information where reasonably necessary, and you must keep such information confidential and not make the information public, including by sharing the information on social media, without our written consent sought and obtained.
19.6. Users can also delete their accounts from the SAMU application. If you delete your account, we will retain your personal information in accordance with our Retention Policy.
19.7. SAMU may retain your personal information after you have requested us to delete or de-identify your information if:
19.8. When personal information is no longer required, we will take reasonable steps to delete the personal information from our systems or de-identify the personal information.
20. Governing law
This Notice is made pursuant to the NDPR 2019, NDPA 2023 and all applicable data protection laws and regulations, in Nigeria. Where any provision of this Notice is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.
This Notice shall be governed by the laws of the Federal Republic of Nigeria.
This Notice applies to all Users of the Services provided by SAMU, and to anyone else who contacts SAMU or otherwise submits information to SAMU.
Last reviewed in December 2024
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