Privacy Policy

PRIVACY POLICY

Last Updated: November 30, 2025

JILOW Horizon Ventures Limited (“we,” “our,” or “us”) is committed to protecting
your privacy. This Privacy Policy explains how we collect, use, disclose, and
safeguard your information when you visit our website (www.jilowhorizon.com and
all associated subdomains) or use our services.

Please read this Privacy Policy carefully. By using our website or services,
you agree to the collection and use of information in accordance with this policy.

INFORMATION WE COLLECT

    We collect information that you provide directly to us, information we obtain
    automatically when you use our website, and information from third-party sources.

    1.1 Information You Provide Directly

    When you interact with our website or services, we may collect:

    Personal Information:

    • Name, email address, phone number, and mailing address
    • Company name and job title (for business inquiries)
    • Date of birth (where required for specific services)
    • Government-issued identification (where legally required)

    Account Information:

    • Username and password (if you create an account)
    • Profile information and preferences
    • Communication preferences

    Payment Information:

    • Billing address and payment method details
    • Transaction history and receipts
    • Note: Payment card details are processed by secure third-party payment
      processors; we do not store complete payment card information

    Communication Information:

    • Content of messages you send us (emails, contact forms, chat messages)
    • Feedback, reviews, and testimonials
    • Survey responses and research participation data

    Employment Information:

    • Resume/CV and cover letter
    • Employment history and references
    • Educational qualifications and certifications

    1.2 Information Collected Automatically

    When you visit our website, we automatically collect:

    Device and Usage Information:

    • IP address and device identifiers
    • Browser type and version
    • Operating system and device type
    • Pages visited, time spent on pages, and navigation paths
    • Referring website or source
    • Date and time of access

    Cookies and Similar Technologies:
    We use cookies, web beacons, and similar tracking technologies to collect
    information about your browsing activities. See our Cookie Policy section
    below for more details.

    Location Information:

    • General location based on IP address
    • Precise geolocation (only if you explicitly grant permission)

    1.3 Information from Third-Party Sources

    We may receive information about you from:

    • Social media platforms (if you connect your account or interact with our
      social media)
    • Business partners and affiliates
    • Public databases and sources
    • Marketing partners and analytics providers
    • Credit bureaus and fraud prevention services (for business purposes)
    1. HOW WE USE YOUR INFORMATION

    We use the collected information for various purposes:

    2.1 To Provide and Improve Services

    • Process your requests, orders, and transactions
    • Deliver services across our eight business ventures
    • Provide customer support and respond to inquiries
    • Improve our website functionality and user experience
    • Develop new products and services
    • Personalize your experience based on preferences

    2.2 For Communication

    • Send service-related notifications and updates
    • Respond to your comments, questions, and requests
    • Send newsletters and marketing communications (with your consent)
    • Provide information about our ventures and offerings
    • Send administrative information and policy updates

    2.3 For Business Operations

    • Process employment applications and manage recruitment
    • Manage accounts and maintain records
    • Conduct internal research and analytics
    • Detect, prevent, and address technical issues
    • Monitor and analyze usage trends and patterns

    2.4 For Marketing and Advertising

    • Send promotional materials and special offers (with your consent)
    • Display targeted advertisements based on your interests
    • Measure effectiveness of marketing campaigns
    • Conduct market research and surveys

    2.5 For Legal and Security Purposes

    • Comply with legal obligations and regulatory requirements
    • Enforce our Terms of Service and other policies
    • Protect against fraud, abuse, and security threats
    • Defend our legal rights and interests
    • Respond to legal requests from authorities
    1. LEGAL BASIS FOR PROCESSING (GDPR AND NDPR COMPLIANCE)

    We process your personal information based on the following legal grounds:

    • Consent: You have given explicit consent for processing your information
      for specific purposes
    • Contract Performance: Processing is necessary to fulfill a contract with you
    • Legal Obligation: We must process your information to comply with legal
      requirements
    • Legitimate Interests: Processing is necessary for our legitimate business
      interests, provided these don’t override your rights
    • Vital Interests: Processing is necessary to protect your life or someone
      else’s life
    1. HOW WE SHARE YOUR INFORMATION

    We do not sell your personal information. We may share your information in the
    following circumstances:

    4.1 Within JILOW Group
    We may share information between our eight business ventures (JILOW Tech,
    JILOW Agro, JILOW Fashion, JILOW Properties, JILOW Edu, JILOW Health,
    E-commerce, and General Goods) to provide integrated services and improve
    your experience across our offerings.

