The The VertMall Limited Privacy Policy
Most recent amendment: March 2026
Index
1. Scope
2. Summary of information
3. Your personal data rights
4. Data controller of your personal data
5. Useful information if you are a USER
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5.1 What are the data processing purposes and the legitimate basis of the
processing?
5.2 What kind of data do we hold about you and how is your personal data collected
5.3 What are the recipients of your data and why are we communicating it
5.4 How long will we keep your data?
Annex I- General retention periods and retention periods applicable for Users
6. Useful information if you are a COURIER:
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6.1 What are the data processing purposes and the legitimate basis of the
processing?
6.2 What kind of data do we hold about you and how is your personal data collected
6.3 What are the recipients of your data and why are we communicating it?
6.4 How long will we keep your data?
Annex I- General retention periods and retention periods applicable for Couriers
7. Useful information if you are a PARTNER:
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7.1 What are the data processing purposes and the legitimate basis of the
processing
7.2 What kind of data do we hold about you and how is your personal data collected
7.3 How long will we keep your data?
Annex I- General retention periods and retention periods applicable to 8. Useful information if you are an INVESTOR:
Partners●
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8.1 What are the data processing purposes and the legitimate basis of the
processing
8.2 What kind of data do we hold about you, and how is your personal data collected
8.3 How long will we keep your data?
Annex I- General retention periods
9. Useful information if you are a JOB APPLICANT:
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9.1 What are the data processing purposes and the legitimate basis of the
processing
9.2 What kind of data do we hold about you, and how is your personal data collected
9.3 How long will we keep your data?
Annex I- General retention periods
10. Useful information if you are a PROSPECT:
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10.1 What are the data processing purposes and the legitimate basis of the
processing
10.2 What kind of data do we hold about you, and how is your personal data
collected
10.3 How long will we keep your data?
Annex I- General retention periods
11. Useful information if you are a WEBSITE VISITOR:
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11.1 What are the data processing purposes and the legitimate basis of the
processing?
11.2 What kind of data do we hold about you, and how is your personal data
collected
11.3 How long will we keep your data?
Annex I- General retention periods
12. Do we proceed to the international transfer of data?
13. Do we proceed to automated decision-making?
14. Do we create profiles and/or segment users based on the collected data?
15. What security measures have been adopted?
16. Ethics Channel17. The VertMall Limited initiatives
18. Artificial Intelligence
Annex II - Details of The VertMall Limited company
Annex III - Definitions
1. Scope
Our commitment
The VertMall Limited is committed to respecting Users’/ Couriers’/ Job Applicants’/
Partners’/ Investors’/ Prospects’/ Website Visitors’ (jointly named hereinafter as the “Data
Subjects”) privacy and protecting their Personal data. In this sense, this Privacy Policy aims
to inform Data Subjects about The VertMall Limited’s processing activities as per GDPR and
the Local Regulation requirements.
The purpose of the Privacy Policy
This Privacy Policy provides information on the processing of personal data of Data Subjects
who contact us via the contact form available on our website, in accordance with the Nigeria
Data Protection Regulation ("NDPR").
To find them, the different stakeholders involved in this processing, as well as our Data
Subjects, can enter our main website thevertmall.com>>Contact us>>Policies, or App:
Help>>Not related to an order>>Policies and there they can select the right which they wish
to exercise.
This Privacy Policy notice describes: how The VertMall Limited collects and processes the
personal data, the different stakeholders involved in this processing, as well as our Data
Subjects' rights concerning their data.
We recommend that all stakeholders involved in the processing, as well as Data Subjects,
read it carefully and on a frequent basis to fully understand this, along with our privacy
overview, which highlights key points about our current privacy practices.
Possible changes and updates to the Privacy Policy
Due to the constant evolution of The VertMall Limited’s activities, this Privacy Policy may be
subject to change or updates in the future.
Use of our Platform after this Privacy Policy has been updated shall be deemed to constitute
consent by Data Subjects, whether located in Nigeria or outside Nigeria, to the updated or
modified Privacy Policy to the extent permitted by local law.
The VertMall Limited will notify the Data Subjects in advance in case of substantial changes
and modifications to the Privacy Policy by e-mail or through any other means that ensure itsreceipt.
The VertMall Limited will in no event modify its policies or practices to make them less
effective in the protection of its Data Subjects personal data.
Any doubts? Contact our DPO
If our Data Subjects have any doubt concerning this Privacy Policy or want to obtain more
information on it, they can contact our DPO at any time to this email address:
dpo@thevertmall.com.
2. Summary of information
Data Controller
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The The VertMall Limited
Your rights You can exercise your rights related to personal data at
any time HERE or by sending us an email to:
gdpr@thevertmall.com.Your rights related to personal
data: right of access, right to rectification, right to
erasure, right to object to processing, right to object to
profiling, right to unsubscribe to any marketing
communication
Data Protection Officer dpo@thevertmall.comFor which purpose do we use
your data?
