THE INDOMITABLES FAN CLUB APP – PRIVACY POLICY & TERMS AND CONDITIONS

INTRODUCTION

The Indomitables Fan Club App (“IFC,” “App”) is an educational, entertainment, and engagement mobile application created and operated by Dufil Prima Foods Ltd (“Dufil,” “we,” “us,” or “our”). The App is designed to be used by individuals of all ages, including minors between the ages of 3 to 16 (“Children”, “Child”, “Minors”) and their parents, guardians, or teachers combinedly referred as (“you”, “your”, “Participants”). Any Personally Identifiable Information is referred as (“Personal Data”).

This document outlines the Terms and Conditions of use as well as our Privacy Policy in compliance with the Nigeria Data Protection Act 2023, Ghana Data Protection Act 2012, and other applicable laws. By downloading, accessing, or using this App, you accept and agree to be bound by these Terms and Conditions and consent to the practices described in our Privacy Policy.

1.       ELIGIBILITY AND CONSENT

 

Use of the App by Minors will require active involvement and informed consent of a parent, legal guardian, or authorized teacher. You represent and warrant that you have the legal authority to provide such consent on behalf of the Child. Each parent /guardian /authorized teacher can create only up to four profiles for their Children.

Employees of Dufil Prima Foods Ltd and their immediate family members may use the App but must comply with all stated terms.

By accepting this policy, you consent to our collection, use, and processing of your information and/or your Child’s information as needed for business purposes of the App.

 

2.       PURPOSE OF THIS PRIVACY POLICY

 

Dufil respects your privacy and is committed to protecting your and your Child’s Personal Data. This privacy policy contains information on how we look after your Personal Data and inform you of your privacy rights and how the law protects you.

 

This policy defines the data we collect from you (data regarding Children of whom you are a parent /legal guardian /teacher), why we collect your data, how we use your data, how you can control your data and how we manage, store, protect, share and retain your data. The policy also highlights the minimum-security controls put in place to protect your and your Child’s data. Parent /legal guardian or teacher who has registered with the App on behalf of the Child will always have access to the App and can control the Child’s use of the App and is responsible to provide Parental Guidance to the Child.

 

Dufil is committed to handle Personal Data in compliance with the Nigeria Data Protection Act 2023, Nigeria Data Protection Act - General Application and Implementation Directive (NDPA ACT-GAID) 2025, Ghana Data Protection Act 2012 and other applicable data protection laws.

 

1.          WHAT DATA DO WE COLLECT ABOUT YOU?

The data we collect from you is Personal Data. Personal Data, or personal information, means any information about an individual from which that person can be identified. In this case Personal Data contains details of you and your Child who are users of the App. The data by itself or in combination or other data can lead to identification of the person (personally identifiable information - PII).

The data we collect, use and store and how we use it is as follows:

• Child’s First Name:   Is used to identify the Child and display on leaderboard when needed. Any winner announcements or game points are linked to the Child’s first name. The leaderboard will be visible to all the other participants /users of the App.
• Child’s Gender and Age Range:   This data will be used to understand the demographics, preferences, and engage the Child through educational and entertainment material.
• Child’s Photo or Avatar:   This information forms part of the Child’s identity and will be used when displaying on the leaderboard, announcing winners. The leaderboard will be visible to all the other participants /users of the App.
• Child School Details:   School details are used to engage Children during IFC school events and understand demographics of IFC Children.
• Child Grade:   This will be used to identify content of interest to IFC Children based on their grade and age group. We will use this information to provide relevant educational and quiz content for your Child.
• Parent/Guardian/Teacher Name:   This data will be used to identify you so we can communicate with you using your preferences, products and services purchased and use your information for demographic purposes or reporting purposes.
• Parent Photo /Avatar: This information is used as a part of your user profile, part of your overall identity information.
• Relationship with Child: This is needed to establish that you are an authorized individual who can accept this policy on behalf of the Child and understand the Child’s data privacy and protection needs.

• Email Address and Phone Number: This is used to establish communications and understand how you would like to hear about us, our services, and products. Used for communication regarding sales campaigns, and marketing events. Email addresses are also used to verify without doubt that you are the user who is registering with the system and to authenticate your identity at the time of registration.
• Location details of the Parent: Location information is used to understand user demographics, inform you about events which are happening in your location and regarding any offers which apply to your location.

