Legal

# Privacy
Policy

This Privacy Policy explains how EbonyLife collects, uses, protects, and shares your personal information across all of our services — online, in-venue, and via our apps.

Last updated: November 2023 Governed by: NDPR — Nigeria
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We Protect Your Data
All data is stored on secure servers with SSL encryption for payment transactions
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You Are in Control
You have the right to access, correct, erase or restrict how we use your personal information
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No Selling Your Data
We never sell your personal information to third parties for direct marketing purposes
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NDPR Compliant
This policy complies with the Nigerian Data Protection Regulation (NDPR)
Part A

## Introduction & Acknowledgements

1

This Privacy Policy provides you with information about EbonyLife's collection and processing of your Personal Information through your use of EbonyLife's online and offline services — including the Website, Contact Services, Mobile Apps, EbonyLife Social Media, EbonyLife Wi-Fi, and all other EbonyLife Services.

2–3

For information about the companies collectively referred to as 'EbonyLife' in this Policy, see Part B. For definitions of all terms used, see Part C.

4

Please read this Privacy Policy carefully before providing any personal information to us. This Policy supplements other notices and is not intended to override them.

5

When you do any of the following, you acknowledge that you have read and agree to this Privacy Policy:

- Access or use our Website or EbonyLife Social Media
- Download, use or register on a Mobile App
- Contact EbonyLife for any reason
- Use EbonyLife Wi-Fi
- Apply for, sign up for, or use any EbonyLife Services

### Amendments

6

EbonyLife reserves the right to amend this Privacy Policy at any time. Amendments take effect when posted on our platforms. Please check our "Privacy and Legal" section regularly. Continued use of our services after any amendment constitutes your agreement to the updated Policy.

7

We will only use your Personal Information for the purposes for which it was collected and other compatible purposes. We may process your Personal Information without your knowledge or consent where required or permitted by law.

Part B

## EbonyLife Companies

8

EbonyLife Cinemas Limited and The White Orchid Hospitality Limited provide hospitality and entertainment services under the EbonyLife brand in Nigeria. "EbonyLife / we / our / us" refers to these companies as controllers for the respective service referred to in this Policy.

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#### Controllers under the NDPR

Company | Nature of Service
--- | ---
EbonyLife Cinemas Limited | Controller for Personal Information processed in connection with the sale of cinema tickets, food, drink and merchandise; and administration of transactions for The White Orchid Hotel, Jinja, Túraká, EbonyLife Wi-Fi and EbonyLife Place.
The White Orchid Hospitality Limited | Controller for Personal Information processed in connection with the sale of food, drink and merchandise for The White Orchid Hotel, Jinja, Túraká, EbonyLife Wi-Fi and EbonyLife Place.

Sponsor Associates may also be controllers in certain circumstances — see Paragraph 37.1.

Part C

## Definitions

11

Mobile Apps | Our mobile applications developed for different operating systems (Apple iOS, Android).
EbonyLife Services | Use of the Website, Mobile Apps, Social Media or Wi-Fi; purchasing tickets, goods and services at EbonyLife Cinemas; hiring cinemas for events such as birthday parties or film screenings.
EbonyLife Social Media | Parts of social media provided by third parties (Facebook, Twitter/X, Instagram, etc.) through which EbonyLife provides services, information, applications and advertisements.
EbonyLife Wi-Fi | The wireless internet access provided by EbonyLife at EbonyLife Place, Victoria Island.
NDPR | The Nigerian Data Protection Regulation and any amendments or updates that come into force.
Personal Information | Any information about you from which you can be identified. Does not include anonymous data.
Privacy Policy | This document and any amended or updated versions created by us.
Website | www.ebonylifeplace.com and any websites redirected from it, including other websites operated by EbonyLife for its entertainment and hospitality centre.

Part D

## Personal Information We May Collect

Within the limits of relevant laws, we may collect the following categories of Personal Information about you:

#### 🪪 Identity Information

First name, last name, title, date of birth, age, health or disability status, photographs, and social media profile username.

#### 📬 Contact Information

Billing address, delivery address, email address, and telephone numbers.