When you are a User or Courier, we may use your data
for:
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legal purposes (e.g. in case of fraud and crimes
committed on our App; to comply with legal
regulations; manage your requests, to fill and/or
defend any claims and legal actions),
contractual purposes (e.g. grant the possibility
to create your own account, locate the nearest
Partner and Courier, perform payment
processing, assist in decisions and use of the
service, provide you with customer service,
study the use of the platform performed by you,
provide you with the equipment and material
needed to provide the services),
security purposes (e.g. use device, location,
profile, usage, and other data to prevent and
detect malicious or unsafe activities, monitor all
actions that could cause fraud, when requested
by any authority, administration or court,
collaborate with Public Authorities),
statistics and research purposes (e.g. analyse
trends, purchase behaviour and characteristics,
understand how you use our Platform, send
voluntary and anonymous questionnaires,
surveys, competitions and communications of
your interest, carry out financial calculations),
marketing and non-marketing purposes (e.g.
carry out marketing, communications, research
and development activities, analyse how to
improve our services, provide you with offers,
promotions, discounts, suggestions, carry out
promotional activities for the delivery of
samples or free products, generate and provide
you with receipts, inform you about any incident
on the App).
When you are a Partner, we may use your data for:
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grant you the possibility to create your own
account and maintain the business relationship
with The VertMall Limited,●
provide you with customer service to answer
your questions or provide consultations.
When you are an Investor we may use your data for:
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fulfil the compliance requirements
formalise the relationship with you as an
Investor,
notify you concerning the corporate matters and
inform you about The VertMall Limited’s results.
When you are a Job Applicant, we may use your data
for:
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consider your present or future suitability for
any of the positions available at The VertMall
Limited, to conduct any interviews it may deem
necessary for the position, test your knowledge,
contact companies for which you have
previously worked, check references, and
assess your skills and abilities in general.
Provide you with information of your interest
regarding our Job offers.
When you are a Prospect, we may use your data for:
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process your requests to obtain the products
and/or services offered by The VertMall Limited
and manage the prospective relationship,
carry out marketing, communications, and
research activities regarding The VertMall
Limited’s products and/or services similar to
those included in your request.
When you are a Web Visitors we may use your data for:
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Follow up on your comments left on The The
VertMall Limited Website or our Blog,
and provide you with the answer regarding your
request.Why can we do it? Lawfulness
of processing
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Compliance with the business/ labour
relationship.
Legitimate interest and User/ Courier /
Applicant/ Investor/ Website visitor consent.
With whom we share your data? If you are a User, we may share your data with two
different groups of recipients:
The recipients of data while we carry on your orders:
the Courier who carries out the task of collecting and
delivering the product; the establishment or venue in
charge of selling the product; the Customer Care
Services available to you; the payment Platform and
payment service providers; Telecommunications
service providers; Providers rendering satisfaction
survey services.
Recipients of the data, during the actions undertaken to
continue to provide the services offered through the
App: service providers that send parcels, carry out
orders and/or resolve incidents with delivery;
pharmacists dispensing products; Payment Platforms
contracted by The VertMall Limited; Service providers
for fraud control purposes and for for the
anonymisation of some data; Telecommunications
services; Punctually another entity or affiliate of the The
VertMall Limited Group; Social media, Third parties
associated with The VertMall Limited for commercial
communications; insurance companies
If you are a Courier, we may share your data with
different groups of recipients:
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advisers and consultants for the pursuit of
accounting, labour, tax, insurance, legal and
technical activities,
government bodies (tax authority, social security
system, etc.),
state security forces, courts, mediation and
arbitration bodies, governments for regulatory
matters
users who have placed an order which you have
agreed to carry out,●
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external service providers that provide
commercial offers with benefits and/or
discounts for you,
to group companies or third parties in charge of
the filing and management of computer data.
In case of every Data Subject (Users, Couriers, Job
Applicants, Partners, Investors, Prospects, Website
Visitors) we may share personal data with:
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another entity or affiliate of the The VertMall
Limited Group,
any public authority that requests the sharing.
3. What are your personal data rights?
Privacy is your right, and you have the choice.
You may exercise your rights free of charge at any time using the form available on our main
website thevertmall.com>>Contact us>>Policies, or in the App, entering: Help>>Not related
to an order>>Policies.
To exercise your rights, click HERE. If you have any questions, you can write to us at
gdpr@thevertmall.com.
You may exercise the following rights vis-à-vis The VertMall Limited:
1. 2. 3. 4. 5. 6. The right of access to your personal data to know which data is being processed and
the processing operations carried out thereon;
The right to correct any inaccuracies in relation to your personal data;
The right to the erasure of your personal data, where possible, by sending us a data
erasure request
The right to request the restriction of processing of your personal data when the
accuracy, legality or need for processing of the data is in question, in which case we
may retain the data for the purpose of filing or defending claims.
The right to request portability of your data to another service provider. We will give
you a copy of your data so that you can provide it to another service provider. If you
request us to do so and it is technically possible, we will transfer the data directly to
that other service provider on your behalf.
The right to object to the processing of your data to resolve any query you may have
raised with us through the contact form (website: thevertmall.com>>Contact
us>>Policies or in the App: Help>>Not related to an order>>Policies) and the right to
object to the processing of your data on social media and/or for the purpose of
processing your CV.7. If you are the User, and you don’t want to receive any marketing communications, you
have the right to unsubscribe to any marketing communication, by sending an e-mail
or by using the link provided for this purpose in every commercial communication.
Please note that disabling Push notifications will also prevent you from receiving
notifications about the status of any order.
You can anytime object to profiling by sending an email to: gdpr@thevertmall.com
If you believe that The VertMall Limited is
in breach of data protection law:
Please take into account that there may be some situations where the above rights could not
be exercised or effectively executed by The The VertMall Limited, for example when asking
us to erase all your personal data where there is contractual relationship with us.
