COMPERIT PRIVACY POLICY

Comperit is a digital platform owned and operated by Clicks International (“Clicks International”, “we”, “us”, or “our”).

Clicks International is the legal entity responsible for the processing of personal data in connection with the Comperit platform, subject to the circumstances described in this Privacy Policy.

Comperit is one of Clicks International’s products and is designed to help customers discover, compare and make informed decisions about businesses and service providers, while helping businesses list, promote and grow their businesses.

Legal Entity: Clicks International

Product/Platform: Comperit

Registered Address: 8a John Olanrele Street, Magodo Phase 1, Lagos, Nigeria

Privacy Contact: info.clicksint@gmail.com

Data Protection Officer / Privacy Contact: Mercy Ajuma Ochiagha

This Privacy Policy explains how Clicks International collects, uses, stores, discloses, protects and otherwise processes personal data through Comperit.

This Privacy Policy applies to personal data processed through Comperit, including:

• the Comperit website;
• Comperit mobile applications;
• business and service-provider profiles;
• search and comparison features;
• account and registration services;
• reviews and ratings;
• favourites and saved information;
• campaigns and promotional features;
• referral and rewards programmes;
• subscriptions and payment-related activities;
• customer support and communications; and
• other features, products or services made available through Comperit.

This Privacy Policy applies whether you interact with Comperit as a customer, business, service provider, visitor, registered user or other participant.

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

We collect personal data that is reasonably necessary to operate, secure, maintain and improve Comperit.

The type of information collected depends on how you use the platform.

3.1 Information You Provide Directly

Depending on your interaction with Comperit, we may collect:

• full name;
• email address;
• telephone number;
• country;
• state, province or region;
• address or other location information where required;
• account and authentication information;
• business name;
• business contact information;
• business location;
• business description;
• business category;
• services offered;
• service descriptions;
• pricing and price ranges;
• photographs, images and videos;
• flyers and other uploaded media;
• social media handles, usernames or links;
• reviews, ratings and other content you submit;
• campaign information;
• referral information;
• subscription information;
• information provided to customer support;
• communications between you and Clicks International; and
• information you voluntarily provide when participating in surveys, promotions, competitions or other activities.

We may also collect information necessary to verify your identity, account, business or eligibility for certain features where such verification is required.

When you use Comperit, certain technical and usage information may be collected automatically.

This may include:

• IP address;
• device type;
• operating system;
• browser type;
• mobile-device information;
• application version;
• device or account identifiers;
• approximate location derived from technical information, where applicable;
• pages, screens or features accessed;
• search activity;
• clicks and interactions;
• session information;
• date and time of activity;
• referral source;
• crash and diagnostic information;
• performance information;
• notification interactions;
• campaign interactions; and
• other technical information reasonably necessary to operate, secure and improve the platform.

We may use this information to understand how Comperit is used, maintain platform performance, detect technical problems, protect the platform and improve our services.

We may receive personal data from third parties where necessary and lawful to provide or protect Comperit.

Depending on the service and your interaction with the platform, these sources may include:

• payment service providers;
• authentication or verification providers;
• communication and notification providers;
• social-media platforms where you choose to connect or share content;
• referral participants;
• fraud-prevention and security providers;
• business or service providers with whom you interact through Comperit; and
• other service providers acting on our behalf.

The information received may include account identifiers, transaction information, verification information, technical information and other information necessary for the relevant service.

Where appropriate, the relevant third party may process your information under its own privacy policy.

If you register a business or service-provider account, we may collect information necessary to create and manage your business profile.

This may include:

• business name;
• business category;
• services offered;
• service descriptions;
• pricing or price ranges;
• business location;
• business contact information;
• business images and videos;
• promotional materials;
• social-media information;
• campaign information;
• referral activity;
• profile engagement;
• customer interactions;
• subscription information; and
• performance and analytics information.

Some information submitted by businesses may be displayed publicly through Comperit.

