Privacy Policy

1. Introduction

JulineMart Online (“JulineMart,” “we,” “our,” or “us”) is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, safeguard, and protect the information you provide when using our website at https://julinemart.com and our services.

Regulatory Compliance:
This policy complies with:

• Nigeria Data Protection Act (NDPA) 2023
• Nigeria Data Protection Regulation (NDPR) 2019
• Payment Card Industry Data Security Standard (PCI DSS)
• Paystack and payment processor requirements

By using JulineMart, you consent to the data practices described in this Privacy Policy.

2. Who We Are

Business Name: JulineMart Online
Nature of Business: Multi-vendor e-commerce marketplace
Email: info@julinemart.com
Physical Address: No. 9 Jesus Is Lord Street, Off Refinery Road, Effurun, Warri, Delta State, Nigeria
Role: Data Controller

JulineMart operates as an online marketplace connecting customers with independent vendors. We manage the platform, process payments through third-party processors, and coordinate logistics through courier partners.

3. Information We Collect

We collect information to provide, improve, and protect our services:

3.1 Personal Identification Information

• Full name (first and last name)
• Email address
• Phone number (mobile and alternative)
• Date of birth (for age verification)
• Gender (optional)

3.2 Address Information

• Delivery address (street, city, state, postal code)
• Billing address (if different from delivery address)
• Address type (home, office, etc.)

3.3 Account Information

• Username and password (encrypted)
• Account preferences and settings
• Communication preferences
• Saved payment methods (tokenized)

3.4 Transaction Information

• Order details (items, quantities, prices)
• Payment references and transaction IDs
• Order history and status
• Refund and return records
• Dispute information

3.5 Vendor-Specific Information (for sellers)

• Business name and registration details
• Business registration number (CAC if applicable)
• Tax identification number
• Bank account details (for payouts)
• Business address and contact information
• Identity verification documents

3.6 Technical Information

• IP address and device identifiers
• Browser type and version
• Operating system
• Device type (mobile, desktop, tablet)
• Pages visited and time spent
• Referring website
• Location data (with consent)

3.7 Communication Data

• Customer support messages and emails
• Chat history
• Phone call recordings (with notice)
• Feedback and survey responses

3.8 Marketing & Analytics

• Website usage patterns
• Click-through rates
• Conversion data
• A/B test participation
• Demographic information (aggregated)

4. How We Collect Information

4.1 Direct Collection
Information you actively provide when you:

• Create an account or register as a vendor
• Place an order or make a purchase
• Update your profile or preferences
• Contact customer support
• Subscribe to newsletters or marketing
• Participate in surveys or promotions
• Submit reviews or feedback

4.2 Automatic Collection
Information automatically gathered through:

• Cookies and tracking technologies
• Server logs
• Analytics tools (Google Analytics)
• Session data
• Device sensors (with permission)

4.3 Third-Party Sources
Information received from:

• Payment processors (Paystack)
• Logistics partners (delivery status)
• Social media platforms (if you connect accounts)
• Identity verification services
• Fraud prevention services

5. How We Use Your Information

5.1 Service Provision

• Create and manage user accounts
• Process orders and facilitate transactions
• Coordinate product delivery and fulfillment
• Provide customer support
• Send order confirmations and updates
• Enable vendor dashboard functionality

5.2 Payment Processing

• Facilitate secure payments through Paystack
• Process refunds and credits
• Calculate and distribute vendor payouts
• Maintain transaction records
• Comply with financial regulations

5.3 Platform Improvement

• Analyze usage patterns and trends
• Improve website functionality and user experience
• Develop new features and services
• Optimize search and recommendation algorithms
• Conduct research and testing

5.4 Communication

• Send transactional emails (order confirmations, shipping updates)
• Provide customer support responses
• Send service announcements and updates
• Deliver marketing communications (with consent)
• Conduct satisfaction surveys

5.5 Security & Fraud Prevention

• Verify user identity and prevent fraud
• Monitor for suspicious activity
• Protect against unauthorized access
• Investigate and resolve disputes
• Enforce our Terms of Service and policies

5.6 Legal Compliance

• Comply with legal obligations and regulations
• Respond to legal requests and court orders
• Protect our legal rights
• Maintain records as required by law
• Report suspicious activity to authorities when required

6. Legal Basis for Processing (NDPR Compliance)

We process your personal data based on:

6.1 Consent
You have given clear consent for specific purposes (marketing, location tracking, cookies)

6.2 Contract Performance
Processing is necessary to fulfill our contract with you (processing orders, delivery coordination)

6.3 Legal Obligation
We must comply with Nigerian law (tax records, anti-money laundering, consumer protection)

6.4 Legitimate Interests
Processing serves our legitimate business interests (fraud prevention, platform security, service improvement) while respecting your rights

7. Payment Processing & Financial Data

7.1 Third-Party Payment Processor
All payment transactions are processed by Paystack, a certified PCI DSS Level 1 payment service provider.