Notifications and Modifications
Due to the constant evolution of The The VertMall Limited’s activities, this Privacy Policy, the
Cookie Policy and the Terms of Use are also subject to change.
The VertMall Limited will send all Users/ Couriers / Job Applicants/ Partners/ Investors/
Prospects/ Website Visitors notifications about substantial changes and modifications to
such documents by email or through any other method that ensures their receipt.
In any case, The VertMall Limited will in no event modify its policies or practices to make
them less effective in the protection of our customers’ previously stored personal data.
4. Who is a Data Controller of your data?
The Data Controller of your Personal Data in relation with the use of the The VertMall Limited
Platform and of the other Forms is The The VertMall Limited.
In addition to the information provided above, details of each The VertMall Limited Group
company can be found in Annex 1 to this Privacy Policy.
Furthermore, The VertMall Limited may share the data of those users (“Users”) or couriers
(“Couriers”) who register on the website or App (the “Platform”) and of those persons who
contact The VertMall Limited using the forms available on its Platform with each of the
subsidiaries and companies of the The VertMall Limited Group for the purpose of offering
the services requested by Users through the Platform.
5. Useful information if you are a USER:
5.1 What are the data processing purposes and the legitimate basis of the processing?The VertMall Limited will process your personal data for the following purposes:
1. For legal purposes.
2. For contractual purposes.
3. For security purposes.
4. For statistics and research purposes.
5. For marketing and commercial purposes.
6. For non-marketing purposes.
Legal purposes
The VertMall Limited processes your personal data for:
i) detect and investigate fraud and possible crimes committed against our Platform and all
the users,
ii) comply with the legislation in case any legal regulations oblige us to keep your data for a
defined period of time (please check Annex II on data retention),
iii) manage and execute your request(s) to exercise the rights established in the NDPR and
other local regulations,
iv) file, submit and defend legal actions against any entity of our Group,
v) in any of the cases above-mentioned, The VertMall Limited shall be entitled to use any
data obtained from you or arisen from your activity through our Platform (e.g. conversations
between you and the Partner, you and the Courier, you and our Platform using the chat
system) for filing and/or defending any claims and/or legal actions that may be necessary,
and to manage any incidents arising in connection with User’s orders.
Contractual purposes
The VertMall Limited processes your personal data for:
i) grant you the possibility to create your own account,
ii) provide you with the services you have requested and any additional features on the
Platform,
iii) locate the nearest Partners and Courier to the delivery point informed by you (which may
involve using geolocation services, if you agreed to them when asked to by the Platform, as
described above),
iv) perform payment processing and collection on behalf of you,
v) communicate your Order to the Partner selected by you and update you on the status of
your Order,vii) assist you in your decisions and use of the service, including the possibility to quickly
reorder from the stores, where you have ordered in the past or suggest stores based on your
past orders or “popularity” among new users. Additionally, we could assist you in your
decisions through automatically determined filters by the historical order you have placed in
the past, providing, in each case, specific content in the Platform tailored for you.
viii) send you the receipt corresponding to your Orders,
ix) provide you with a customer service to manage any incident related to your Orders, and
be able to answer your questions or consultations,
x) allow your direct contact with the Courier in charge of your Order,
xi) be contacted by our Partners in case of any incident with your Orders,
xii) process reimbursements and refunds both via promo-codes or bank refunds,
xiii) notify you concerning changes or updates to our services, terms and conditions, privacy
policy, cookies policy and any other corporate document that may substantially affect you.
Security purposes
The VertMall Limited processes your personal data for:
i) use device, location (including geolocation data, if you agreed to), profile, usage, and other
data to prevent and detect malicious or unsafe activities (e.g. payment fraud, identity fraud,
account hacking, phishing, incentive abuses). In particular, The VertMall Limited uses your
device's IP address to detect fraudulent activity on your device and to keep the platform
away from attackers who may try to access your account by impersonating you.
ii) monitor all actions that could cause fraud or the commission of a criminal offence related
to the payment method employed by you; if any irregularities are detected, The VertMall
Limited reserves the right to retain the data provided and share it with the competent
Authorities to carry out the relevant investigation.
iii) make sure that you follow the legal requirements related to specific products you may
order through the Platform (e.g. legal age for alcoholic beverages).
For statistics and research purposes
The VertMall Limited processes your statistics based on your Personal data for:
i) analyse trends, purchase behaviour and characteristics,
ii) understand how you use our Platform,iii) manage and improve the services offered, including the possibility of adding new or
different features and services to improve the quality of the services.
Marketing and commercial purposes
The VertMall Limited processes your personal data for:
i) carry out marketing, communications, research and development activities,
ii) analyse and research how to improve our services both offline and on the Platform, by
using the data provided by you (such as in focus groups, reviews, valuations of the services,
satisfaction survey, feedback or any kind, etc.),
iii) provide you with personalised offers, promotions, discounts, suggestions, views and
options in App, by email or by any other communication means, including the use of cookies
or other technologies for advertising in third party websites or apps, according to our Cookie
Policy and only if you have agreed to,
iv) carry out promotional activities for the delivery of samples or free products inside the
order placed by you, which may be of your interest to promote The The VertMall Limited’s
and our Partner’s products or services,
v) carry out promotional activities such as contests, raffles, tenders, quizzes, competitions
between users when they have subscribed and/or sent their data for such campaigns,
vi) create custom audiences with Facebook or other providers to reach out to you or other
people with similar characteristics, who might be interested in using The The VertMall
Limited services; you can manage your privacy in your Facebook or other third party platform
settings,
vii) use as commercial or marketing material published by you on your social networks
profiles when The The VertMall Limited has been expressly mentioned by you (i.e. via
hashtag or @).
