This data privacy, protection and cookie policy (“Privacy Policy”) describes your privacy rights regarding Hotbot Technology Platforms Limited (“Hotbot”, “we”, “us” or “our”) collection, use, storage, sharing and protection of your personal information. It applies to our website and all related sites, applications, services and tools regardless of how you access or use them.
This Privacy Policy will help you understand how we use your information and what we do with it and applies to all forms of systems, operations and processes within the Hotbot environment that involve the collection, storage, use, transmission and disposal of Personal Information. However, the application of this Privacy Policy does not extend to services that are not owned or controlled by Hotbot, including third-party websites and the services of other Hotbot’s merchants or partners. Hotbot ensures to handle personal data provided to us by our customers and merchants (“Users”) in strict compliance with applicable data privacy and protection laws.
To use our website or any of our products or services, your consent is required for the use of your data as described in this Privacy Policy
1. About Hotbot
Hotbot is a technology provider which facilitates e-commerce among individuals or companies willing to trade goods and services.
We are an independent contractor for all purposes, providing this website and our services on an independent service provider basis. We do not have control or assume the liability or legality for the products or services that are paid for with our service. We do not guarantee any user’s identity and cannot ensure that a buyer or seller will complete a transaction.
2. Updates, Modifications & Amendments
We may need to update, modify or amend our Privacy Policy as our technology evolves and as required by law. We reserve the right to make changes to this Privacy Policy from time to time and notify Users of material changes. The Privacy Policy will apply from the effective date provided on our website at the time of publishing the updates.
We advise that you check this page often, referring to the date of the last modification on the page. If a User objects to any of the changes to this Privacy Policy, the User must cease using this website or any of our Services. Where such User continues to use this website and/or any of our Services, it shall continue to be bound by the terms of this Privacy Policy.
3. Age Restriction
Our website and Services are not directed to children under 18. We do not knowingly collect information from, or conduct business with, children under 18. If as a parent or guardian, you become aware that your child or ward has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.
4. The Information we Collect
a. Personal Information
As part of our operations, Hotbot collects and processes certain types of information (such as name, telephone numbers, email address, physical address, financial information etc.) of individuals that makes them easily identifiable. These individuals include current, past and prospective employees, merchants, suppliers/vendors, customers of merchants, Users and other individuals whom Hotbot communicates or deals with, jointly and/or severally (“Data Subject(s)”).
Hotbot is firmly committed to complying with applicable data protection laws, regulations, rules and principles to ensure security of Personal Information handled by Hotbot.
To gain full access to our website and services, you may need to register for a Hotbot account. When you register for an account, we collect Personal Information which you voluntarily provide to us. Personal Information refers to information relating to an identified person or information that can be used to identify you, (e.g. email address, bank details, name, telephone number). It may also include anonymous information that may be linked to you specifically, (e.g. IP address).
- We use your Personal Information to:
- Provide you with the required services, including opening a user account, carrying out necessary KYC/CDD, monitoring ongoing compliance and reporting to regulators.
- Respond to your questions or requests.
- Improve features, website content and analyze data to develop products and services.
- Address inappropriate use of our website.
- Prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools.
- Send you marketing content, newsletters and service updates curated by Hotbot, however, we will provide you with an option to unsubscribe if you do not want to hear from us.
- Verify your identity and the information you provide in line with Hotbot’s statutory obligations using internal and third party tools.
- Maintain up-to-date records.
- Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies.
- Any other lawful purpose or legal obligation which we may have in the course of providing our services.
We may retrieve additional Personal Information about you from third parties and other identification/verification services such as your financial institution and payment processor. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using the Services through your Hotbot account we will keep records of your transactions and collect information about your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislations.
In providing you with the services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. You consent that we may transfer your data for the purpose of providing you with the services. We will ensure to comply with the requirements of the Nigeria Data Protection Regulation (“NDPR”) with respect to transfer of personal data. We will endeavor to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and your personally identifiable information is treated in a safe and secure manner.
b. Information that we collect from website visitors
We do not collect your Personal Information when you visit our website. However, so we can monitor and improve our website and services we may collect non-personally-identifiable information. We will not share or disclose this information with third parties except as a necessary part of providing our website and services. We may use the information to target advertisements to you.
c. Information that we collect from checkout users
When you checkout with Hotbot on a merchant’s website, we collect and store your payment information, your email address, your mobile phone number, and billing and shipping address. To ensure your payment information is kept safe and secure on our servers, we implement access control measures (physical and virtual), security protocols, policies and standards including the use of encryption and firewall technologies in compliance with the PCI-DSS Requirements and we implement periodical security updates to ensure that our security infrastructures are in compliance with reasonable industry standards.
