Privacy Policy
This page and its sub-pages tell you everything you need to know about how Esorae Home and/or its subsidiaries (“Esorae”; “we”) protect the personal data we process and control relating to you (“your personal data”; “your data”) and which rights you have in relation to the processing of your personal data.
Any Esorae entity located outside Lagos will for the purposes of compliance with data privacy laws be represented by Esorae Home.
Below, we give a general description of how Esorae protects your personal data and include specific information on how we use personal data and cookies.
- How does Esorae Home protect your personal data?
- How do we use personal data when you visit Esorae Home’s website?
- How do we use cookies (and other tracking technologies)?
- How do we use personal data when you visit our offices?
- How do we use personal data for marketing purposes?
1. How does Esorae Home protect your personal data?
Esorae Home attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with Esorae Home, your personal data are in good hands.
Esorae Home protects your personal data in accordance with applicable laws and our data privacy policies. In addition, Esorae Home maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.
The following sections provide further details as to how Esorae Home processes your personal data:
a) Which categories of personal data do we collect and how do we process such personal data?
We collect personal data of our customers, potential customers, corporate clients, retail clients, and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.
Except for certain information that is required by law or by Esorae Home policies (including client relationship with Esorae Home), your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.
If you provide us with personal data of another person (for instance, a potential customer/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with Esorae Home.
The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to receive an invoice or special request to a query or buy a product on our website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.
b) For which purposes and on which legal basis do we use your personal data?
Esorae Home uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which Esorae Home uses your personal data and (ii) an overview of the legal basis for each such purpose.
Purpose
Managing our contractual and/or transactional relationship with you.
Legal basis
Necessary for the performance of the execution of your orders.
Purpose
Facilitating communication with you (including in case of emergencies, and to provide you with requested information).
Legal basis
Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Purpose
Complying with legal requirements.
Legal basis
Necessary for the compliance with a legal obligation to which we are subject.
Purpose
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).
Legal basis
Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Purpose
Improving the security and functioning of our website, networks and information.
Legal basis
Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Purpose
Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within Esorae Home and/or to provide a better user experience. (more details on how we run analytics on our website can be found in our cookies policy).
Legal basis
Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Purpose
Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below).
Legal basis
Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Purpose
Social listening (Identifying and assessing what is being said about Esorae Home and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)
Legal basis
Justified on the basis of our legitimate interest of protecting our assets and our brand on social media
Purpose
Operating and managing our business operations.
Legal basis
Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Where the above listing states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity.
We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.
To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis.
We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
c) Will we share your personal data with third parties?
We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and Esorae Home’s internal policies.
For example, we may disclose personal information to third parties for other business purposes as follows:
- We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
- To protect and defend the legal rights, safety, and security of Esorae Home, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
- For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.
We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
d) What about sensitive data?
We do not generally seek to collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.
The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
e) What about data security?
We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.
f) Where will your personal data be processed?
As an organization with offices and operations throughout Nigeria, personal data we collect may be transferred or be accessible throughout Esorae Home’s nationwide business.
Any such transfers throughout Esorae Home’s business take place in accordance with the applicable data privacy laws.
g) What are the sources we get your personal information from?
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), Esorae Home employees, contractors, (prospective) members of board of directors, shareholders, Esorae Home’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, suppliers and vendors (including third party data providers).
In section 5, you can find more information on the sources of your personal information for marketing purposes.
h) How long will your personal data be retained by us?
We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
- We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
- We will only keep the data while your account is active or for as long as needed to provide services to you.
- We retain your data for as long as needed in order to comply with our global legal and contractual obligations.
i) Which rights do you have with respect to the processing of your personal data?
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
- Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
- Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
- Object to the processing of your personal data: this right entitles you to request that Esorae Home no longer processes your personal data.
- Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
- Request the restriction of the processing of your personal data: this right entitles you to request that Esorae Home only processes your personal data in limited circumstances, including with your consent.
- Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Esoare Home, or request Esorae Home to transmit such personal data to another data controller.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Esorae Home’s Data Privacy Officer. Please note that this will not affect Esorae Home’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
2. How do we use personal data when you visit Esorae Home’s website?
In addition to the information set out above, the following sections describe how we use personal data when you visit Esorae Home’s website:
a) Which personal data do we gather?
Esorae Home collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter, purchase a product or register to make an enquiry on our website); and (2) indirectly (for example, through our website’s technology).
We may collect and process the following personal data:
- Personal data that you provide by filling in forms on our website. This includes registering to make a purchase on the website, subscribing to services, newsletters and alerts, registering to request a quote or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.
- If you contact us, we may keep a record of that correspondence.
- We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Any postings, comments or other content that you upload or post to a Esorae Home website.
- Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
- Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information.
b) Do we include (links to) websites and programs of third parties?
Our websites may include:
- Links to and from the sites of our partner networks, advertisers and affiliates.
- Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.
- Point of Purchase on our website or our instore locations. Where this is the case, note that such information is to enable us process your transaction and ensure a smooth and timely delivery.
We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.
c) How do we use personal data that we collect from our websites?
We use personal data for the purposes described in the section “For which purposes and on which legal basis do we use your personal data?” above, as well as to provide you with information you request, product information on benefits, costs and delivery, and for other purposes which we would describe to you at the point where it is collected. For example:
- Links to and from the sites of our partner networks, advertisers and affiliates.
- Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.
- Point of Purchase on our website or our instore locations. Where this is the case, note that such information is to enable us process your transaction and ensure a smooth and timely delivery.
We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.
3. How do we use cookies (and other tracking technologies)?
In addition to the information set out above, this section describes how we use cookies and other tracking technologies.
We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.
Please see our Cookies policy for more details including for information about your choices with respect to advertising and social media cookies and for access to our cookie consent manager.
4. How do we use personal data when you visit our offices or stores?
In addition to the information set out above, this section describes how we use personal data when you visit Esorae Home offices or stores.
Please contact us to receive further details on how we process your personal data when visiting our offices or stores (this sub-page also relates to the potential processing of your personal data through CCTV and access management systems in case such CCTV and access management systems are active.)
If you have any questions on data privacy or you want to let us know about website/marketing permissions, please contact us.
5. How do we use personal data for marketing purposes?
In addition to the information set out above, the following sections describe how we use personal data for marketing purposes:
a) What are the sources of marketing data?
The bulk of the personal data we collect and use for marketing purposes relates to individual customers or corporate clients with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual or company.
b) Do we send targeted e-mails?
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Esorae Home, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from Esorae Home may include additional data privacy information, as required by applicable laws.
c) Do we maintain Customer Relationship Management (CRM) databases?
Like most companies, Esorae Home uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Esorae Home professionals based on their personal interactions with you. If you wish to be excluded from our CRM databases, please contact us.
d) Do we combine and analyze personal data?
We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites such as our products and corporate sections and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn). We combine this data to better assess your experience with Esorae Home and to perform the other activities described throughout our privacy policy.
e) Do we share personal data with third parties?
In addition to the third parties mentioned in the section “Will we share your personal data with third parties?” above, we may share your personal data with marketing automation platforms we use in sending out the newsletters to you.
f) What are your rights regarding marketing communications?
You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by contacting us. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.