The The VertMall Limited might show you ads based on your interests. If you prefer not to
see these ads, you can always opt out by emailing us at gdpr@thevertmall.com or through
managing your privacy in our settings: enter your The The VertMall Limited account
>>Manage privacy>>personalised ads
We may personalize the marketing communications by using the User activity in our App
(including your past orders) and the interaction with the App, online advertising, previous
emails, promotions, etc. However, this personalisation is not made only by automated
means, nor have any legal effect or affect the User similarly.
The The VertMall Limited may use Push services on the User’s mobile device to provide
marketing communications. If the User does not want to receive these marketing
communications, he / she shall unsubscribe in the notifications centre. Please note thatdisabling Push notifications will also prevent the User from receiving notifications about the
status of any order.
Non-marketing purposes
The The VertMall Limited processes your personal data for:
i) generate and provide you with receipts from each of your Orders placed through our App,
ii) inform you about any incident on the Platform or the operation of the services, including
incidents related to your orders. This information can be sent by e-mail or SMS messages,
and any other messaging application that may be used by you and The The VertMall Limited
at any moment,
ii) inform you about any changes to our Terms and Conditions, privacy policy, cookies policy,
services, and more generally to inform you about any relevant non-marketing
communications.
iii) process incidents and claims with insurance companies in the event you report the
occurrence of any damages or unforeseen events that may be covered by The The VertMall
Limited’s insurance policy.
5.2 What kind of data do we hold about you, and how is your personal data collected?
The The VertMall Limited holds the following data about you:
1. Information supplied directly by you:
1.1. Registration Data: the information provided by you when you create an account on the
The The VertMall Limited Platform: username and e-mail.
1.2. User Profile Information: the information added by you on the Platform to be able to use
The The VertMall Limited's service, e.g.. your mobile phone number and delivery address.
You can view and edit the personal data on your profile whenever you wish.
1.3. Payment information: payment information when processing your orders; card data will
be processed by our electronic payment service providers, who will receive the data directly
from you. The The VertMall Limited will have access to this information only for complying
with the request of any competent authority.
The The VertMall Limited offers its users the ability to store payment information or card
details. In this case, the card details are tokenised (converted into a unique code). This token
is usable in the The The VertMall Limited platform, allowing The The VertMall Limited to
facilitate the use of the platform by preventing the introduction of the card details each time
you want to perform a payment and provide additional security, as the details of the card are
never stored in our systems. You can erase this token at any moment in your profile area.1.4. Additional information: any information that you could supply to The The VertMall
Limited for other purposes, e.g. your photograph or the billing address in the case if you have
asked to receive invoices from The The VertMall Limited.
1.5. Information about previous communications with The The VertMall Limited: information
supplied by you for the resolution of any queries or complaints about the use of the platform,
whether through the contact form (website: thevertmall.com>>Contact us>>Policies, App:
Help>>Not related to an order>>Policies), by e-mail or by phone through the customer
service.
1.6. Information regarding any accidents: information of any of the parties involved in the
provision of services through the Platform for the purpose of making insurance claims or
carrying out any other actions with the insurance companies contracted by The The VertMall
Limited.
1.7. Information of conversations held with The The VertMall Limited: Transcription and
recording of conversations for the processing of incidents, queries or other consultations
that may be made to guarantee and improve the quality of our services and for security
reasons.
1.8. Information on Communications: communications exchanged between you and the
Couriers on the chat system provided on the Platform whenever it is necessary to address
any incident or discussion between Users and Couriers, or to comply with any request made
by authorities. The The VertMall Limited will never access the communications if it is not
strictly necessary and will always ensure the privacy of its users and the confidentiality of all
information exchanged on its platform.
1.9. Any additional information that you provide in your requests, comments or questions.
2. Information indirectly supplied by Users:
2.1. Data arising from the Use of the Platform: The The VertMall Limited collects the data
arising from your Use of the Platform every time you interact with the Platform.
2.2. Data on the application and the device: The The VertMall Limited stores data on the
device and the Application used by you to access the services:
i) the IP address used by you to connect to the Internet using your computer or mobile
phone, and to prevent fraudulent misappropriation or unauthorised access to your account
by third parties
ii) information about your computer or mobile phone, such as your Internet connection,
browser type, version and operating system, and type of device,
iii) the full uniform resource locator (URL) Clickstream (the information related to your
navigation through our website or the Application, links followed, etc.), including date and
time,iv) data from your account: information on the orders made by you, as well as feedback
and/or comments made by you,
v) your browsing history and preferences.
2.3. Data arising from the User’s origin: if you arrive at the The The VertMall Limited Platform
through an external source (such as a link from another website or a social network, as long
as you have authorised it on those websites), The The VertMall Limited collects data on the
source from which you arrived.
2.4. Data resulting from the management of incidents: if you contact the The The VertMall
Limited Platform through the Contact Form( website: thevertmall.com>>Contact
us>>Policies or App: Help>>Not related to an order>>Policies), The The VertMall Limited
Chat or on The The VertMall Limited’s phone number, The The VertMall Limited will collect
the messages received in the format used by you and may use and store them to manage
current or future incidents.