    4.2 With Service Providers
    We share information with third-party service providers who perform services
    on our behalf:

    • Payment processors and financial institutions
    • Cloud storage and hosting providers
    • Email and communication platforms
    • Marketing and analytics services
    • Customer relationship management (CRM) systems
    • Security and fraud prevention services

    All service providers are contractually obligated to protect your information
    and use it only for the purposes we specify.

    4.3 For Business Transfers
    If JILOW Horizon Ventures Limited or any of its ventures undergoes a merger,
    acquisition, reorganization, or sale of assets, your information may be
    transferred as part of that transaction. We will notify you of any such change.

    4.4 With Your Consent
    We may share your information with third parties when you explicitly consent
    to such sharing.

    4.5 For Legal Reasons
    We may disclose your information if required to do so by law or in response to:

    • Legal processes (subpoenas, court orders)
    • Government or regulatory requests
    • Requests from law enforcement
    • Protection of our rights, property, or safety
    • Prevention of fraud or illegal activities

    4.6 Aggregated or De-identified Information
    We may share aggregated or de-identified information that cannot reasonably
    be used to identify you for research, marketing, or analytics purposes.

    1. COOKIES AND TRACKING TECHNOLOGIES

    5.1 What Are Cookies
    Cookies are small text files placed on your device by websites you visit. They
    help websites remember your preferences and improve your experience.

    5.2 Types of Cookies We Use

    Essential Cookies:
    Required for the website to function properly. These cannot be disabled.

    • Session management
    • Security features
    • Load balancing

    Performance Cookies:
    Help us understand how visitors interact with our website.

    • Analytics and statistics
    • Traffic measurement
    • Error reporting

    Functionality Cookies:
    Remember your preferences and choices.

    • Language preferences
    • Login information
    • User settings

    Marketing Cookies:
    Used to deliver relevant advertisements and track campaign effectiveness.

    • Targeted advertising
    • Social media integration
    • Marketing analytics

    5.3 Managing Cookies
    You can control and manage cookies through your browser settings. However,
    disabling certain cookies may affect website functionality. Most browsers
    allow you to:

    • View cookies stored on your device
    • Delete cookies
    • Block cookies from specific sites
    • Block all cookies
    • Delete cookies when you close your browser

    5.4 Third-Party Cookies
    We use services from third parties (Google Analytics, Facebook Pixel, etc.)
    that may place cookies on your device. These third parties have their own
    privacy policies governing their use of information.

    1. DATA SECURITY

    We implement appropriate technical and organizational measures to protect your
    personal information against unauthorized access, alteration, disclosure, or
    destruction.

    6.1 Security Measures Include:

    • Encryption of data in transit and at rest
    • Secure Socket Layer (SSL) technology for data transmission
    • Regular security assessments and audits
    • Access controls and authentication procedures
    • Employee training on data protection
    • Secure data storage with reputable hosting providers
    • Regular backups and disaster recovery procedures
    • Firewall and intrusion detection systems

    6.2 Limitations
    While we strive to protect your information, no method of transmission over
    the internet or electronic storage is 100% secure. We cannot guarantee absolute
    security, and you provide information at your own risk.

    6.3 Your Responsibility
    You are responsible for maintaining the confidentiality of your account
    credentials. Please notify us immediately if you suspect unauthorized access
    to your account.

    1. DATA RETENTION

    We retain your personal information only for as long as necessary to fulfill
    the purposes outlined in this Privacy Policy, unless a longer retention period
    is required or permitted by law.

    7.1 Retention Periods

    Account Information:
    Retained for the duration of your account plus 2 years after account closure

    Transaction Records:
    Retained for 7 years for accounting and tax purposes

    Marketing Information:
    Retained until you withdraw consent or 3 years of inactivity

    Employment Applications:
    Retained for 1 year after application

    Website Analytics:
    Aggregated data retained indefinitely; individual data for 26 months

    Legal Documents:
    Retained as required by applicable laws and regulations

    7.2 Deletion
    After the retention period expires, we securely delete or anonymize your
    information. You may request earlier deletion subject to legal and contractual
    obligations.

    1. YOUR RIGHTS AND CHOICES

    Under Nigerian Data Protection Regulation (NDPR) and international privacy
    laws (where applicable), you have the following rights:

    8.1 Right to Access
    You can request a copy of the personal information we hold about you.

    8.2 Right to Rectification
    You can request correction of inaccurate or incomplete information.

    8.3 Right to Erasure (“Right to Be Forgotten”)
    You can request deletion of your personal information, subject to legal
    obligations.

