ClemGTech — Privacy Policy Effective Date: June 2025 | Version 1.0 Applies to: clemgtech.com.ng and all orders/interactions via WhatsApp, phone, email, or in-store. Governing framework: Nigeria Data Protection Act, 2023 (NDPA) and Nigeria Data Protection Regulation (NDPR).
1. Introduction
ClemGTech (“ClemGTech”, “we”, “us”, “our”) respects your privacy and is committed to protecting the personal data of everyone who visits our website, places an order, contacts us via WhatsApp/phone/email, or visits our store. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, who we share it with, and your rights.
By using clemgtech.com.ng or placing an order, you acknowledge that you have read and understood this policy. If you do not agree, please do not use our website or services.
2. Who We Are (Data Controller)
ClemGTech is the data controller. Address: No. 1 Obakran Babatola Close, Westmildland University, Computer Village, Ikeja, Lagos, Nigeria. Contact: 07075062698 / 08101170878 / 08088569689 | clemgtechtechnology@gmail.com
3. What Personal Data We Collect
| Category | Examples | When Collected |
|---|---|---|
| Identity data | Full name, title | Checkout, account creation, WhatsApp/in-store order |
| Contact data | Phone number, delivery address, email | Checkout, orders, support |
| Order data | Products purchased, order value, history, preferences | Every purchase |
| Payment data | Transaction reference, confirmation (card/bank details processed by third-party processors; we do not store full card details) | At checkout or COD deposit |
| Delivery data | Address, recipient name, instructions, status | Checkout and fulfillment |
| Communication data | WhatsApp messages, call logs, emails | When you contact us |
| Technical data | IP address, browser/device type, pages visited (via cookies/analytics) | Automatically when browsing |
| Marketing preferences | Opt-in/out of promotional messages | When you subscribe or unsubscribe |
We do not intentionally collect sensitive personal data (health, religion, biometrics, etc.) and ask that you do not share such information unless necessary for support.
4. How and Why We Use Your Data (Purpose & Legal Basis)
| Purpose | What We Use It For | Legal Basis |
|---|---|---|
| Processing & fulfilling orders | Confirming payment, packaging, dispatch, delivery | Performance of a contract |
| Delivery & logistics | Sharing name, phone, address with logistics partners | Performance of a contract |
| Customer support | Inquiries, returns, refunds, warranty claims | Performance of a contract / legitimate interest |
| Payment processing | Passing details to payment processors | Performance of a contract |
| Order & financial records | Accounting and tax compliance | Legal obligation |
| Fraud prevention | Verifying orders, reducing failed COD deliveries | Legitimate interest |
| Marketing | Promotional offers via WhatsApp/SMS/email | Consent (opt-in; withdraw anytime) |
| Improving website/services | Analytics | Legitimate interest / consent (cookies) |
| Legal compliance | Responding to lawful requests | Legal obligation |
5. Payment Data
We do not store full card numbers, CVV, or bank login details. Payments are processed by licensed third-party providers. For COD, we retain only the confirmation deposit reference and record of balance collected.
6. Sharing Your Data
We share data only as necessary:
| Recipient | What’s Shared | Why |
|---|---|---|
| Logistics partners | Name, phone, address | To deliver orders / handle pickups, returns, replacements |
| Payment processors | Order amount, reference | To process payments |
| Analytics tools | Browsing/technical data | Website improvement & advertising |
| Regulators / law enforcement | As legally required | Compliance |
| Professional advisors | Financial records | Accounting/tax |
We do not sell, rent, or trade your personal data for third-party marketing.
7. Cookies & Tracking
We use essential cookies (cart/session) and analytics tools. You can control cookies via browser settings. Disabling them may affect site functionality.
8. Data Retention
- Order/transaction records: 6 years (tax/accounting).
- Support/complaint records: 12 months from resolution.
- Marketing consent: Until withdrawn + reasonable period. Data is securely deleted or anonymized thereafter unless longer retention is legally required.
9. Data Security
We apply reasonable technical and organizational measures (restricted access, secure processors, partner instructions). No system is 100% secure. In case of a breach likely to risk your rights, we will notify the Nigeria Data Protection Commission (NDPC) and affected customers as required.
10. Your Rights Under the NDPA
You have the right to: access, rectification, erasure (subject to legal retention), restriction, object (including to marketing), withdraw consent, data portability, and lodge a complaint with the NDPC.
Contact us to exercise these rights. We will respond within NDPA timeframes after identity verification.
11. Marketing Communications
Promotional messages only with opt-in. Opt out anytime by replying “STOP”, unsubscribing, or contacting us. Transactional messages (order updates, delivery) continue.
12. Children’s Privacy
Our services are not directed at children under 18. We do not knowingly collect their data. Contact us to delete any such data.
13. International Data Transfers
Website and service providers may process data outside Nigeria (e.g., hosting/analytics servers). Transfers occur with appropriate safeguards under the NDPA.
14. Contact for Privacy Enquiries
WhatsApp/Call: 07075062698 | 08101170878 | 08088569689 Email: clemgtechtechnology@gmail.com Address: No. 1 Obakran Babatola Close, Westmildland University, Computer Village, Ikeja, Lagos.
15. Changes to This Policy
We may update this policy. The Effective Date will change. Material changes will be communicated as required. Continued use constitutes acceptance.