2.5. Data arising from “cookies”: The The VertMall Limited uses its own and third-party
cookies to facilitate browsing by its users and for statistical purposes, among others (please
refer to the Cookie Policy for more details).
2.6. Geolocation Data: provided that you have authorised this, The The VertMall Limited will
collect data relating to your location, including the real-time geographic location of your
computer or mobile device.
2.7. Data resulting from external third parties
i) The The VertMall Limited collects personal data or information from external third
parties only if you authorise such third parties to share that information with The The
VertMall Limited. For example, if you create an account through your Facebook or Google
account, these platforms could disclose to us your personal data that can be found on your
Facebook/Google profile (such as name, gender or age).
ii) If you choose to send messages to us from social media networks (including Twitter,
Facebook and Whatsapp), we will collect that information you provide to us for the purposes
set out in this privacy policy, including responding to your inquiry, providing you with
customer support and resolving issues.
2.8. At The VertMall Limited your privacy is our top priority. We want to remind you that The
VertMall Limited will never ask for an ID Card or related documents to verify your identity.
Instead, we use secure and less intrusive methods to ensure your privacy. If you ever receive
a request for personal documentation, such as an ID Card or any other related document,
please do not share it. In those cases, reach out to us immediately for verification and
assistance. You can contact us through a form or by emailing us at gdpr@thevertmall.com5.3. What are the recipients of your data and why are we communicating it?
The VertMall Limited warrants that all commercial partners, technicians, suppliers or
independent third parties are bound by contractually binding promises to process the
information shared with them in accordance with The VertMall Limited’s indications, this
Privacy Policy and the applicable data protection legislation.
We will not disclose your personal data to any third party who does not act under our
instructions, and no communication will involve selling, renting, sharing or in any other way
revealing customers’ personal information for commercial purposes in breach of the
commitments made in this Privacy Policy.
When carrying out an order, data may be shared with:
1. 2. 3. 4. 5. 6. The Courier who carries out the task of collecting and delivering the product.
The establishment or venue in charge of selling the product, if you have requested
the purchase of a product. If you contact the above-mentioned providers directly and
give them your data directly, VertMall Limited will not be responsible for the
providers’ use of such data.
The Customer Care Services contracted by The VertMall Limited for the purpose of
warning you of any possible incidents or asking why negative feedback has been
given; data will be used to manage any incidents that may occur during the provision
of the services.
The payment Platform and payment service providers so that the amount can be
charged to your account.
Telecommunications service providers, when they are used to send communications
regarding orders or incidents relating to orders.
Providers rendering satisfaction survey services on behalf of The VertMall Limited.
Sharing your data with third parties:
To continue providing the services offered through the Platform, The VertMall Limited may
share your certain personal data with:
1. 2. Service providers: service providers that send parcels, carry out orders and/or resolve
incidents with deliveries have access to your personal information as may be
necessary only to carry out their functions. They must process the said personal
information as provided in this Privacy Policy and in the applicable data protection
legislation.
Payment Service Providers: When you enter your card number on the App, this is
stored directly by the Payment Platforms contracted by The VertMall Limited, which
allows payment to be charged to your account. Payment service providers have been
chosen based on their security measures and, in any event, comply with the security
measures stipulated in the payment service legislation, and they are PCI Compliant3. 4. 5. 6. 7. 8. 9. under the Payment Card Industry Data Security Standard or PCI DSS. The VertMall
Limited does not store such data in any event.
Service providers for fraud control purposes: The VertMall Limited will share your
data with fraud control service providers to assess the risk of the transactions
carried out.
Service providers for the anonymisation of some data: To prevent the misuse of your
data by third-party service providers, your data may be anonymised so that it can be
used solely for the provision of the service. For example, The VertMall Limited may
assign your telephone numbers to third parties to anonymise them and provide them
in this format to the providers used to carry out the services contracted by you.
Security companies and Law Enforcement Forces and Agencies: The The VertMall
Limited may disclose personal data on its customers’ accounts if such disclosure is
necessary to comply with the law, to enforce or apply the “Terms of Use'' or to protect
The The VertMall Limited, its users’ or third parties’ rights, property or safety. It
includes the exchange of information with other companies (for example, The
VertMall Limited uses Google's reCAPTCHA Enterprise service to protect users from
cyber attacks or threats to their accounts) and organisations and with Law
Enforcement Forces and Agencies to protect against fraud and reduce credit risk.
Call centre and incident management services: In order to provide customer service
and call centres, actions to measure your degree of satisfaction and the provision of
administrative support services, your data may be disclosed to companies located
outside the European Economic Area.
Telecommunications services: In order to be able to provide you with telephone
contact services, The VertMall Limited may contact telecommunications companies
that provide secure lines and systems for the purpose of contacting you.
Companies in The VertMall Limited group: To be able to provide its services, The
VertMall Limited may transfer certain personal data to subsidiaries, based on the
geographical area from which users request our services and to Delivery Hero GmbH.
When you register on the Platform from any country in which The VertMall Limited
operates, your data is stored on The VertMall Limited’s database, which is located in
Ireland and belongs to the Spanish company The VertMall Limited 23, S.A. In the
case of subsidiaries located outside the European Economic Area, the data will be
transferred, using the systems established by the European Commission and the
GDPR, to countries with an appropriate personal data protection level or through
contracts approved by the European Commission establishing and guaranteeing the
rights of data subjects.
