Privacy Policy
Effective date: [EFFECTIVE DATE] · Last updated: [LAST UPDATED DATE]
At Harin Cosmetics, your privacy matters. This policy explains what personal information we collect, how we use it, and the choices you have — written with the Nigeria Data Protection Act 2023 and NDPC guidance in mind.
Introduction
Harin Cosmetics is committed to handling personal information responsibly and transparently.
This Privacy Policy explains how we collect, use, store, disclose, and protect personal information in connection with our website and the services we offer. It applies to visitors, customers, account holders, and anyone else who interacts with Harin Cosmetics through our website, checkout process, customer accounts, contact forms, marketing communications, or other digital interactions.
Please read this Privacy Policy carefully before using our website or services. If you do not agree with any part of this policy, you should not use our website.
This policy has been prepared with the Nigeria Data Protection Act (NDPA) 2023 and applicable guidance from the Nigeria Data Protection Commission (NDPC) in mind. It describes our stated practices and is not, by itself, a guarantee of legal compliance.
Who We Are
Harin Cosmetics operates an online cosmetics and beauty e-commerce platform serving customers in Nigeria.
Brand name: Harin Cosmetics
Legal business name: [LEGAL BUSINESS NAME]
Registered / business address: [BUSINESS ADDRESS]
Privacy contact: hello@harincosmetics.com
General customer service contact: hello@harincosmetics.com
Website: [WEBSITE URL]
For the purposes of applicable data-protection law, Harin Cosmetics acts as the data controller in respect of personal information collected through our website and services, subject to confirmation of the registered legal entity above.
Information We Collect
We may collect the following categories of information, depending on how you interact with us.
A. Identity information — such as your full name, username, or account details, and any customer identification information reasonably required to serve you. We do not collect date of birth or government identification numbers unless this becomes necessary and is clearly disclosed at the point of collection.
B. Contact information — such as your email address, telephone number, WhatsApp number where you contact us that way, billing address, and shipping/delivery address.
C. Transaction information — such as products purchased, product preferences, order number, order history, transaction date, order value, discounts applied, refund information, and delivery status.
D. Payment information — payment details you submit at checkout are processed by our third-party payment processor, [PAYMENT PROVIDER]. Harin Cosmetics does not store full card numbers, CVVs, PINs, or banking credentials on our own systems unless explicitly stated otherwise. Please refer to [PAYMENT PROVIDER]'s own privacy policy for details of how it handles your payment data.
E. Technical information — where actually collected by our website, this may include IP address, browser type, device type, operating system, device identifiers, pages visited, referring URLs, approximate location derived from IP address, session information, and error or security logs.
F. Communications — information you provide when you contact customer support, submit a contact form, send us an email, message us on social media, leave a product review, submit feedback, or take part in a survey.
G. Marketing preferences — where applicable, your email or SMS marketing preferences, promotional preferences, communication history, and records of consent or opt-out.
We do not collect sensitive personal data such as biometric information or government ID numbers as part of our standard operations.
How We Collect Information
We may collect information:
- Directly from you, when you create an account, place an order, or contact us
- During checkout, when you provide delivery and payment details
- Through contact forms, email, WhatsApp, or social media messages
- Through cookies and similar technologies, where used on our website
- Through analytics tools, where implemented (see **Analytics and Advertising** below)
- Through marketing systems, where you have opted in to receive communications
- Through third-party service providers who support our operations (e.g. [PAYMENT PROVIDER], [DELIVERY PROVIDER])
- Through fraud-prevention and security systems, where implemented
We only rely on collection methods that are actually implemented on our website — this policy is not a statement that every method listed here is currently in use.
How We Use Personal Information
We use personal information for the following purposes:
Order processing — processing purchases, confirming orders, managing your cart, processing refunds, and providing order updates.
Delivery — delivering purchased products, sharing necessary details with delivery partners such as [DELIVERY PROVIDER], and tracking shipments.
Customer support — responding to enquiries, resolving complaints, and providing assistance.
Account management — creating and maintaining your account, authentication, password recovery, and managing your preferences, where accounts are offered.
