TABLE OF CONTENTS

• 1. WHAT INFORMATION DO WE COLLECT?
• 2. HOW DO WE PROCESS YOUR INFORMATION?
• 3. LEGAL BASIS
• 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
• 5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
• 6. HOW LONG DO WE KEEP YOUR INFORMATION?
• 7. HOW DO WE KEEP YOUR INFORMATION SAFE?
• 8. DO WE COLLECT INFORMATION FROM MINORS?
• 9. WHAT ARE YOUR PRIVACY RIGHTS?
• 10. CONTROLS FOR DO-NOT-TRACK FEATURES
• 11. PRIVACY POLICY UPDATES
• 12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
• 13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In the course of providing and improving our products and services, we collect personal information that you voluntarily provide to us when you register on the Haird App. When you create an account, book an appointment, confirm an appointment, contact us directly, participate in activities available through the Haird platform, express an interest in obtaining information about us or our Services, or otherwise use the Haird Service, the personal information that we collect depends on the context of your interactions with us and the Services provided by Haird, the choices you make, and the features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles of professional service providers/technicians
• Identification/verification data such as technicians’ photos, certifications, and identity documents.​
• usernames
• passwords
• contact preferences
• contact or authentication data
• billing addresses
• debit/credit card numbers

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law(s), we process the following categories of sensitive information for the purpose of tailoring personal services needs, upholding integrity and user safety:

• health data such as medical history, allergies, etc.
• Offences data such as data about criminal convictions and offences, where permitted under local laws and regulations.

Account and Profile.

In order to create and manage your Haird account, we may collect your mobile phone number or email address as the login credentials for your account. We may provide you with the option to register, sign up or log in via external third-party services, such as Google or using your existing social media account details like your Facebook, X, or other social media account. If you choose to register in this way, you agree we may collect certain profile information about you from the social media provider, and your profile photo, username, and email address associated with the relevant third-party service provider. We also collect account settings and preferences.

Bookings

In order for users and professional service providers to complete transactions and fulfil booking requests, we collect data related to user bookings on the Service (e.g., transaction history) and user residential address (e.g., city, postal code, street number).

Payment Data

We may collect payment information required to process your payment in order to complete the transaction for booking a personal service such as your payment card or instrument number, and the security code associated with your payment card or instrument or other third-party payment information required for payment. All payment data is handled and stored by third-party applications and you are expected to understand and agree with their privacy notice link(s).

Customer support activity

When you communicate with our customer service team through customer support functions, social media, or any other means, we will collect your communication history with an ongoing effort to improve customer services support.

Information when you contact us

When you contact us, we collect the information you send us, such as reports, feedback, or inquiries about your use of the Services or information about possible violations of our Terms and Conditions or other policies.

User-generated content

We collect communication and correspondence records such as when users and professional service providers engage with our in-app chat ("Send a Message" option), or speak directly with one another, the date and time of the communication, and its content. We also collect in-app audio user-to-technician recordings generated while booking a personal service. Further, when users provide personal service reviews and ratings on the App, we collect this information, including any accompanying images, videos, or text, as well as associated metadata.

Promotion and event participation

In the event that we introduce promotional events in a bid to encourage and reward your dedication to the Haird Platform and our Services, we collect information that you actively share when you participate in a contest, promotion, or survey, such as contact information provided when you enter a contest, or giveaway through the Service. We do this to notify you of a win, to verify your identity, and/or to send you a prize. In some cases, we may require additional information as part of the participation process, such as your desired prize selection. Such contests are voluntary. We recommend that you read the rules and other relevant information for each contest that you enter. In addition, we collect information about your preferences for receiving marketing communications from us as well as your interactions with them.

Application Data

If you use our mobile application, we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information:

  We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide accurate location being that we provide a platform offering home-based services. If you wish to change our access or permissions, you may do so in your device's settings.

• Mobile Device Access:

  We may request access or permission to certain features from your mobile device, including your mobile device's calendar, contacts, microphone, camera, reminders, SMS messages, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

• Push Notifications:

  We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings. This information is primarily needed to maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes.

Other data not explicitly listed here

We will use other data that you provide as described in this Privacy Policy or for any other purpose disclosed to you at the time we collect your information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information from third-party sources

We may combine the personal information that we receive from you with personal information that we obtain from other third-party sources, such as:

• Data providers:

  Such as information services data licensors that provide demographic information, which among other purposes help us detect fraud.

• Our affiliate partners:

  Such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.

• Marketing partners:

  Such as joint marketing partners and event co-sponsors.

• Public sources:

  Such as government agencies, public records, and other publicly available sources.

• Other third-party services:

  We may obtain your information from other third-party services, such as Social media services - from which we may collect information such as your username, profile picture, and email address associated with the relevant third-party service provider, if you choose to register or log in on the Service using said third-party service.