Delivery Hero group companies: We are part of an international group of companies
with legal entities in many parts of the world, including our group’s headquarters
located with Delivery Hero SE in Berlin, Germany. In order to utilise our resources
efficiently and ensure that our business processes function properly, we utilise our
group-wide shared technological support services that sometimes necessitate
sharing personal data with our parent company, Delivery Hero SE. Delivery Hero
group companies are bound by strict intra-group data transfer agreements, ensuring
compliance with data protection requirements whenever sharing personal data with
group companies.10. Social media connected by Users: If you connect your The VertMall Limited account
to other social media or to a third-party platform, The VertMall Limited may use the
information provided to such social media or third-party platform in compliance with
the privacy policy of the social media or third-party platform in question.
11. Third parties associated with The VertMall Limited for commercial communications:
The VertMall Limited may transfer your personal data to third parties associated with
The VertMall Limited, provided that you have given your express informed and
unequivocal consent to such transfer of data and that you are aware of the purpose
and recipient of such transfer.
12. Changes of ownership: If The VertMall Limited’s ownership changes or the majority
of its assets are acquired by a third party, you are informed that The VertMall Limited
will transfer your data to the acquiring organisations to continue to provide the
services, subject to the processing of data. As The VertMall Limited keeps growing
continuously, we may buy or sell business units, assets, shares or legal entities, so
data subjects’ information may also be transferred. That information, when acquired
by The VertMall Limited, shall be processed as any other information as described in
our privacy policy. You acknowledge that such transfer may occur and that we will be
allowed to use your personal information for any of the purposes described in this
Privacy Policy. The new file controller will inform Users of its identification data. The
The VertMall Limited states that it will comply with its duty of information, and it shall
inform Users of the change of file controller if and when this happens. This
processing shall be carried out under the contract entered into with The VertMall
Limited.
13. Insurance companies: The VertMall Limited may provide your data to those insurers
and insurance brokers it collaborates with, for the management and processing of
claims and losses arising from the activity carried out by The VertMall Limited and
the parties that collaborate with it.
Your data will not be disclosed to any third parties unless:
i) This is necessary to provide the services requested if The VertMall Limited is collaborating
with third parties.
ii) if The VertMall Limited has your express and unambiguous authorisation;
iii) where this has been requested by a competent authority pursuant to its functions (in
order to investigate, prevent or take action in relation to illegal actions);
iv) finally, where required by law.
Sharing your data with The VertMall Limited Partners
The VertMall Limited may also share your data with some of The VertMall Limited’s top
Partners and only under certain conditions:i) having obtained your expressed consent via the consent checkbox, which may appear (a)
at the first order made by you or (b) in each order made by you previously, to proceed with
the check-out when placing an order through the Partner store.
Once giving your consent, you will be able to withdraw it at any time, using the Contact Form
( website: thevertmall.com>>Contact us>>Policies or App: Help>>Not related to an
order>>Policies).
ii) having signed a Data Sharing Agreement with the Partner and ensuring that all legal,
safety and technical measures are met.
5.4 How long will we keep your data?
The VertMall Limited shall retain your data for the duration of the contractual relationship
and, after this has come to an end, for the period established by law for filing or defending
the appropriate legal actions. This is established at a maximum of fifteen (15) years to
comply with The VertMall Limited’s legal obligations, which include the duty to assist the
security forces as necessary in the investigation and prosecution of crimes pursuant to the
higher interest of public safety, and defend itself or take any action in relation to criminal, tax
and social security matters.
The said period may be shorter depending on the legal provision applicable to each purpose
of data processing, as established in the table of retention periods outlined in Annex II.
ANNEX I - GENERAL RETENTION PERIODS
GENERAL
TER
M
DESCRIPTION LEGAL REF.
PERSONAL CIVIL
ACTIONS
Personal actions of any kind
without a specific limitation
period established from the
moment when the obligation
becomes enforceable, taking
into account that, in the case
of ongoing positive or negative
obligations, the period will
start running again every time
they are infringed.
Statutes of Limitation of
the various states in
Nigeria and the Limitation
Act applicable in the
Federal Capital Territory
(FCT).ACCOUNTING AND
TAX
DOCUMENTATION
6
year
s
6
year
s
For commercial purposes:
books, correspondence,
documentation and supporting
documents relating to their
business, duly ordered, from
the last entry in the books,
save as may be established by
general or special provisions.
This commercial obligation
applies to both compulsory
books (income, expenses,
investment goods and
provisions), and the
documentation and
documentary evidence of the
entries contained in the books
(invoices issued and received,
vouchers, amendment
invoices, bank documents,
etc.).
For tax purposes: accounting
books and other compulsory
record books pursuant to the
applicable tax legislation
(personal income tax, VAT,
corporation tax, etc.), as well
as documentary evidence
justifying the entries in the
books (including software and
computer files and any other
documentary evidence that is
relevant for tax purposes)
must be retained at least for
the period during which the tax
authorities are entitled to verify
and investigate and, therefore,
assess and inform of, the tax
owed.