Business users are responsible for ensuring that information they submit is accurate, lawful and does not infringe the rights of another person or organisation.

If you use Comperit to discover, compare or interact with businesses and service providers, we may process information such as:

• searches;
• categories and services viewed;
• providers compared;
• providers saved as favourites;
• reviews and ratings;
• notifications interacted with;
• contact or engagement activity;
• information provided during registration;
• information provided when saving a favourite; and
• information provided when contacting or interacting with a business through Comperit.

Certain areas of Comperit may be available without registration. Some features may require you to create an account.

We process personal data for purposes that are lawful, specific and reasonably necessary for the operation of Comperit.

These purposes include:

8.1 Providing and Operating Comperit

We may process personal data to:

• create and manage accounts;
• provide search and comparison functionality;
• display business and service listings;
• facilitate favourites and saved information;
• process reviews and ratings;
• provide customer support;
• send service notifications;
• manage subscriptions;
• provide business dashboards;
• operate campaigns;
• administer referral programmes; and
• provide other features requested by users.

8.2 Improving Comperit

We may use appropriate usage and technical information to:

• understand how users interact with Comperit;
• improve features and functionality;
• improve search and discovery;
• identify technical problems;
• develop new features;
• measure platform performance; and
• improve the overall user experience.

8.3 Security, Fraud Prevention and Abuse Detection

We may process information to:

• protect user accounts;
• verify users;
• prevent fraud;
• detect abuse;
• detect suspicious activity;
• prevent manipulation of reviews, campaigns or referral programmes;
• protect the security of Comperit;
• investigate security incidents; and
• enforce our terms, policies and platform rules.

Certain activities may use OTP verification, device information or other technical controls for security and fraud prevention.

8.4 Communications

We may use your contact information to send:

• account-related communications;
• security alerts;
• service notifications;
• transactional communications;
• important platform updates;
• information you have requested;
• campaign-related communications; and
• marketing communications where permitted by law and consistent with your choices.

Depending on the circumstances and applicable law, Clicks International may process personal data on one or more of the following lawful bases:

Consent

Where you have freely given consent to a specific processing activity.

Where processing is based on consent, you may withdraw that consent where applicable.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Contract

Where processing is necessary to provide a service you have requested, manage your account or take steps at your request before entering into an agreement.

Legitimate Interests

Where processing is necessary for our legitimate interests or those of another party, provided those interests do not override your applicable privacy rights.

This may include:

• platform security;
• fraud prevention;
• service improvement;
• analytics;
• business operations;
• protection of users; and
• protection of the platform.

Legal Obligation

Where processing is necessary to comply with applicable law, regulation, legal process or lawful governmental requirements.

Other Lawful Bases

Where applicable law recognises another lawful basis for processing, we may rely on that basis where appropriate.

The lawful basis used will depend on the particular purpose and circumstances of the processing.

We aim to collect personal data that is adequate, relevant and reasonably necessary for the purposes for which it is processed.

We also take reasonable steps to maintain accurate and up-to-date personal data where accuracy is necessary for the relevant processing purpose.

You should provide accurate information and update your account or business information when it changes.

Comperit may allow eligible users to submit ratings, reviews and other content.

Reviews may be associated with your account, profile or other identifying information depending on the design and functionality of the platform.

Reviews are intended to reflect genuine user experiences. Where applicable, we may use verification mechanisms before a review can be submitted.

We may moderate, restrict, remove or investigate content that violates our Terms and Conditions, Community Guidelines, applicable law or other platform rules.

Please do not include sensitive personal information about another person in a review or other public submission.

Businesses may choose to publish information through Comperit.

Information designated for public display may include:

• business name;
• business category;
• services;
• pricing or price ranges;
• business location;
• business description;
• images and videos;
• promotional materials;
• social-media links;
• ratings and reviews; and
• other information designated as public.

Publicly displayed information may be viewed, accessed, copied or shared by other users or members of the public.