Security — preventing fraud, detecting suspicious activity, protecting our website, preventing unauthorized access, and investigating security incidents.
Website improvement — understanding how visitors interact with our website, diagnosing technical problems, improving user experience, and testing functionality.
Marketing — where you have opted in and it is legally permitted, sending promotional emails or messages, personalizing marketing content, and measuring marketing performance.
Legal and regulatory compliance — complying with applicable Nigerian laws (including NAFDAC requirements where relevant), responding to lawful requests, protecting our legal rights, resolving disputes, and maintaining appropriate business records.
We do not use your personal data for automated decision-making or profiling that produces legal effects concerning you.
Legal Bases for Processing
We only process personal information where an appropriate legal basis exists. The applicable basis depends on the specific processing activity and may include:
- **Performance of a contract** — for example, processing your order and arranging delivery
- **Compliance with a legal obligation** — for example, maintaining tax and accounting records
- **Consent** — for example, sending you marketing communications you have opted in to receive
- **Legitimate interests**, where applicable and permitted by law — for example, maintaining the security of our website
- **Protection of vital interests**, where applicable
- Other lawful bases recognized under the Nigeria Data Protection Act 2023
Where we rely on your consent, that consent is freely given, and we aim to make clear what you are consenting to. Where applicable, you may withdraw your consent at any time; withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Payment Information
Payments made on our website may be processed by a third-party payment provider, currently referenced here as [PAYMENT PROVIDER].
Our payment provider collects and processes the payment details you submit at checkout in accordance with its own privacy policy and security standards. Harin Cosmetics does not store your full card number, CVV, PIN, or banking credentials on our own systems unless this is explicitly confirmed elsewhere in this policy.
We encourage you to review [PAYMENT PROVIDER]'s privacy policy and terms of service for further detail on how your payment information is handled.
Delivery and Logistics
To fulfil your order, we may share the information reasonably necessary for delivery with our courier partner(s), currently referenced here as [DELIVERY PROVIDER].
This may include:
- Your name
- Delivery address
- Phone number
- Order number
- Delivery instructions
- Other order details relevant to fulfilling your delivery
We only share the information that is reasonably necessary to complete delivery of your order.
Marketing Communications
Where you have opted in, we may send promotional communications by email and/or other channels actually used by Harin Cosmetics (for example WhatsApp), which may include product updates, offers, and skincare tips.
You can unsubscribe from marketing emails at any time using the unsubscribe link included in those emails, or by contacting us at hello@harincosmetics.com. Withdrawing marketing consent does not affect transactional messages, such as order confirmations and delivery updates, which we may still need to send you to fulfil your order.
Signing up for marketing communications is not a condition of making a purchase.
Analytics and Advertising
As of the last update to this policy, Harin Cosmetics has not confirmed the use of any third-party analytics or advertising tools. If and when such tools (for example, an analytics or advertising platform) are implemented, this section will be updated to name the specific provider(s), described as [ANALYTICS PROVIDER] / [ADVERTISING PROVIDER] in the interim.
Where analytics or advertising cookies are used, you can manage your preferences through the cookie controls on our website (where offered) or through your browser settings.
International Data Transfers
Some of our service providers may process personal information outside Nigeria. We do not confirm that international transfers occur unless our actual service architecture requires it.
Where personal information is transferred outside Nigeria, Harin Cosmetics will take the steps required by applicable data-protection law to safeguard that information. Details of destination countries, relevant service providers, transfer mechanisms, and safeguards will be added here once confirmed.
Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including completing transactions, customer service, legal and tax obligations, fraud prevention, dispute resolution, security, and other legitimate business purposes.
Specific retention periods vary by data category and have not yet been finalized for every category. Until confirmed, the following are placeholders to be replaced with actual retention periods or criteria:
- Customer accounts: [RETENTION PERIOD / RETENTION CRITERIA]
- Orders: [RETENTION PERIOD / RETENTION CRITERIA]
- Payment records: [RETENTION PERIOD / RETENTION CRITERIA]
- Customer support records: [RETENTION PERIOD / RETENTION CRITERIA]
- Marketing information: retained until you unsubscribe or request deletion
- Analytics information: [RETENTION PERIOD / RETENTION CRITERIA]
- Security logs: [RETENTION PERIOD / RETENTION CRITERIA]
You may request deletion of your personal data at any time by contacting us at hello@harincosmetics.com, subject to any retention we are legally required to maintain.