USERS
Sections 374 and 375 of
the Companies and Allied
Matters Act 2020
Section 63 Companies
Income Tax Act;
Section 55 Personal
Income Tax Act.USERS AND
CONSUMERS
6
year
s
Claims to enforce performance
of the service as a result of
non-conformity with the
contract are subject to a
limitation period of six years
after the delivery of the product
Statutes of Limitation of the
various states in Nigeria and
the Limitation Act applicable in
the Federal Capital Territory
(FCT).
6. Useful information if you are a COURIER:
The VertMall Limited will process the personal data of Couriers for the following purposes:
1. For legal purposes.
2. For contractual purposes
3. For security purposes.
4. For statistics and research purposes.
Legal purposes
The VertMall Limited processes your personal data for:
i) detect and investigate fraud and possible crimes committed against our Platform and all
the users,
ii) comply with the legislation in case any legal regulations oblige us to keep your data for a
defined period of time (please check Annex II on data retention),
iii) manage and execute your request(s) to exercise the rights established in the NDPR and
other local regulations,
iv) file, submit and defend legal actions against any entity of our Group,
v) manage and execute your claims related to an Order, problems with the delivery and
different sorts of general incidents generated by the use of the Platform.
Contractual purposes
The VertMall Limited processes your personal data for:
i) manage The VertMall Limited’s activity, enabling you to access and communicate with the
The VertMall Limited platform to provide its services through it,
ii) provide informative sessions to you before the start of services (focus groups) and to
comply with the services offered by the providers through the technological platform, and
with obligations arising from the contractual relationship,iii) studying the use of the platform performed by you and the performance of focus groups
with you to understand their opinion and feedback about the services provided.
iv) provide you with the equipment and material needed to provide the services, if requested,
v) activate the insurance in case of an incident involving you during the delivery of an Order,
vi) assign Orders to you and show to the Customers your position while delivering their
Orders,
vii) assist you during the performance of services by contacting customer centres,
viii) notify you concerning changes or updates to our services, terms and conditions, privacy
policy, cookies policy and any other corporate document that may affect them in a
substantial way
Security purposes
The VertMall Limited processes your personal data for:
i) control visitors’ access to the Courier centre’s facilities and ensure your goods’ and
facilities’ safety,
ii) use device, location, profile, usage, and other data to prevent and detect improper
payments, money laundering, especially when you pay by cash,
iii) when requested by any authority, administration or court, collaborate with Public
Authorities whenever they request The VertMall Limited information useful to the aim of
their investigation (e.g. anti-drug projects, anti-fraud projects, anti-terrorism projects),
iv) defend The VertMall Limited's interests in case of a conflict between the parties related to
the interpretation or execution of the contract,
v) comply with the compensation, accounting, tax and economic obligations.
For statistics and research purposes
The VertMall Limited processes your statistics based on your personal data for:
i) carry out statistical and financial calculations based on aggregate and non-identifiable
data,
ii) send voluntary and anonymous questionnaires, as well as surveys, competitions and
communications of your interest, for the purpose of assessing the quality of the relationship
and any opinions that you may have.
6.2 What kind of data do we hold about you, and how is your personal data collected?The VertMall Limited holds the following data about you:
1. 2. Name and surnames: pursuit of the contractual relationship.
Identity Card (DNI) / Passport No.Foreign resident’s card: pursuit of the contractual
relationship – billing and legal compliance.
3. 4. Social Security number: payment management and legal compliance.
Bank and billing information: information for billing purposes, current account or
credit card numbers, if necessary to fulfil contractual obligations or manage
purchases or services.
5. 6. Photo: road safety, account fraud prevention and public safety.
Image: video surveillance and access control when entering one of the company’s
sites.
7. Voice (without biometrics) from Customer service calls: pursuit of the contractual
relationship and legal compliance.
8. Signature: pursuit of the contractual relationship.
9. Date of birth: legal compliance.
10. Residence details (resident/non-resident): legal compliance.
11. Accident insurance processing details: accident insurance management.
12. Driving licence: road safety.
13. Own vehicle: pursuit of the contractual relationship.
14. Vehicle insurance: pursuit of the contractual relationship.
15. Geolocation: management of the service provider’s location during the provision of
services for road safety reasons and in order to comply with tax and accounting
obligations.
16. Phone number and Email (Contact data): Pursuit of the contractual relationship and
be able to communicate with the Courier by sending some communications through
different channels such as SMS, email, WhatsApp messages, etc.
17. Internet connection: pursuit of the contractual relationship.
18. Conversation information: Transcription and recording of conversations held
between Couriers and The VertMall Limited to guarantee and improve the quality of
our services, processing of incidents and for security reasons.
6.3 What are the recipients of your data, and why are we communicating it?
Your data may be disclosed to third parties only where necessary for the establishment,
performance and termination of the contractual relationship with The VertMall Limited. We
never disclose your data to unauthorised third parties. All data recipients must meet the
legal data protection requirements and prove their data protection level with appropriate
proof.
The third-party recipients of the Data include:
i) establishments with which The VertMall Limited has a commercial contract,
ii) users who have placed an order whose delivery will be provided by you
iii) external service providers that provide commercial offers with benefits and/or discounts
for you.iv)advisers and consultants for the pursuit of accounting, labour, tax, insurance, legal and
technical activities,
v) government bodies for regulatory matters (tax authority, social security system, etc.),
vi) state security forces, courts, mediation and arbitration bodies,
During the performance of the relationship and to ensure that you can carry out your activity,
the Data will be disclosed:
i) to those establishments with which The VertMall Limited has a commercial T&Cs,
ii) those users who have placed an order which you have agreed to carry out,
iii) external service providers that provide commercial offers with benefits and/or discounts
for you.