Businesses must not publish personal information about employees, customers, contractors or other individuals unless they have a lawful basis and appropriate authority to do so.

Businesses may use Comperit to create and manage promotional campaigns.

Depending on the subscription plan and available functionality, campaign features may include:

• campaign creation;
• audience selection or targeting;
• campaign scheduling;
• external social-media sharing; and
• campaign performance measurement.

We may process campaign interaction information, including views, clicks, engagement and conversions, to provide campaign analytics and improve the platform.

Campaign functionality may vary by subscription plan, location and platform configuration.

Comperit may operate referral or rewards programmes using unique referral codes or other mechanisms.

Where applicable, we may process:

• referral codes;
• referrer information;
• referred-user information;
• referral activity;
• verification information;
• reward eligibility;
• reward history; and
• technical information used for fraud prevention.

Referral information may be used to determine eligibility, administer rewards, prevent abuse and protect the integrity of the programme.

Businesses may be able to subscribe to paid Comperit plans.

Subscription information may include:

• selected plan;
• country;
• currency;
• subscription status;
• subscription start date;
• expiry or renewal information;
• payment status;
• transaction reference; and
• payment-related metadata.

Payments may be processed through third-party payment service providers.

Where payment details are collected directly by a payment provider, Clicks International generally does not need to receive or store full payment-card information.

Payment providers may independently process personal data in accordance with their own privacy policies and terms.

You should review the privacy policy of the payment provider you use.

Comperit may use cookies, software development kits (SDKs), pixels, local storage and similar technologies.

These technologies may be used for:

Essential Technologies

To:

• keep you signed in;
• maintain security;
• support core platform functionality;
• remember essential settings; and
• prevent fraud.

Preference Technologies

To remember choices such as:

• language;
• currency; and
• certain platform preferences.

Analytics Technologies

To understand:

• traffic;
• usage;
• feature performance;
• user journeys; and
• platform performance.

Marketing Technologies

Where applicable and legally permitted, technologies may be used to measure or support advertising and marketing activities.

Where consent is required by applicable law, non-essential cookies or similar tracking technologies will not be activated until the required consent has been obtained.

Where applicable, Comperit will provide a conspicuous cookie notice explaining the presence and purpose of relevant technologies, identify Clicks International as the organisation responsible for their use, and provide an appropriate mechanism for managing or withdrawing consent.

You may also be able to control certain cookies through your browser or device settings.

Blocking certain technologies may affect the availability or functionality of some parts of Comperit.

Comperit may support multiple languages and currencies.

Your language or preference settings may be stored to provide a consistent user experience.

Depending on the country and platform configuration, available currencies may include:

• Nigerian Naira (NGN);
• United States Dollar (USD);
• British Pound Sterling (GBP); and
• Euro (EUR).

Available languages, currencies, features and subscription options may vary by country.

We do not sell your personal data merely because you use Comperit.

We may disclose or otherwise share personal data where reasonably necessary to provide the platform, fulfil your instructions, protect users, operate our business or comply with applicable law.

This may include sharing information with:

18.1 Service Providers

Third-party providers that support the operation of Comperit, including providers of:

• hosting and cloud infrastructure;
• databases and storage;
• authentication and OTP services;
• communications and notifications;
• analytics;
• payment processing;
• customer support;
• security;
• fraud prevention; and
• other technology services.

These providers may process personal data only as necessary to provide the services for which they are engaged, subject to applicable contractual, legal and security requirements.

18.2 Businesses and Service Providers

Where you choose to interact with a business or service provider through Comperit, we may share information necessary to facilitate that interaction.

18.3 Social-Media Platforms

Where you choose to share content, campaigns or other information to a supported social-media platform, information may be transmitted to that platform according to your instructions.

That platform will process the information under its own terms and privacy policy.

18.4 Legal and Regulatory Authorities

We may disclose personal data where reasonably necessary to:

• comply with applicable law;
• respond to lawful requests;
• comply with court orders or regulatory requirements;
• protect our legal rights;
• prevent fraud;
• investigate abuse;
• protect users; or
• protect the security and integrity of Comperit.

