CofluenXa
Your Data, Our Responsibility Brands
We implement robust security measures to safeguard your personal data at every touchpoint.
Privacy Policy
Last Updated: July 15, 2025
Introduction
This Privacy Policy (“Policy”) outlines how Cofluenxa in Nigeria (“Company,” “we,” and “our”) collects, processes, uses, and shares personal data when you use our website https://cofluenxa.com (the “Website”). This Policy complies with the Nigeria Data Protection Act, 2023 (NDPA) and other applicable Nigerian laws. Please read this Policy carefully to understand our practices regarding your personal data.
Purposes of Processing
What is Personal Data?
Under the NDPA, “personal data” refers to any information relating to an identified or identifiable individual, including, but not limited to, your name, postal address, email address, telephone number, or any other information that can be used to identify you, either alone or in combination with other data we process about you.
Why Do We Need Your Personal Data?
We process your personal data in compliance with the NDPA and other applicable Nigerian laws. We require certain personal data to provide you with access to the Website, its services, products, or content. When you register with us, you will be asked to provide explicit consent, as required under Section 26 of the NDPA, to process this information. This consent serves as the legal basis for processing your personal data. You have the right to withdraw your consent at any time by contacting us. If you do not consent to our use of your personal data in accordance with this Policy, please do not use our Website.
Collecting Your Personal Data
We collect your personal data in the following ways:
Information You Provide
This includes:
- Personal data provided during registration, such as your name, postal address, email address, telephone number, username, password, and demographic information (e.g., gender).
- Personal data in videos, comments, or other submissions you upload or post to the Website.
- Personal data provided in connection with our rewards program or other promotions.
- Personal data provided when reporting issues with the Website or seeking customer support.
- Personal data provided during purchases made through the Website.
- Personal data provided when you correspond with us via phone, email, or other means.
Information from Social Networking Sites
Our Website may allow you to connect with social networking sites (“SNS”). By connecting to an SNS through our Website, you authorize us to access, use, and store information provided by the SNS based on your settings on that platform, in accordance with this Policy and Section 30 of the NDPA. You may revoke our access to this information at any time by adjusting the relevant settings in your SNS account.
Information Automatically Collected
We automatically collect information about you and your device when you access our Website. This includes your device’s operating system name and version, manufacturer, model, browser type, language, screen resolution, the website visited before ours, pages viewed, time spent on pages, access times, and details of your interactions with the Website. We use cookies to collect this information, as permitted under the NDPA.
Automated Decision Making and Profiling
We do not engage in automated decision-making or profiling using your personal data, except where required to fulfill legal obligations. If such processing is necessary, we will notify you and provide an opportunity to object, in line with Section 28 of the NDPA.
User Profiles and Submissions
Certain user profile information, such as your name, location, and uploaded content (e.g., videos or images), may be visible to other users to facilitate interaction or address service requests. You can control the visibility of your profile information through your account privacy settings. Any content you voluntarily post publicly (e.g., on discussion boards or chat areas) becomes publicly available and may be collected or used by others. If you sign in via a third-party SNS, your “friends” list from that platform may be imported, and registered users may access certain non-public information in your profile, subject to SNS privacy policies.
Cookies
What Are Cookies?
Cookies are small data files stored on your device by a website. We use session cookies (which expire when you close your browser) and persistent cookies (which remain until deleted) to enhance your experience on our Website, as permitted under the NDPA.
Cookies We Use
We use the following cookies:
- Essential Cookies: Necessary to provide Website services, such as logging into secure areas and ensuring fast page loading. These are critical for Website functionality.
- Functionality Cookies: Enable the Website to remember your preferences, such as language settings or login details, to provide a personalized experience.
- Analytics and Performance Cookies: Collect anonymized data on Website traffic and usage to improve functionality, using tools like Google Analytics. Learn more about Google Analytics cookies at:https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and Google’s privacy practices at:https://policies.google.com/privacy. You can opt out of Google Analytics via:http://tools.google.com/dlpage/gaoptout?hl=en-GB.