The VertMall Limited hereby informs you that the Data may be disclosed to companies in the
VertMall Limited group in connection with the purposes described previously.
The Data may also be transferred outside Nigeria to group companies or third parties in
charge of the filing and management of computer data solely for purposes related to the
management of the contractual relationship between the Parties and fully in accordance
with the applicable data protection legislation. The The VertMall Limited hereby reports that
it has taken the necessary measures to ensure that the disclosure of your data is carried out
in accordance with the above-mentioned legislation.
Companies in the The The VertMall Limited group: To be able to provide its services, The
VertMall Limited may transfer certain personal data to subsidiaries, based on the
geographical area from which users request our services and to Delivery Hero GmbH. When
you register on the Platform from any country in which The VertMall Limited operates, your
data is stored on The VertMall Limited’s database, which is located in Ireland and belongs to
the Spanish company The VertMall Limited 23, S.A. In the case of subsidiaries located
outside the European Economic Area, the data will be transferred, using the systems
established by the European Commission and the GDPR, to countries with an appropriate
personal data protection level or through contracts approved by the European Commission
establishing and guaranteeing the rights of data subjects.
6.4 How long will we keep your data?
The VertMall Limited shall retain your data for the duration of the contractual relationship
and, after this has come to an end, for the period established by law for filing or defending
the appropriate legal actions. This is established at a maximum of fifteen (15) years in order
to comply with The VertMall Limited’s legal obligations – which include the duty to assist the
security forces as necessary in the investigation and prosecution of crimes pursuant to the
higher interest of public safety – and defend itself or take any action in relation to criminal,
tax and social security matters.
The said period may be shorter depending on the legal provision applicable to each purpose
of data processing, as established in the table of retention periods set forth in Annex II.ANNEX I - GENERAL RETENTION PERIODS
GENERAL
TER
M
DESCRIPTION LEGAL REF.
PERSONAL CIVIL
ACTIONS
Personal actions of any kind
without a specific limitation
period established from the
moment when the obligation
becomes enforceable, taking
into account that, in the case
of ongoing positive or negative
obligations, the period will
start running again every time
they are infringed.
Statutes of Limitation of
the various states in
Nigeria and the Limitation
Act applicable in the
Federal Capital Territory
(FCT).
ACCOUNTING AND
TAX
DOCUMENTATION
6
year
s
For commercial purposes:
books, correspondence,
documentation and supporting
documents relating to their
business, duly ordered, from
the last entry in the books,
save as may be established by
general or special provisions.
This commercial obligation
applies to both compulsory
books (income, expenses,
investment goods and
provisions), and the
documentation and
documentary evidence of the
entries contained in the books
(invoices issued and received,
vouchers, amendment
invoices, bank documents,
etc.).
Sections 374 and 375 of
the Companies and Allied
Matters Act 20206
year
s
For tax purposes: accounting
books and other compulsory
record books pursuant to the
applicable tax legislation
(personal income tax, VAT,
corporation tax, etc.), as well
as documentary evidence
justifying the entries in the
books (including software and
computer files and any other
documentary evidence that is
relevant for tax purposes)
must be retained at least for
the period during which the tax
authorities are entitled to verify
and investigate and, therefore,
assess and inform of, the tax
owed.
Section 63 Companies
Income Tax Act
Section 55 Personal
Income Tax Act.
COURIERS
COMMERCIAL
AGREEMENTS OR.
CONTRACTS
6
year
s
The agreements signed
between the Courier and The
VertMall Limited in case of
commercial relationships.
Statute of Limitation of the
various states in Nigeria and
the Limitation Act applicable
in the Federal Capital
Territory (FCT)
COMMERCIAL
AGREEMENTS OR.
CONTRACTS
6
year
s
The agreements signed
between the Courier and The
VertMall Limited in case of
commercial relationships.
Statute of Limitation of the
various states in Nigeria and
Limitation Act applicable in
the Federal Capital Territory
(FCT)
USERS AND
CONSUMERS
6
year
s
Claims to enforce
performance of the service
as a result of non-conformity
with the contract are subject
to a limitation period of three
years after the delivery of the
product
Statute of Limitation of the
various states in Nigeria and
Limitation Act applicable in
the Federal Capital Territory
(FCT)
7. Useful information if you are a PARTNER:
7.1 What are the data processing purposes and the legitimate basis of the processing?
The VertMall Limited will process your personal data in order to:i) grant you the possibility to create your own account and maintain the business
relationship with The VertMall Limited in order to provide technology intermediation in the
generation of leads and processing of payments and other services relating to in-store sales
and the delivery of products, also to handle incidents arising in relation to orders,
ii) provide you with customer service to answer your questions or consultations.
7.2 What kind of data do we hold about you, and how is your personal data collected?
The VertMall Limited holds the following data about you:
1. Information supplied directly by you:
1.1. Registration Data: the information provided by you when you create an account on The
VertMall Limited Platform: username and e-mail.
1.2. User Profile Information: phone number and email; pursuit of the business relationship,
and be able to communicate with the Partner or the Investor by sending some
communications through different channels, such as SMS and email.
1.3. Information of conversations held with The VertMall Limited. Transcription and
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