18.5 Corporate Transactions

If Clicks International or a material part of the Comperit business is involved in a merger, acquisition, restructuring, financing, sale or similar corporate transaction, personal data may be transferred as part of that transaction, subject to applicable law and appropriate protections.

Because Comperit may use technology, infrastructure and service providers operating in different countries, personal data may be processed or stored outside the country in which you reside.

Where personal data is transferred internationally, Clicks International will take reasonable steps required by applicable law to ensure that the transfer is subject to appropriate safeguards.

Depending on the circumstances, safeguards may include contractual, technical, organisational or other legally recognised protections.

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected or further processed.

The appropriate retention period may depend on:

• the nature of the information;
• the purpose for which it was collected;
• whether your account remains active;
• contractual requirements;
• legal and regulatory requirements;
• dispute resolution;
• fraud prevention;
• security requirements;
• enforcement of agreements; and
• legitimate business-record requirements.

Different categories of information may therefore be retained for different periods.

When personal data is no longer required, we may securely delete, anonymise or otherwise dispose of it in accordance with applicable law and our internal retention procedures.

Deletion may not always be immediate where information must be retained for legal, security, fraud-prevention, dispute-resolution or other legitimate purposes.

Clicks International takes reasonable technical and organisational measures designed to protect personal data against unauthorised or unlawful processing, unauthorised access, loss, destruction, alteration, misuse and accidental disclosure.

Depending on the nature of the information and the risks involved, security measures may include:

• access controls;
• authentication mechanisms;
• role-based permissions;
• encryption where appropriate;
• security monitoring;
• backups;
• system safeguards;
• fraud-prevention controls;
• incident-management procedures; and
• organisational security measures.

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

You are responsible for maintaining the confidentiality of your account credentials and should notify us promptly if you believe that your account has been compromised.

If Clicks International becomes aware of a personal data breach, we will assess the incident and take reasonable steps to investigate, contain, mitigate and remediate the breach.

Where notification is required by applicable law, we will notify the relevant regulatory authority within the applicable statutory period and communicate with affected data subjects where required.

Where the Nigeria Data Protection Act 2023 applies, Clicks International will comply with the statutory requirements governing personal-data breach notification, including applicable notification requirements for breaches that are likely to result in a risk to the rights and freedoms of individuals.

Subject to applicable law and relevant conditions, you may have the following rights:

Right to Be Informed

You have the right to receive clear information about how your personal data is processed.

Right of Access

You may request access to personal data we hold about you and information concerning its processing.

Right to Rectification

You may request correction of inaccurate or incomplete personal data.

Right to Object

You may have the right to object to certain processing of your personal data.

Right to Restrict Processing

You may, in appropriate circumstances, request that certain processing of your personal data be restricted.

Right to Data Portability

Where applicable, you may request your personal data in a structured, commonly used and machine-readable format.

Right to Erasure

You may request deletion of your personal data in appropriate circumstances.

This right is not absolute. We may retain certain information where required or permitted by law or where another lawful basis for retention applies.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent.

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Rights Relating to Automated Decision-Making

Where applicable, you may have rights relating to decisions based solely on automated processing, including rights recognised under applicable data-protection law.

Where required by law, appropriate safeguards and human intervention mechanisms will be provided.

Right to Lodge a Complaint

You may lodge a complaint with the relevant data-protection supervisory authority where you believe your personal data has been processed in violation of applicable data-protection law.

To make a privacy or data-subject request, contact:

Privacy / Data Protection Email: info.clicksint@gmail.com

Your request should provide sufficient information for us to understand what you are requesting and, where reasonably necessary, verify your identity.

We may request additional information where necessary to prevent unauthorised disclosure of personal data.

We will respond to valid requests within the period required by applicable law.