To enhance your experience with our services and support the other purposes for which we collect personal information, we may automatically record information about you, your computer, or mobile device and your interactions with the Service, our communications, and other online services over time, such as:

• Device data:

  We collect certain information about the device you use to access the Service, such as device model, operating system information, language settings, and unique identifiers (including identifiers used for advertising purposes).

• Service usage information:

  We collect information about your interactions with the Service, including the pages you view, the duration on a page, the source from which you arrived at the page, your interactions with the page, whether you opened our emails, and whether you clicked the links within our emails.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Haird App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through technology. The information we collect includes:

• Location Data:

  We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of our Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage Haird accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To facilitate efficient delivery of services between users and professional service providers. We may process your information to provide you with the requested personal service and connect users with an available technician.
• To respond to user inquiries/offer support to users and/or professional service providers. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our services, changes to our terms and policies, and other similar information.
• To fulfil and manage booking requests and appointments. We may process your information to fulfil and manage your requests, payments, and appointments scheduled utilising Haird Services.
• To enable user-to-technician communications. We may process your information where you choose to use any of our offerings that allow for communication with a professional service provider.
• To request feedback. We may process your information when necessary to request feedback, reviews and ratings and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.
• To post testimonials. We post testimonials on our Services that may contain personal information.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To administer prize draws and competitions. We may process your information to administer prize draws and competitions.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
• We may also process your information for other purposes with your consent.

Where personal data is processed for a new purpose other than that for which the personal data are originally collected and the processing is not based on the data subject’s consent, we carefully assess the permissibility of such new processing. We will, in order to ascertain whether processing for a new purpose is compatible with the purpose for which the personal data are initially collected, take into account, inter alia:

• any link between the purposes for which the personal data are collected and the purposes of the intended further processing;
• the context in which the personal data are collected, in particular, regarding the relationship between you and us;
• the nature of the personal data, in particular whether special categories of personal data are processed or whether personal data related to criminal convictions and offences are processed; and
• the possible consequences of the intended further processing for you; and the existence of appropriate safeguards, which may include encryption or pseudonymisation.

3. LEGAL BASIS

We are allowed to use personal information in the ways described above if we have a proper reason to do so. We always make sure we have a good reason for doing anything with your data.

Entry into and performance of the contract (including, provision of personal services) Personal data is generally processed in order to provide the services contracted through the Haird app with you. This means that to give you the service we promised you, and to meet our terms and conditions, we’ll process your personal data to meet those obligations.

Legitimate interest

We generally in other circumstances process your personal data relying on legitimate interest grounds, if we have concluded a legitimate interest assessment. Legitimate interests include our commercial interests in providing an innovative, personalised, safe and profitable service to our users and partners, where applicable, unless those interests are overridden by other interests.

We may process your personal data (excluding special categories of personal data) based on legitimate interest for the following purposes:

• for the purpose of investigating and detecting fraudulent payments, malicious activities or unlawful activities, and/or safety or security incidents (depending on the nature of the investigation, all data categories may be processed);
• maintaining the safety and security of our network and systems, and responding to suspected or actual criminal acts; making and reviewing recordings and logs: we may record messages and booking requests given both on our premises and using means of communication (e-mail, phone calls, the Haird app, etc.) as well as information and other activities we have performed. We may also review audio recordings submitted to us using our audio recording feature (where such a feature is available). If necessary, we use these recordings for investigations, proof and protection against claims and/or for quality assurance; and

• implementing and maintaining features to ensure the security of our services; and establishing, exercising or defending legal claims, including:

  • supporting our own internal investigations;
  • the assignment of claims and the use of debt collecting agencies where permissible by law; and
  • the use of legal advisors (depending on the claim, all data may be processed).

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We only work with trusted partners and authorities. We only share when there is a proper reason to do so. We limit sharing to only that which is required. We do not sell your personal information.

With respect to users, we may share your personal information with technicians you have requested an appointment with through the Platform. We endeavour to platform only trusted professional service providers/technicians. The personal data of the user is only disclosed to the professional service provider/technician when they engage with a personal service in the Haird app; in such a case, the professional service provider/technician will see the name, phone number, and geolocation data of the user.

After providing the personal service, the name and telephone number of the users and professional service provider/technician will remain visible for 24-48 hours. This is necessary for parties to resolve any issues like getting an item back to a professional service provider/technician which might have been forgotten in the course of a home service.

Feedback given by users regarding the quality of the personal service service is anonymous. Your rating is private between you and Haird.

We may also share your data, when absolutely necessary, with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may share personal information with are as follows:

• Payment Processors
• Performance Monitoring Tools
• Sales & Marketing Tools
• User Account Registration & Authentication Services

We also may need to share your personal information in the following situations:

• Business Transfers:

  We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, change of control, or acquisition of all or a portion of our business to another company. Haird will process personal data in this regard under the same strict conditions as established in this privacy notice.