    8.4 Right to Restrict Processing
    You can request that we limit how we use your information.

    8.5 Right to Data Portability
    You can request your information in a structured, commonly used format.

    8.6 Right to Object
    You can object to processing of your information for marketing purposes or
    based on legitimate interests.

    8.7 Right to Withdraw Consent
    Where processing is based on consent, you can withdraw it at any time.

    8.8 Right to Lodge a Complaint
    You can file a complaint with the Nigeria Data Protection Bureau (NDPB) or
    relevant supervisory authority.

    8.9 How to Exercise Your Rights
    To exercise any of these rights, contact us at:

    • Email: privacy@jilowhorizon.com
    • Email: info@jilowhorizon.com

    We will respond to your request within 30 days. We may require verification
    of your identity before processing your request.

    1. CHILDREN’S PRIVACY

    Our website and services are not directed to children under the age of 18. We
    do not knowingly collect personal information from children under 18. If you
    are a parent or guardian and believe your child has provided us with personal
    information, please contact us immediately. We will take steps to delete such
    information from our systems.

    Certain JILOW ventures (such as JILOW Pathways) may offer services to minors with
    parental consent. In such cases, we comply with all applicable laws regarding
    children’s privacy and obtain appropriate parental consent before collecting
    information from minors.

    1. INTERNATIONAL DATA TRANSFERS

    JILOW Horizon Ventures Limited is based in Nigeria. If you access our website
    or services from outside Nigeria, please be aware that your information may be
    transferred to, stored in, and processed in Nigeria or other countries where
    our service providers operate.

    These countries may have data protection laws different from those of your
    country of residence. By using our services, you consent to the transfer of
    your information to Nigeria and other countries as described in this Privacy
    Policy.

    We take appropriate safeguards to ensure your personal information remains
    protected in accordance with this Privacy Policy, including:

    • Standard contractual clauses approved by relevant authorities
    • Compliance with applicable international data protection frameworks
    • Ensuring third-party processors provide adequate protection
    1. THIRD-PARTY WEBSITES AND SERVICES

    Our website may contain links to third-party websites, applications, or services
    that are not operated by us. This Privacy Policy does not apply to third-party
    websites. We are not responsible for the privacy practices of third parties.

    We encourage you to review the privacy policies of any third-party websites or
    services before providing your information to them.

    Third-party services we may use include:

    • Payment processors (Paystack, Flutterwave, etc.)
    • Social media platforms (Facebook, LinkedIn, Twitter, Instagram)
    • Analytics services (Google Analytics)
    • Cloud storage providers
    • Marketing platforms
    1. MARKETING COMMUNICATIONS

    12.1 Opt-In
    We will send you marketing communications only if you have opted in to receive
    them or where we have another lawful basis to do so.

    12.2 Opt-Out
    You can opt out of marketing communications at any time by:

    • Clicking the “unsubscribe” link in any marketing email
    • Updating your communication preferences in your account settings
    • Contacting us directly at info@jilowhorizon.com

    Even if you opt out of marketing communications, we may still send you
    service-related messages (transaction confirmations, account notifications,
    security alerts, etc.).

    12.3 Marketing Partners
    With your consent, we may share your information with selected partners who
    may send you marketing communications. You can opt out of such sharing at any
    time.

    1. DO NOT TRACK SIGNALS

    Some web browsers have “Do Not Track” features that send a signal to websites you visit indicating you do not wish to be tracked. Our website does not currently respond to Do Not Track signals. We will update this Privacy Policy if we implement Do Not Track functionality in the future.

    You can still control tracking through cookie settings and opt-out mechanisms described in the Cookies section of this Privacy Policy.

    1. SOCIAL MEDIA INTERACTIONS

    When you interact with us through social media platforms (Facebook, LinkedIn, Twitter, Instagram, etc.), the social media platform may provide us with information about you based on your privacy settings on that platform.

    Information we may receive includes:

    • Profile information (name, profile picture, email)
    • Posts, comments, and interactions
    • Friends or connections list
    • Demographic information

    This information is governed by both this Privacy Policy and the privacy policy of the social media platform. We encourage you to review the privacy settings and policies of any social media platforms you use.

    1. AUTOMATED DECISION-MAKING AND PROFILING

    We may use automated systems to analyze your information and provide personalized services, such as:

    • Personalized content and product recommendations
    • Targeted marketing based on your interests
    • Risk assessment for business purposes
    • Fraud detection and prevention

    You have the right to:

    • Be informed about automated decision-making
    • Request human intervention in automated decisions
    • Challenge decisions made solely by automated means
    • Express your point of view regarding automated decisions

    To exercise these rights, contact us at privacy@jilowhorizon.com.