• Transaction Data: Transaction data is used to understand your and your Child’s activities, preferences, and develop customized promotional events to meet your preferences. Transaction data will also help us identify top scoring /participating Child to be displayed on the leaderboard.

By sharing this information, you have provided consent to:

1. The collection, use, processing, storage, and retention of your and your Child’s Personal Data by Dufil for the purpose of the App, for engaging your Child with educational and entertainment content and promotional purposes.
2. Receiving future marketing communications from Dufil, including promotional offers, Children-oriented events, and brand updates.
3. Display your Child’s first name and profile picture /avatar on the Leaderboard which is visible to all the users of the system.
4. Posting pictures of Child /Children on the IFC App, in case of physical events hosted by Dufil. E.g., award events, brand awareness events.

 

2.          HOW DO WE COLLECT THE DATA?

The above-mentioned personally identifiable information regarding you and your Child is collected through multiple touch points while you interact with the IFC App. Our key modes of collection include:

1. App registration and profile creation – When you register on the IFC App, use our services and become a user of IFC App, information will be collected to identify your Child and you as an authorized parent /guardian /teacher to consent to this policy and terms.
2. Marketing Events /Exchanges – During marketing events and interactions such as this brand awareness events, IFC get together events.
3. Forms, feedback tools, surveys – Online web surveys that enable us to gather feedback regarding your and your Child’s preferences.
4. Interaction with content and features within the App: Your transaction data, preferences and choices will be obtained to provide better customer experience.
5. Where lawful – from third parties and public sources.

 

3.          LEGAL BASIS FOR PROCESSING YOUR and YOUR CHILD’s DATA

We will only use your and your Child’s Personal Data as allowed by law. As a part of the IFC APP, we will use your Personal Data in the following circumstances applied under relevant laws:  

• Where you consent to our use of your and your Child’s Personal Data. Provided you are authorized parent /guardian /teacher to provide informed consent to this policy and terms.
• Where we need to comply with a legal obligation.
• Legitimate interest in improving user experience and promoting safe interaction.
• Where we provide you with services or share with you content of interest to you and your Child.
• Enhance our products, services, and your experience across our channels.
• Understand your and your Child’s needs as a user of the App and your interest in the material, content, products, and services.
• Onboard new products and services that may be of interest to you/ your Child.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to protect your vital interest and your Child’s online safety and protection.
• Where it is in the interest of AI based or similar third parties to process your data to provide you with information /outputs of your interest.

 

4.          DATA STORAGE & PROTECTION

Data is stored securely and has administrative safeguards. Only authorized personnel and service providers may access the application and data bases on which Personal Data is stored.

5.          STORAGE OF YOUR PERSONAL DATA 

Your and your Child’s Personal Data will be:

1. Retained for as long as necessary to fulfil the purpose for which it was collected.

• We will retain your Personal Data only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws. This means that we store your Personal Data for as long as it is required to deliver our IFC App based services and products to you and your Child, except where we have a lawful basis for saving it for an extended period. We also retain the Personal Data we need for the execution of contractual obligations, and/or as necessary for the establishment, exercise, or defense of legal claims and for audit and compliance purposes, for our legitimate business interests, and to prevent harm.
• If you choose to delete your account or data with us, we will retain the data /account for 90 days. Upon the completion of 90 days the user account will be permanently deleted. You can create a new account with us afterwards. By providing consent to this policy, you consent to a retention period of 3 months /90 days of the account after your request to delete.

 

2. Protection of your Personal Data and Security Measures

• To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of your and your Child’s data, Dufil uses a range of physical, technical, and administrative, and procedural security measures to safeguard your and your Child’s Personal Data. These measures are aimed at preventing unauthorized access, collection, use, disclosure, copying, modification, or disposal. Your data will be stored in Microsoft Azure services hosted in North Europe. We safeguard and protect your data in a manner that complies with applicable data protection regulation Nigeria.
• Please recognize that protecting your Personal Data is also your responsibility. We ask you to be responsible for safeguarding your data and review who you share it with. Dufil cannot safeguard your Personal Data disclosed to other sources of which Dufil has no knowledge or control.
• It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

 

3. Information we share with third parties:

• We do not sell data. We do not routinely transfer your Personal Data to third parties; we ensure that a similar degree of protection is afforded to it within Nigeria or within the country to which it is transferred. We may share your Personal Data when working with trusted service providers who assist in processing the videos, marketing efforts,  SMS /email verification, or customer communications. You hereby consent to such transfers where such adequate protection has been ensured for your data.