7.2 What We Do NOT Store

• Full credit/debit card numbers
• Card CVV/CVC codes
• Complete card expiration dates
• Bank account credentials

7.3 What We Store

• Payment transaction references
• Last 4 digits of cards (for identification)
• Payment status and history
• Paystack customer tokens (encrypted)

7.4 Payment Security

• All payment data transmitted via SSL/TLS encryption
• Paystack complies with PCI DSS standards
• We use tokenization for saved payment methods
• Regular security audits conducted

7.5 Vendor Payouts For vendors, we securely store:

• Bank account numbers (encrypted)
• Account names
• Bank names and codes
• Used only for legitimate payout processing

8. Cookies & Tracking Technologies

8.1 What Are Cookies?
Cookies are small text files stored on your device that help us provide and improve our services.

8.2 Types of Cookies We Use

Essential Cookies (Always Active)

• Enable core functionality (login, cart)
• Maintain security and prevent fraud
• Remember language and region preferences

Performance Cookies (Optional)

• Track website usage and performance
• Help us improve user experience
• Identify technical issues

Functional Cookies (Optional)

• Remember your preferences
• Personalize content
• Enable social media features

Marketing Cookies (Optional)

• Deliver relevant advertisements
• Measure campaign effectiveness
• Track conversion rates

8.3 Managing Cookies
You can control cookies through:

• Browser settings (disable or delete cookies)
• Our cookie consent tool on the website
• Opt-out links in marketing emails

Note: Disabling essential cookies may limit platform functionality.

8.4 Third-Party Cookies
We use trusted third-party services:

• Google Analytics (website analytics)
• Facebook Pixel (advertising)
• Paystack (payment processing)

Each has their own privacy policies governing cookie use.

9. Data Sharing & Disclosure

9.1 We Do NOT Sell Your Data
JulineMart does not sell, rent, or trade your personal information to third parties for marketing purposes.

9.2 When We Share Information

With Vendors (Limited Disclosure)

• Customer name, phone, and delivery address for order fulfillment only
• Order details and special instructions
• Vendors are contractually obligated to protect this data

With Logistics Partners

• Delivery name, phone, and address for shipment
• Order weight and dimensions
• Delivery instructions

With Payment Processors

• Transaction amount and reference
• Customer identifier (never full card details)
• For payment processing and fraud prevention

With Service Providers

• Email service providers (for transactional emails)
• SMS gateway (for delivery notifications)
• Cloud hosting services (AWS, Google Cloud)
• Analytics providers (Google Analytics)
• Customer support platforms

With Legal Authorities When required by law or legal process:

• Court orders or subpoenas
• Law enforcement investigations
• Regulatory compliance requirements
• Protection of legal rights
• Prevention of fraud or illegal activity

Business Transfers In the event of merger, acquisition, or asset sale:

• User data may be transferred
• You will be notified via email
• Same protections will apply

10. Data Security Measures

We implement comprehensive security measures to protect your information:

10.1 Technical Safeguards

• Encryption: SSL/TLS for data transmission, AES-256 for data storage
• Firewalls: Network-level protection against attacks
• Access Controls: Role-based access and multi-factor authentication
• Regular Updates: Security patches applied promptly
• Monitoring: 24/7 system monitoring for threats

10.2 Organizational Safeguards

• Staff Training: Regular security awareness training
• Background Checks: Screening of employees with data access
• Confidentiality Agreements: Legal obligations to protect data
• Incident Response: Procedures for data breach management
• Vendor Audits: Review of third-party security practices

10.3 Payment Security

• PCI DSS compliance through Paystack
• Tokenization of payment methods
• No storage of complete card details
• Regular security assessments

10.4 Limitations
While we implement strong security measures, no system is completely secure. You share information at your own risk and should:

• Use strong, unique passwords
• Enable two-factor authentication when available
• Keep login credentials confidential
• Report suspicious activity immediately

11. Data Retention

11.1 Retention Periods

Active Accounts:

• Retained as long as your account is active
• Includes all transaction and profile data

Closed Accounts:

• Basic account data: 90 days after closure
• Transaction records: 7 years (tax and legal requirements)
• Support communications: 3 years
• Marketing data: Until consent withdrawn