    1. VENTURE-SPECIFIC PRIVACY PRACTICES

    Certain JILOW ventures handle information requiring additional protection:

    16.1 JILOW Health Health information is treated with the highest level of confidentiality and security in accordance with applicable health privacy laws. Medical records and health data are:

    • Stored in secure, encrypted systems
    • Accessible only to authorized healthcare professionals
    • Processed in compliance with medical confidentiality standards
    • Subject to enhanced security measures

    16.2 JILOW Edu Educational records are protected in accordance with applicable educational privacy regulations. Student information is used solely for educational purposes and shared only with explicit consent or as required by law.

    16.3 JILOW Agro Agricultural project information and proprietary farming data are treated as confidential business information and protected accordingly.

    16.4 JILOW Tech Technical implementations and business systems data are protected with industry-standard security measures and confidentiality agreements.

    1. DATA BREACH NOTIFICATION

    In the event of a data breach that compromises your personal information, we will:

    • Assess the breach and its impact
    • Take immediate steps to contain and remedy the breach
    • Notify affected individuals within 72 hours (as required by NDPR)
    • Notify relevant authorities as required by law
    • Provide information about the breach and steps you can take to protect yourself

    We maintain an incident response plan to handle data breaches promptly and effectively.

    1. CALIFORNIA PRIVACY RIGHTS (CCPA)

    If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

    • Right to know what personal information is collected, used, shared, or sold
    • Right to delete personal information held by us
    • Right to opt-out of sale of personal information (we do not sell personal information)
    • Right to non-discrimination for exercising your CCPA rights

    To exercise these rights, contact us at privacy@jilowhorizon.com or call us at [your phone number].

    We will verify your identity before processing CCPA requests. We do not discriminate against individuals who exercise their CCPA rights.

    1. EUROPEAN UNION USERS (GDPR)

    If you are located in the European Union or European Economic Area, you have rights under the General Data Protection Regulation (GDPR) as described in Section 8 of this Privacy Policy.

    Our legal basis for processing your information under GDPR includes:

    • Your consent
    • Performance of a contract
    • Compliance with legal obligations
    • Legitimate interests

    You may lodge a complaint with your local supervisory authority if you believe we have violated GDPR.

    Data Controller: JILOW Horizon Ventures Limited Abuja, Nigeria Email: privacy@jilowhorizon.com

    1. NIGERIAN DATA PROTECTION COMPLIANCE

    We comply with the Nigeria Data Protection Regulation (NDPR) 2019 and all applicable Nigerian data protection laws.

    20.1 Data Protection Officer We have appointed a Data Protection Officer (DPO) responsible for overseeing our data protection practices.

    Contact our DPO: Email: privacy@jilowhorizon.com

    20.2 Nigeria Data Protection Bureau If you have concerns about how we handle your personal information, you may contact the Nigeria Data Protection Bureau (NDPB):

    Nigeria Data Protection Bureau Email: info@ndpb.gov.ng Website: ndpb.gov.ng

    20.3 Lawful Processing We process personal data only when we have a lawful basis as defined by NDPR and obtain appropriate consent where required.

    1. CHANGES TO THIS PRIVACY POLICY

    We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

    21.1 Notification of Changes We will notify you of material changes by:

    • Posting the updated policy on our website
    • Updating the “Last Updated” date at the top of this policy
    • Sending email notification (for significant changes)
    • Displaying a prominent notice on our website

    21.2 Review We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

    21.3 Continued Use Your continued use of our website or services after changes to this Privacy Policy constitutes acceptance of the updated policy.

    1. CONTACT US

    If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

    JILOW Horizon Ventures Limited

    General Privacy Inquiries: Email: privacy@jilowhorizon.com Alternative: info@jilowhorizon.com

    Mailing Address: JILOW Horizon Ventures Limited Abuja, Nigeria

    Phone: [Your contact number]

    Venture-Specific Privacy Contacts:

    Response Time: We will respond to all privacy-related inquiries within 30 days.

    1. CONSENT

    By using our website and services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

    If you do not agree with this Privacy Policy, please do not use our website or services.

    ACKNOWLEDGMENT

    Thank you for trusting JILOW Horizon Ventures Limited with your personal information. We are committed to protecting your privacy and handling your data responsibly.

    © 2024 JILOW Horizon Ventures Limited. All Rights Reserved.

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