Privacy Policy

Trace by NurseryCorp. · NurseryCo R&P Limited

This Privacy Policy (the “Policy”) sets out the basis on which NurseryCo R&P Limited (“NurseryCorp.”, “We”, “Our”, or “Us”) will process personal data we collect from you when you register with, and use Trace (“Trace” or the “Platform”).

The Platform is a digital infrastructure operated by NurseryCo R&P Limited (NurseryCorp.), and provides independent sellers (“Vendors”) with the tools and service to update their customers (“Users”/“Customers”) on the status of their orders in real-time. Trace is not responsible for order fulfilment. Vendors, not Trace, are solely responsible for order fulfilment.

By continuing to use the Platform, you acknowledge that you have read, understood and accepted the terms of this Policy.

We will process your personal data only if you give your consent willingly or in accordance with the law.

By using the Platform, you consent to the terms of this Privacy Policy. Vendors can withdraw their consent at any time but we may not be able to provide you with our services as your account will be disabled. Other users (Customers) that may not require an account to use Trace can stop using Trace if they do not consent to this Policy.

Where you provide us with third-party information, we assume that you have obtained the required consent from the relevant party to share his/her personal information with us.

The Platform is intended for individuals who are of 18 years of age and above. By using the Platform, you represent that you are at least 18 years old. We do not knowingly collect, process or store personal data relating to individuals under the age of 18 years.

Depending on the way you use Trace, We process most or all of the following personal data when you use the Platform:

• Personal Identification Data: includes full name, residential/telephone address, phone number, email address.
• Platform Usage Data: includes data about your usage of our Platform, products and services.
• Device/Technical Data: includes login information, password, username, device operating system, device type, IP address, and browser information.
• Marketing and Communication Data: we may collect Personal Data you provide to us for the purpose of marketing and communicating with you or other users.
• Geographical Data: location and jurisdiction.

With your consent further to this Policy, we process your personal data for the following purposes:

• in performance of our contract with you;
• to provide customer support and dispute resolution;
• to comply with applicable laws and regulations;
• to deal with enquiries and complaints relating to the Platform;
• to identify, investigate and prevent illegal activity;
• for security and maintenance of the Platform;
• to send marketing and promotional information;
• to carry out statistical and other analyses to identify potential markets and trends, evaluate and improve our business (this includes improving existing and developing new products and services); and
• to comply with legal obligations.

We may disclose your information:

• to our employees, agents, contractors or other authorized personnel in performance of our contract with you;
• equipment/facility vendors registered on the Platform;
• third parties that assist us in delivering the services;
• in compliance with a court order request by law enforcement agencies, regulatory or governmental bodies, or in compliance with regulatory obligations;
• where we have a public duty to disclose the data; or
• where you consent that we can disclose your data.

We will not disclose your personal data to external organizations that are not our service providers, unless you gave us your consent, or unless we may do so by law, or if it is necessary for the conclusion or performance of our agreement with you.

Where there is a need to transfer your Personal Data to another country, we will ensure that the country to which the data is being transferred or the foreign institution receiving said Personal Data, shall have adequate and sufficient data protection laws, in accordance with the General Data Protection Regulation and the Nigeria Data Protection Act 2023.

We have implemented physical, electronic and procedural measures to protect your information from unauthorized or unlawful access and use. This includes the use of firewalls, secure audit logging, access controls, and other forms of security to ensure your data is protected.

We train and require our staff and third parties processing data on our behalf, to comply with relevant data policies and guidelines. Our security systems, which are regularly updated, are designed to prevent loss, unauthorized destruction, damage and/or access to your personal data from unauthorized third parties.

While we take reasonable measures to protect your personal information, you are ultimately responsible for maintaining the confidentiality of your account. We recommend you:

• use strong and unique passwords for your account, and change them regularly;
• not share your login details with anyone;
• monitor your account activity for any unauthorized activities; and
• avoid accessing your account when using shared or public devices.

Additionally, exercise due diligence when clicking on links purportedly sent by Trace to track your order. Do not click on tracking links from unknown vendors and/or if you are not expecting a tracking link for an item you ordered.

You grant us the right to commercially exploit data generated through your interaction with the Platform. This right includes the right to:

• develop artificial intelligence, analytics, and predictive tools;
• share insights of datasets with commercial partners; and
• license or sell datasets derived from Platform usage.

This right does not apply to your personal identification data, as an individual. Where it is reasonably possible, we may also generate and commercialize aggregated or anonymized datasets derived from user activity and lease transactions.

You can exercise your right to object to commercialization of your personal data by submitting a request to hello@nurserycorp.com, using the subject “Personal Data Commercialization Opt-Out”.

We use cookie technology on our Platform to improve your user experience and analyze Platform performance. The cookies can be disabled if you wish by clicking on the appropriate prompt; however, some areas of the Platform may not be accessible when you disable cookies.

We retain your data for as long as necessary for the purpose for which it was collected. We keep your data as long as you maintain an account on the Platform. We shall take steps to destroy your information with us in the event of the termination between us and you, subject to certain laws and regulations that require that we retain certain information for specified periods of time.

Specifically, we will retain your personal data including location, device and usage for a minimum of 5 years after deletion of your account on the Platform, where applicable.

As a user of our platform, you have the following rights as provided under the Nigeria Data Protection Act, 2023:

• right to request for and access your personal information held by us;
• right to restrict or object, on reasonable grounds, to certain types of processing;
• right to request for deletion of your data, subject to legal or regulatory requirement for its continued processing;
• right to withdraw consent previously given; and
• right to file a complaint in the event you feel your data privacy rights are not being adequately protected by us.

We reserve the right to revise or change this Privacy Policy from time to time. Where the changes are material, you will be notified. Your continued use following any revision to this policy will be deemed as your acceptance of all changes.

The latest version of our privacy statement will replace all earlier versions, unless it says differently.