We may share your contact information with merchants as part of your transaction details for record purposes. We will not share this information with other third parties except as a necessary part of providing our website and services. We do not share your card information with merchants. Please review your merchant’s privacy policy to understand the privacy policies guiding the merchant you transact with.
5. Purpose Limitation
Hotbot collects Personal Information only for identified purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose.
6. Data Minimization
Hotbot limits Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. Hotbot will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.
7. Cookies
We use cookies to identify you as a User and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.
Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.
If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience using our website.
8. How We Protect your Information
Hotbot shall establish adequate controls in order to protect the integrity and confidentiality of Personal Information, both in digital and physical formats and to prevent Personal Information from being accidentally or deliberately compromised.
Hotbot is committed to managing your Personal Information in line with global industry best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration, we also use industry recommended security protocols to safeguard your Personal Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to Personal Information to only employees who require it to fulfill their job responsibilities. Any Personal Information processing undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties is unauthorized.
Employees may have access to Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Information for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.
9. How we share the Personal Information you provide
Hotbot does not sell, trade or rent personal information to anyone. However, to enable us render our services to you on our website, we may share your information with trusted third parties, such third parties include financial institutions, payment processors, verification services, sanctions screening and identity verification services, any third party that you have directly authorized to receive your Personal Information, as well as any third party which we may be mandated to provide the data to by law or an order of a competent court. Your Personal Information may be stored in locations outside the direct control of Hotbot, for instance, on servers or databases co-located with hosting providers.
We may be constrained to disclose your Personal Information in compliance with applicable law or a legal obligation to which we are bound.
Please note that merchants, sellers, and other Users you buy from or contract with have their privacy policies, and although Hotbot’s Terms of Use does not allow the other transacting party to use your information for anything other than as authorised by you, Hotbot is not responsible for their actions, including their information protection practices.
The use of your information by such third parties will be subject to their applicable privacy policy, which you should carefully review.
10. Transfer of Personal Information
a. Third Party Processor within Nigeria
Hotbot may engage the services of third parties in order to process the Personal Information of Data Subjects collected by us. The processing by such third parties shall be governed by a written contract with Hotbot to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with the terms of this Privacy Policy.
b. Transfer of Personal Information to Foreign Country
Where Personal Information is to be transferred to a country outside Nigeria, Hotbot shall put adequate measures in place to ensure the security of such Personal Information. In particular, we shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) White List of Countries with adequate data protection laws and comply with the provisions of the NDPR in making such transfers.
Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the NDPR. Hotbot will therefore only transfer Personal Information out of Nigeria on one of the following conditions:
- The consent of the Data Subject has been obtained;
- The transfer is necessary for the performance of a contract between Hotbot and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request;
- The transfer is necessary to conclude a contract between Hotbot and a third party in the interest of the Data Subject;
- The transfer is necessary for reasons of public interest;
- The transfer is for the establishment, exercise or defense of legal claims;
- The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
Hotbot will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.
11. Grounds for Processing of Personal Information
Processing of Personal Information by Hotbot shall be lawful if at least one of the following applies:
- the Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;
- the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which Hotbot is subject;
- processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
- processing is necessary for the performance of a task carried out in the public interest or in exercise of an official public mandate vested in Hotbot.
For the purpose of this Privacy Policy, consent means any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.
12. Choices and Rights
Individuals who have Personal Information held by Hotbot are entitled to reach out to exercise the following rights:
- Right to request for and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format;
- Right to information on their personal information collected and stored;
- Right to objection or request for restriction;
- Right to object to automated decision making;
- Right to request rectification and modification of Personal Information which Hotbot keeps;
- Right to request for deletion of their data;
- Right to request the movement of data from Hotbot to a third party; this is the right to the portability of data; and
- Right to object to, and to request that Hotbot restricts the processing of their information.
Such requests will be reviewed by Hotbot’s Data Protection Officer and carried out except as restricted by law or Hotbot’s statutory obligations. You may decline to provide your personal Information when it is requested by Hotbot, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.
13. The Data that We Retain
We will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations or verify your information with a financial institution.
Hotbot is statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us, our banking providers and card processors.
Therefore, even after closing your Hotbot account, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by Hotbot where possible. For all Personal Data and records obtained, used and stored by Hotbot, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.
The length of storage of Personal Information shall, amongst other things, be determined by:
- the contract terms agreed between Hotbot and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
- whether the transaction or relationship has statutory implication or a required retention period; or
- whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require Hotbot to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
- whether Hotbot has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
14. Contact
If you have any questions relating to this Privacy Policy or would like to find out more about exercising your data protection rights, please reach out to us via email at “compliance@hotbot.com”.
| Title | Initial Publication | Date of Next Review | Version |
|---|---|---|---|
| DPO | 18th August 2020 | 6th September 2021 | 1.0 |
| DPO | 6th September 2021 | 6th September 2022 | 2.0 |