#### 💳 Financial Information

Bank account details, direct debit details, gift card details, credit and debit card details, and card tokens.

#### 🧾 Transactional Information

Details of payments to and from you, usage of points, vouchers, promotions, memberships, gift cards, and products or services purchased.

#### 💻 Technical Information

Device type, IP address, session data, browser type and version, time zone setting, and location data.

#### 👤 Profile Information

Your interests, preferences, feedback, survey responses, and information about how you use EbonyLife Services.

#### 📣 Marketing Preferences

Your preferences in receiving marketing from us and third parties, and your communication preferences.

#### 📷 Other Information

Any personal information you voluntarily share with us, as well as CCTV footage when you attend our premises.

13

#### Aggregated Data

We also collect, use and share aggregated data (e.g. statistical or demographic data). This is not considered Personal Information as it does not identify you. However, if aggregated data is combined with your Personal Information in a way that identifies you, we treat the combined data as Personal Information and use it accordingly.

14

Purchases: If you make a purchase, EbonyLife collects the information needed to fulfil your order and notify you of its status. Where you pay by card, we obtain a card token as part of the payment authorisation process.

15–17

Competitions & Surveys: We collect Personal Information you submit when entering competitions or promotions, and may invite you (with your consent) to participate in surveys. Participation in surveys is entirely voluntary.

If you contact us for any reason, we may keep a record of that correspondence.

Part E

## Social Media, Mobile Apps & Wi-Fi

19

Mobile Apps: Certain app functions require location data from your device (e.g. finding your nearest cinema). If you do not want the app to use your location data, please change the settings on your device.

20

Social Media: EbonyLife Social Media is provided via third-party social media sites which have their own terms, cookies and privacy policies. You should read these carefully and check your personal settings before using social media integrations.

EbonyLife is not liable for any loss suffered as a result of your use of third-party social media sites.

21

We may upload your name and contact details into social media platforms to create targeted advertising campaigns. We rely upon your consent for marketing for such purposes.

23–24

Wi-Fi: When you use EbonyLife Wi-Fi, we may collect information about your device and its location, the volume of data you use, and the websites and applications you access.

If you do not want EbonyLife Wi-Fi to use your location data, please change your device settings. Disabling location access may result in loss of certain functionality.

Part F

## Our Use of Your Information & Legal Justification

We will only use your Personal Information where one of the following legal bases applies:

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#### Permitted by Law

We are permitted by law to process your information in the relevant circumstances.

26

#### Contractual Necessity

Processing is necessary to conclude or perform a transaction with you.

27

#### Legitimate Interests

Processing is necessary for our legitimate interests (or those of a third party), provided your interests and rights do not override those interests.

28

#### Legal Obligation

Processing is necessary to comply with a legal or regulatory obligation.

29

Purchases: We use your information to fulfil your order, send booking confirmations, and generate a profile of your purchase preferences so we can send you more relevant advertising and offers. We may also use anonymised data for statistical and trend analysis.

Marketing

## Marketing Communications

30

If you are over 18 and have consented, or have transacted with us, we may send you marketing communications about related or similar EbonyLife products and services.

31

EbonyLife marketing communications may cover film times, cinema news, promotions, loyalty schemes, competitions, special offers, and information about EbonyLife products and services. We will communicate through the channels you have opted into.

32

We will never sell your personal information. Marketing messages will only come from EbonyLife. We do not pass your Personal Information to any third party for their direct marketing. Where we share news about partner organisations, we do not disclose your identity to them.

34

EbonyLife Wi-Fi: Data collected during your Wi-Fi session is used only to provide you with access to the Wi-Fi service — not for marketing or profiling.

Premises

## CCTV Surveillance

35

We use CCTV systems in our premises for our legitimate interests — and those of our customers, visitors, business partners and service providers — in detecting, investigating and addressing incidents including health and safety issues and unlawful acts.

CCTV footage may be used by us, relevant third parties, our representatives, the police, or health and safety investigators, in detecting and addressing any incidents.

