eFashon Privacy Policy

Effective Date: 31 August 2026

1. Introduction

eFashon Limited ("eFashon", "we", "our", or "us") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you access or use the eFashon website, mobile applications, and related services (collectively, the "Platform").

This Privacy Policy is intended to comply with the Nigeria Data Protection Act 2023 ("NDPA"), applicable regulations issued by the Nigeria Data Protection Commission ("NDPC"), and other applicable privacy laws.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

The data controller responsible for your personal information is:

eFashon Limited

Email: info@efashon.com Website: efashon.com

Where required by law, eFashon may appoint a Data Protection Officer or engage a licensed Data Protection Compliance Organisation (DPCO).

3. Information We Collect

We may collect the following categories of personal data.

3.1 Information You Provide

When you create an account, submit a listing, make a payment, contact us, or otherwise interact with the Platform, we may collect:

• Full name
• Email address
• Phone number
• WhatsApp number
• Username
• Password (encrypted)
• Business name
• Business address
• Social media handles
• Profile photograph
• Portfolio photographs
• Product photographs
• Communications sent to us

3.2 Payment Information

Payments are processed by independent payment providers such as Paystack.

eFashon does not store complete debit card or payment card details.

However, we may receive:

• Payment confirmation
• Transaction reference numbers
• Subscription status
• Billing records

3.3 Technical Information

When you access the Platform, we may automatically collect:

• IP address
• Device information
• Browser type
• Operating system
• Usage data
• Referral source
• Session activity
• Log files

3.4 Cookies and Similar Technologies

We may use cookies, pixels, analytics tools, and similar technologies to:

• Improve functionality
• Remember preferences
• Measure performance
• Understand user behaviour
• Prevent fraud

Users may control cookie preferences through browser settings and our Cookie Policy.

4. How We Use Your Information

We use personal information for the following purposes:

Account Management

• Creating accounts
• Authenticating users
• Managing subscriptions
• Providing customer support

Platform Operations

• Displaying member listings
• Operating e-showrooms
• Facilitating user interactions
• Maintaining platform functionality

Payments

• Processing subscriptions
• Verifying payments
• Preventing fraud

Communications

• Sending notices
• Service updates
• Account notifications
• Security alerts

Marketing

Where permitted by law, we may send:

• Newsletters
• Promotions
• Product updates
• Marketing communications

Users may opt out at any time.

Security and Compliance

• Fraud prevention
• Security monitoring
• Legal compliance
• Enforcement of platform policies

5. Lawful Basis for Processing

Under the NDPA, we process personal data on one or more of the following lawful bases:

Contract Performance

Processing necessary to:

• Create accounts
• Provide platform services
• Manage subscriptions

Consent

Processing based on user consent, including:

• Marketing communications
• Optional platform features
• Cookies where required

Legal Obligations

Processing necessary to:

• Comply with laws
• Respond to regulators
• Prevent unlawful activity

Legitimate Interests

Processing necessary for:

• Fraud prevention
• Platform security
• Business operations
• Service improvement

6. AI and Automated Processing

eFashon may use automated systems, artificial intelligence, machine learning, recommendation engines, ranking systems, matching systems, and analytics tools.

These systems may:

• Recommend designers
• Recommend fabrics
• Suggest styles
• Improve search results
• Personalize user experiences

Automated outputs are intended to assist users and should not be relied upon as professional advice.

Users may contact us regarding concerns about automated processing.

7. Sharing of Personal Information

We do not sell personal information.

We may share information with:

Payment Providers

Including:

• Paystack
• Flutterwave
• Banks
• Payment processors

Technology Providers

Including:

• Cloud hosting providers
• Analytics providers
• Communication providers

Professional Advisers

Including:

• Lawyers
• Accountants
• Auditors

Government Authorities

Where required by law, court order, regulatory directive, or lawful investigation.

8. Cross-Border Data Transfers

Some service providers may process personal data outside Nigeria.

Where cross-border transfers occur, eFashon shall implement appropriate safeguards as required by applicable law, including contractual protections and other lawful transfer mechanisms.

By using the Platform, you acknowledge that your personal information may be transferred and processed in countries outside Nigeria.

9. Data Retention

We retain personal data only for as long as reasonably necessary to:

• Provide services
• Maintain accounts
• Comply with legal obligations
• Resolve disputes
• Enforce agreements

When data is no longer required, it will be securely deleted, anonymized, or archived in accordance with applicable law.

10. Security Measures

We implement reasonable technical, organizational, and administrative safeguards designed to protect personal information against:

• Unauthorized access
• Disclosure
• Loss
• Destruction
• Misuse
• Alteration

However, no internet transmission or storage system can be guaranteed to be completely secure.

11. Your Rights Under the NDPA

Subject to applicable law, you may have the right to:

• Be informed about processing
• Access your personal data
• Correct inaccurate information
• Request deletion of data
• Restrict processing
• Object to processing
• Withdraw consent
• Request data portability
• Challenge certain automated processing decisions
• Lodge complaints with the NDPC

Withdrawal of consent shall not affect processing already lawfully carried out before withdrawal.

12. Marketing Communications

Where permitted by law, we may send promotional communications.

You may unsubscribe at any time by:

• Clicking the unsubscribe link
• Updating account preferences
• Contacting us directly

13. Children's Privacy

The Platform is not intended for persons under eighteen (18) years of age.

We do not knowingly collect personal data from children.

If we become aware that a child has provided personal information, we may remove such information.

14. Third-Party Links and Services

The Platform may contain links to third-party websites, social media platforms, WhatsApp, payment providers, and other services.

eFashon is not responsible for the privacy practices of third parties.

Users should review the privacy policies of third-party services independently.

15. Data Breach Notification

Where required by applicable law, eFashon shall notify affected individuals and relevant authorities of eligible personal data breaches in accordance with legal requirements.

16. Complaints

If you believe your privacy rights have been violated, please contact us first.

Email: privacy@efashon.com

You also have the right to lodge a complaint with the Nigeria Data Protection Commission.

17. Changes to this Privacy Policy

We may update this Privacy Policy periodically.

Updated versions will be posted on the Platform with a revised Effective Date.

Continued use of the Platform after publication constitutes acceptance of the updated Privacy Policy.

18. Contact Us

eFashon Limited

Email: info@efashon.com