Data Security
We take reasonable technical and organizational measures to protect personal information, which may include HTTPS encryption across our website, restricted internal access to customer data on a need-to-know basis, and reliance on our payment provider's own security controls for transactions.
We only describe security measures that are actually implemented — this section will be updated as additional safeguards (such as specific access controls, monitoring, or backup practices) are confirmed.
No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your information. In the event of a data breach affecting your rights, we will take appropriate steps as described in Data Breaches and Security Incidents below.
Your Privacy Rights
Depending on the circumstances and applicable law, including the Nigeria Data Protection Act 2023, you may have the following rights in relation to your personal information:
- **Right to be informed** about how your personal data is collected and used
- **Right of access** — to request a copy of the personal data we hold about you
- **Right to correction / rectification** — to ask us to update inaccurate or incomplete information
- **Right to deletion / erasure**, where applicable, subject to any legal obligations we must comply with
- **Right to object** to certain processing, including direct marketing, at any time
- **Right to restrict** certain processing, where applicable
- **Right to data portability**, where applicable
- **Right to withdraw consent**, where consent is the legal basis for processing
- **Rights relating to automated decision-making or profiling**, where applicable
- **Right to lodge a complaint** with the relevant regulator (see **Complaints and Regulatory Rights** below)
Not every right applies in every situation — the rights that apply to you depend on the specific processing activity and the applicable legal basis.
How to Exercise Your Rights
To exercise any of the rights described above, please contact us at hello@harincosmetics.com or via WhatsApp on 07082693152.
We may need to verify your identity before actioning your request, to prevent unauthorized disclosure of your personal information. We will respond within the time required by applicable law; we do not promise a specific response time beyond what is legally required.
Children's Privacy
Our website and services are not directed at children, and we do not knowingly collect personal information from children where this is prohibited by applicable law.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us at hello@harincosmetics.com. If we discover that we have collected a child's personal information improperly, we will take appropriate steps to delete that information.
Third-Party Websites and Services
Our website may contain links to third-party websites or services, such as payment providers, social media platforms (e.g. WhatsApp, Instagram), or delivery-tracking portals. Once you leave our website, this Privacy Policy no longer applies.
We do not control the privacy practices of third-party sites or services and encourage you to review their privacy policies before providing them with your information.
Data Breaches and Security Incidents
Harin Cosmetics maintains procedures for identifying, assessing, responding to, and managing personal-data security incidents.
Where a data breach affects your rights, we will notify affected users and, where legally required, the relevant regulator, within the timeframes required by applicable law. We do not commit to a specific notification deadline beyond what the law requires.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business practices, technology, legal requirements, or third-party services. When we do, we will update the "Last updated" date at the top of this page.
For material changes, we will consider appropriate ways to notify users, such as a notice on our website. Continued use of our website after any changes constitutes your acceptance of the updated policy. We encourage you to review this page periodically.
Contact Us
If you have any questions about this Privacy Policy or how we handle your data, please reach out:
Harin Cosmetics
Legal business name: [LEGAL BUSINESS NAME]
Address: [BUSINESS ADDRESS]
Privacy email: hello@harincosmetics.com
Customer service email: hello@harincosmetics.com
Phone: 07082693152
WhatsApp: wa.me/2347082693152
Website: [WEBSITE URL]
Complaints and Regulatory Rights
If you believe we have not handled your personal information appropriately, we encourage you to contact us first at hello@harincosmetics.com so we can try to resolve your concern directly.
You may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), Nigeria's data-protection regulator. Official contact and complaint-submission details should be confirmed directly at https://ndpc.gov.ng before being published on this page, to ensure accuracy.
Effective Date
This Privacy Policy is effective as of [EFFECTIVE DATE].
Last updated: [LAST UPDATED DATE]
Questions about your data?
hello@harincosmetics.com