- Targeted and Advertising Cookies: Track browsing habits to deliver relevant ads. You can disable these cookies at:http://www.youronlinechoices.com/uk/your-ad-choices. Note that disabling these may not eliminate all tailored ads, as not all advertising companies are covered by this opt-out.
- Social Media Cookies: Enable sharing or liking content via social media platforms (e.g., Facebook, Twitter). These platforms may record your interactions.
Disabling Cookies
You can disable cookies through your browser settings (found in “settings,” “help,” or “tools”). However, disabling cookies may limit Website functionality, such as requiring repeated logins. We will seek your consent for non-essential cookies in compliance with the NDPA.
Advertising
We may use third-party companies to serve advertisements on our Website. These companies may collect information such as clickstream data, browser type, and timestamps to provide relevant ads, using tracking technologies subject to their own privacy policies and the NDPA.
Using Your Personal Data
We may use your personal data to:
- Operate, maintain, and improve our Website, products, and services.
- Manage your account and communicate regarding your account.
- Administer rewards programs and promotions.
- Respond to comments, questions, and provide customer support.
- Send technical notices, updates, security alerts, and administrative messages.
- With your consent, send marketing emails about promotions and products. You may opt out of marketing emails at any time, but non-marketing emails (e.g., account-related) will continue.
- Process payments made via the Website.
- Comply with applicable laws, lawful requests, or legal processes, enforce this Policy, and protect our or your rights, privacy, safety, or property, as permitted under Sections 24 and 25 of the NDPA.
- Conduct analysis and studies.
Sharing Your Personal Data
We may share your personal data as follows:
- With Your Consent: To third parties you designate.
- Third-Party Service Providers: For services like data analysis, payment processing, IT infrastructure, customer service, email delivery, and auditing, under strict data processing agreements compliant with Section 29 of the NDPA.
- Legal Obligations: To comply with Nigerian laws, court orders, or government requests.
Third-Party Sites
Our Website may link to third-party websites or features. This Policy does not cover their privacy practices, and we are not responsible for their policies. Please review their privacy policies before submitting data.
User-Generated Content
Content you submit, such as via rewards programs, forums, or blogs, may become public and accessible to other users or the general public. Be cautious when sharing personal data, as it will not remain private once published. Feedback you provide may be used on our Website without associating it with your personal data, unless you consent to including your name.
International Data Transfer
Your personal data may be transferred to and processed in countries outside Nigeria, where data protection laws may differ. By accepting this Policy, you consent to such transfers, as permitted under Section 43 of the NDPA. We will implement adequate safeguards to ensure your data is protected in accordance with this Policy.
Security
We implement reasonable organizational, technical, and administrative measures to protect your personal data, in line with Section 24 of the NDPA. However, no system is completely secure. If you suspect a security breach, please notify us immediately.
Retention
We retain your personal data only as long as necessary for you to use the Website or until you close your account, unless a longer retention period is required or permitted by law (e.g., for regulatory purposes), as stipulated in Section 27 of the NDPA.
Our Policy on Children
Our Website is not directed to children under 16. If a parent or guardian discovers their child has provided information without consent, they should contact us, and we will delete such data promptly, in compliance with Section 31 of the NDPA.
Your Rights
Under the NDPA, you have the following rights:
- Opt-Out: Opt out of direct marketing, automated decision-making, profiling, sensitive data collection, new processing purposes, or international data transfers.
- Access: Access the personal data we hold about you via your account or by contacting us.
- Amend: Update or correct inaccuracies in your personal data.
- Portability: Request your personal data be transferred to another service provider.
- Erasure: Request deletion of your personal data when it is no longer relevant or is incorrect.
To exercise these rights, contact us, specifying the personal data and the right you wish to enforce. We may verify your identity and will respond within 30 days, as required by Section 33 of the NDPA. We may retain certain data for legal or recordkeeping purposes.
Complaints
If you have concerns about our data practices, please contact us. We will respond within 30 days. If unsatisfied, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC), as provided under Section 40 of the NDPA.
Contact Information
For questions or comments about this Policy, contact us via our Website or in writing at our registered address.