 

4. Access to the App and Parental Guidance

• Parent/legal guardian /authorized teacher will have unlimited access to the application and can choose to delete data /games /transactions as found suitable to ensure personal protection and safety of the Child.
• Parent /legal guardian /authorized teachers are responsible to ensure that adequate parental guidance is provided to the Child on the amount of time to be spent on the App and how to use the App for its intended purposes. The App may not have in-built controls for Parental guidance.

 

6.          YOUR PRIVACY RIGHTS

In addition to being able to control the data you directly provide to us, you may exercise any of the below rights with respect to your data:

1. Withdrawal of Consent

Users of IFC App may withdraw their consent and request the deletion of their Personal Data and/or their Child’s data at any time by contacting Dufil Customer Service. Upon verification, Dufil shall process the request in accordance with applicable data protection regulations.

 

2. Other Privacy Rights

It is your right to be able to

• Access and review your and your Child’s Personal Data
• Correct any inaccuracies or make updated /request changes to your or your Child’s Personal Data
• Request us to refrain from doing certain things with your and your Child’s Personal Data or restrict the extent of our collection or processing of your data.
• Request partial or complete erasure of your Personal Data.
• Object to our processing of your personal information where we are processing your personal information for direct marketing purposes.
• Request the transfer of your personal information to another party. If you wish to exercise any of the rights set out above, please contact us using the Dufil Customer Service.

 

 

3.       COOKIE POLICY

Cookies are small files placed on your computer’s hard drive or your mobile that enables the IFC App to identify your device as you view different pages. Cookies allow websites and applications to store your preferences to present contents, options or functions that are specific to you. Like most interactive Apps, our IFC App uses cookies to enable the tracking of your activity for the duration of a session. Our App uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer or mobile device. They will typically store information in the form of a session identification that does not personally identify the user.

By consenting to this policy, you consent that we might use cookies to understand your preferences, activities, and session management.

4.       TERMS AND CONDITIONS

 

1.       Appropriate Use

 

• You agree to use the App solely for its intended purposes. You must not misuse, exploit, or manipulate the App in any unauthorized manner including, but not limited to, uploading harmful, defamatory, or illegal content.

 

2.         User-Generated Content

 

• By submitting content including names, photos, or avatars through the App, you grant Dufil a royalty-free, non-exclusive, perpetual, and worldwide license to use, reproduce, and distribute the content for marketing, education, promotional or research purposes, provided such use complies with privacy rights.

 

3.         Updates and Termination

 

• Dufil reserves the right to update, modify, suspend, or terminate the App or its features at any time. Notifications of material changes will be sent via the App or other reasonable communication channels.

 

4.          Limitation of Liability

 

• We do not warrant uninterrupted access or error-free performance. Dufil is not responsible for indirect, incidental, or consequential damages from the use or inability to use the App.

 

5.         Indemnification

 

• You agree to indemnify and hold harmless Dufil from any claims, liabilities, damages, or expenses arising out of your misuse of the App or breach of these terms.

 

6.         Governing Law

 

• These Terms shall be governed by the laws of the Federal Republic of Nigeria. Disputes shall first be addressed amicably, and unresolved issues may be submitted to the Lagos Multi-Door Courthouse for mediation.

 

To exercise your rights, please contact Dufil’s Customer Support.

Contact Details
Dufil Prima Foods Limited
44 Jimoh Odutola Street, Off Eric Moore Road, Surulere, Lagos
Email: contactus@dufil.com
Phone: 234(0)8004636643‬ & (0)7004636643.

By reading and/or accepting this privacy policy, you confirm that you have read, understood, and agreed to the policy terms & conditions.