Part G

## Sharing Your Information with Third Parties

37

We may share your Personal Information with the following third parties:

- Sponsor Associates — organisations to whose customers we provide goods, services and events. We share your data only to the extent relevant to the specific Sponsored Screening, and only if you are a Sponsor Customer. Sponsor Associates may be independent controllers of your data in such cases, governed by their own privacy policy.
- Service Providers — third parties performing functions on our behalf (e.g. developing and maintaining databases, creating and analysing customer communications, administering competitions, providing customer services).
- Processors — where we transfer data to service providers acting as processors, they are required to comply with appropriate NDPR safeguards.

38

We reserve the right to release Personal Information without your consent where this is appropriate to comply with legal obligations, enforce our terms, protect the security of our services, prevent fraud, or protect the legitimate interests of EbonyLife or its customers.

39

We may share statistical (anonymised) information about customers with advertisers, business partners and sponsors. This information is always shared in a way that ensures your identity is not revealed.

40

If EbonyLife or any part of our business is restructured, sold, or integrated with another business, we may transfer customer information (including your Personal Information) to other companies in the EbonyLife group or to the new owners, as appropriate.

Part H

## Safeguards for Your Information

41

We follow strict security procedures, processing Personal Information in a manner that ensures appropriate security — including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.

Payment transactions are encrypted using SSL technology. We store your information on secure servers. However, we cannot guarantee the absolute security of information transmitted over the Internet — any such transmission is at your own risk.

42

We have procedures in place to deal with any suspected Personal Information breach. We will notify you and any applicable supervisory authority of a breach where legally required to do so.

43

If you are provided with a username, password, or other security information, you must treat it as strictly confidential and not disclose it to any third party. Notify us immediately of any suspected unauthorised use. We reserve the right to disable any account if we believe you have failed to keep your security information secure.

Part I

## How Long We Keep Your Data

44

We will only retain your Personal Information for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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To determine the appropriate retention period, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your Personal Information so it no longer identifies you, in which case we may use and retain that information indefinitely without further notice to you.

Part J

## Your Rights

Under the NDPR, you have the following rights regarding your Personal Information:

#### Right to Access

Request a copy of the Personal Information we hold about you and how we use it.

#### Right to Rectification

Request that inaccurate or incomplete Personal Information be corrected or completed.

#### Right to Erasure

Request that we delete your Personal Information where there is no good reason for us to continue processing it.

#### Right to Restriction

Request that we suspend the processing of your Personal Information in certain circumstances.

#### Right to Portability

Request transfer of your Personal Information to you or a third party in a structured, machine-readable format.

#### Right to Object

Object to the processing of your Personal Information where we rely on a legitimate interest, including for direct marketing.

To exercise any of your rights, please contact us via the "Contact Us" page of our Website or email us at enquiries@ebonylifeplace.com. We will respond to your request within the timeframes required under the NDPR. In some cases, we may need to verify your identity before processing your request.

Part K

## Cookies

Our Website uses cookies and similar tracking technologies to distinguish you from other users and to enhance your experience. Cookies are small text files placed on your device when you visit our Website.

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#### Types of Cookies We Use

- Strictly Necessary Cookies — essential for the operation of our Website (e.g. enabling you to log in and make purchases)
- Analytical / Performance Cookies — allow us to recognise and count visitors and understand how they navigate our Website, helping us improve it
- Functionality Cookies — used to recognise you when you return and to personalise content for you
- Targeting Cookies — record your visit, pages viewed and links followed to deliver advertising more relevant to your interests

You can block cookies through your browser settings. However, blocking some or all cookies may affect your ability to use parts of our Website. For more information, visit www.allaboutcookies.org.

Contact

## Questions & Data Officer

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how we handle your Personal Information, please contact us.

EbonyLife Cinemas Limited
Registered Office: 6 Industrial Avenue, Ilupeju, Lagos State, Nigeria (RC 1450412)
Operational Address: 1637 Adetokunbo Ademola Street, Victoria Island, Lagos
Email: enquiries@ebonylifeplace.com

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Email
enquiries@ebonylifeplace.com
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Phone
+234 906 800 0006
+234 906 800 0007
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Regulator
Nigerian Data Protection Bureau (NDPB)
Governed by the NDPR