We may decline or limit a request where permitted or required by law, including where:

• fulfilling the request would adversely affect the rights of another person;
• disclosure is prohibited by law;
• information must be retained to comply with a legal obligation;
• the request would compromise security or fraud-prevention measures; or
• another lawful exemption applies.

Where we cannot fully comply with a request, we will explain the reason where legally permitted.

Where permitted by applicable law, we may send marketing communications about Comperit, Clicks International products, services, promotions or other relevant opportunities.

You may unsubscribe from promotional email communications by using the unsubscribe mechanism included in the communication or by contacting us.

You may continue to receive essential communications that are necessary for the operation or security of your account, including:

• security alerts;
• account notifications;
• transaction-related communications;
• service notifications; and
• important platform updates.

Where account deletion functionality is available, you may request deletion of your Comperit account through the available account-management functionality or by contacting us.

Account deletion does not necessarily result in immediate deletion of every piece of information associated with your account.

We may retain information where necessary or permitted for:

• legal compliance;
• fraud prevention;
• security;
• dispute resolution;
• enforcement of agreements;
• financial or transaction records; or
• other legitimate purposes recognised by applicable law.

Where possible, information that no longer needs to identify you may be anonymised.

Public content, including certain business listings, reviews or other user-generated content, may require additional processing depending on its nature and applicable legal requirements.

Comperit may contain links, integrations or features provided by third parties.

Third-party websites and services operate independently from Clicks International and may have their own privacy policies, terms and data-processing practices.

We are not responsible for the privacy practices of third-party websites or services that we do not control.

We encourage you to review the privacy policies and terms of third-party services before providing personal information or using their services.

Comperit is not intended to knowingly collect personal data from children in circumstances where such collection is prohibited by applicable law.

Where applicable law imposes specific age requirements or parental-consent requirements, Clicks International will apply those requirements.

If you believe that a child has provided personal data to us without the appropriate authorisation, please contact us so that we can investigate and take appropriate action.

If you use Comperit as a business or service provider, you are responsible for ensuring that:

• information you submit is accurate;
• you have the lawful right and authority to submit personal information;
• you have appropriate permission to upload images, videos and other media;
• you do not unnecessarily upload sensitive personal information;
• you do not use Comperit to unlawfully collect, disclose or misuse another person's personal data;
• your campaigns and communications comply with applicable laws;
• your advertising and promotional activities comply with applicable requirements;
• information displayed publicly through your profile is lawful and appropriate; and
• you respect the privacy rights of customers, employees, contractors and other individuals whose information you submit.

Where a business uses Comperit to process personal data relating to its own customers or other individuals, the business remains responsible for complying with the data-protection obligations applicable to its own processing activities.

Clicks International is committed to responsible data governance and privacy-by-design principles.

We may periodically review our data-processing activities, security measures, privacy practices and platform features to identify and manage privacy risks.

Where required or appropriate, we may conduct privacy assessments, maintain internal data-protection procedures, provide relevant training and implement additional safeguards based on the nature and risk of the processing.

We may update this Privacy Policy from time to time to reflect:

• changes to Comperit;
• changes to our data-processing practices;
• new products or features;
• changes in technology;
• changes in service providers;
• changes in applicable laws or regulatory requirements; or
• improvements to our privacy practices.

When we make material changes, we will take reasonable steps to notify users where required by applicable law.

The “Last Updated” date at the beginning of this Privacy Policy indicates when the latest version became effective.

If you have questions, concerns, requests or complaints about this Privacy Policy or how Clicks International processes your personal data through Comperit, please contact:

Clicks International

Product: Comperit

Privacy / Data Protection Contact: Mercy Ajuma Ochiagha

Email: info.clicksint@gmail.com

Registered Address: 8a John Olanrele Street, Magodo Phase 1, Lagos, Nigeria

We encourage you to contact us first so that we can investigate and attempt to resolve any privacy concern.

Where applicable, you also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another relevant data-protection supervisory authority.

Nothing in this Privacy Policy prevents you from exercising any statutory right available to you.