Vendor Accounts:

• Financial records: 7 years (tax compliance)
• Business details: Until vendor relationship ends + 3 years
• Payout history: 7 years

11.2 Deletion Criteria
Data is deleted or anonymized when:

• Retention period expires
• No longer needed for original purpose
• User requests deletion (where legally permitted)
• Legal obligations are satisfied

11.3 Backup Systems
Deleted data may persist in backups for up to 90 days before permanent deletion.

12. Your Rights Under Nigerian Law

Under the NDPR and NDPA, you have the following rights:

12.1 Right to Access
Request confirmation of what personal data we hold about you and receive a copy.

12.2 Right to Rectification
Request correction of inaccurate or incomplete information.

12.3 Right to Erasure
Request deletion of your personal data (subject to legal obligations).

12.4 Right to Restrict Processing
Request limitation on how we use your data.

12.5 Right to Data Portability
Receive your data in a structured, machine-readable format.

12.6 Right to Object
Object to processing based on legitimate interests or for marketing purposes.

12.7 Right to Withdraw Consent
Withdraw consent for marketing communications or optional data processing.

12.8 Right to Complain
File a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.

12.9 How to Exercise Your Rights
Email info@julinemart.com with:

• Your full name and email address
• Specific right you wish to exercise
• Supporting information (if applicable)
• Government-issued ID (for identity verification)

We will respond within 30 days of verification.

13. International Data Transfers

13.1 Data Processing Locations
Your data may be processed in:

• Nigeria (primary)
• Cloud service provider data centers (Google Cloud, AWS)

13.2 Safeguards for Transfers
When data is transferred outside Nigeria:

• We use service providers with NDPR-compliant data protection
• Standard contractual clauses are implemented
• Encryption protects data in transit and at rest
• We assess third-party security practices

13.3 Your Consent
By using JulineMart, you consent to these international transfers under the safeguards described above.

14. Children’s Privacy

14.1 Age Requirement
JulineMart is not intended for users under 18 years of age. We do not knowingly collect data from children.

14.2 Parental Discovery
If we discover we have collected data from a child under 18:

• We will delete the information promptly
• We will notify the parent/guardian if identifiable
• The account will be closed

14.3 Parental Notification
If you believe your child has provided information to us, contact info@julinemart.com immediately.

15. Marketing Communications

15.1 Types of Marketing

• Promotional emails about deals and new products
• SMS notifications about sales and offers
• Push notifications (PWA app)
• Personalized product recommendations

15.2 Consent
We will only send marketing with your explicit consent obtained during:

• Account registration (opt-in checkbox)
• Checkout process (optional subscription)
• Preference center updates

15.3 Opting Out
Unsubscribe anytime by:

• Clicking “unsubscribe” in emails
• Replying “STOP” to SMS messages
• Updating preferences in your account settings
• Contacting info@julinemart.com

Note: You cannot opt out of essential transactional emails (order confirmations, delivery updates).

16. Third-Party Links & Services

16.1 External Websites
Our platform may contain links to third-party websites (social media, payment processors, courier tracking). We are not responsible for their privacy practices.

16.2 Third-Party Integrations

• Paystack: Payment processing (see Paystack Privacy Policy)
• FEZ Delivery, GIG Logistics, RedStar Express: Delivery services
• Google Analytics: Website analytics

16.3 Recommendation
Review the privacy policies of any third-party service before providing information.

17. Updates to This Privacy Policy

17.1 Right to Modify
We may update this Privacy Policy to reflect:

• Changes in our practices
• New legal requirements
• Platform improvements
• User feedback

17.2 Notification of Changes
When we make material changes:

• Updated “Last Updated” date at the top
• Email notification to registered users
• Prominent notice on the website
• 30-day notice period for significant changes

17.3 Your Acceptance
Continued use after changes constitutes acceptance. If you disagree with changes, please close your account before they take effect.

18. Contact Us & Data Protection Officer

18.1 General Inquiries
Email: info@julinemart.com
Phone: +234 706 380 3732
Address: No. 9 Jesus Is Lord Street, Off Refinery Road, Effurun, Warri, Delta State, Nigeria

18.2 Data Protection Matters
For privacy-specific concerns, requests to exercise your rights, or data protection questions: Email: info@julinemart.com (Subject: “Data Protection Inquiry”)

18.3 Nigeria Data Protection Commission
If you believe your privacy rights have been violated:
Website: https://ndpc.gov.ng
Email: info@ndpc.gov.ng