• When we use Google Maps Platform APIs:

  We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise. We obtain and store on your device ('cache') your location for twelve (12) months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

• Affiliates:

  We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Other Users:

  When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

• Offer Wall:

  Our application(s) may display a third-party hosted 'offer wall'. Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be redirected to an external channel belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

Legal Obligations and Rights.

In some circumstances, we are legally obliged to share information with external recipients. For example, a valid legal request to disclose personal information pursuant to a Court Order or where we cooperate with a data protection supervisory authority such as the Nigeria Data Protection Commission (NDPC) in handling complaints or investigations. We can also respond to requests, such as those from law enforcement agencies, when we have a good-faith belief that the response is required by law or furthers a public interest task, affects users, and is consistent with lawfully recognised standards. In any scenario, we’ll always satisfy ourselves that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.
In such circumstances where we may access, preserve, and share the information described in ‘WHAT INFORMATION DO WE COLLECT?’ with law enforcement agencies, public authorities, copyright holders, or other third parties, it is premised on good faith belief that it is necessary to:

• comply with applicable law, legal process or government requests, as consistent with internationally recognised standards;
• protect the vital interests, rights, property, and safety of users, and professional service providers/technicians, including protecting life or preventing imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk; and/or when you have given us clear consent to do so for another specific purpose for which you have been fully informed;
• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards; or
• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

The retention periods will be different depending on the type of information, the purposes for which we use the information and any legal requirements. For example, when we process your information to provide you with our Services, we keep this information for as long as you have an active account. This information includes your profile information, input and payment information. If you violate any of our terms, policies or guidelines, we may remove your profile information, input and/or payment information from public view immediately but keep your information as necessary to process the violation.

If your account is closed, personal data will be deleted (according to our retention schedule and rules), unless such data is still required to meet any legal obligation, or for accounting, dispute resolution or fraud prevention purposes.

Financial data regarding personal services provided to users will be stored for three (3) years after the last home service delivery. Data required for other accounting purposes will be stored for six (6)years after the last home service delivery.

In the event that there are formal investigations of a criminal offence, fraud or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements.

In case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims.

Booking history data and the data about usage of personal services will be stored for two (2) years, after which the data will be anonymized.

We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing our Services and enhancing their safety, security and stability), and for the exercise or defence of legal claims.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

The security of your information is important to us. We maintain commercially reasonable technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. Having implemented these appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process, we regularly review our security measures to consider available new technology and methods.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Haird app, or third-party circuits.

8. INFORMATION RELATING TO MINORS?

Our Services are not aimed at children under the age of 18 and we do not actively collect personal information from or market to minors. Minors cannot create a profile on the Haird app. In the event that a minor desires the services offered by the platform, the minor must seek the approval and assistance of a parent or guardian who is capable of providing consent and operating a Haird account on their behalf.

If we notice or receive feedback that we have collected any of their personal information without prior consent from a parent or guardian, we will attempt to delete the information as soon as possible. If you believe that we processed personal information about or collected from a minor, please contact us at hairdlimited@gmail.com

9. WHAT ARE YOUR PRIVACY RIGHTS?

We want you to stay in control of your personal data. Haird provides you with controls through the app where you can view your personal information including your profile data and booking history for personal services. We may also offer in-app settings like marketing opt-ins, where applicable.

Your right of access

You can access your personal data via the Haird app. You have the right to ask us for copies of your personal information. There are some exemptions, such as when we have to balance the rights of others, which means you may not always receive all the information we process.

Your right to rectification

You can access and update your personal data via the Haird app. You have the right to ask us to rectify information you think is otherwise inaccurate. You also have the right to ask us to complete information you think is incomplete.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances. Please note that the de-installation of the Haird app in your device does not cause the deletion of your personal data. If the Haird app has not been used for two (2) years, we’ll get in touch and ask you to confirm whether you wish to keep your account active for future use. If no reply is received in a reasonable time, the account will be closed and personal data will be deleted unless such data is required for any purpose mentioned earlier in this privacy notice.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights.

Your right to object to processing

You may have the right to object to processing if we are processing your information on the basis of legitimate interests. You may object at any time to the processing of your personal data which involves automated processing or profiling which has a significant effect on your rights requires human intervention. You also have the right to require an explanation regarding the logic behind an automated decision we have made.

Your right to data portability

You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you, in certain circumstances. This only applies to information you have given us.

The retention period for the data about instant messages directly in the Haird In-app messages is ninety (90) days, except in cases where messages are related to a reported incident, in which case we will store them for twelve (12) months.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to personal service requests or bookings, or confirmation of appointments, or for other non-marketing purposes.

Account Information

You may review, change, or terminate your account at any time. If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked. If a standard for tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

11. PRIVACY POLICY UPDATES

We may update this Privacy Notice from time to time to improve our Services and stay compliant with relevant laws. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification or by providing any other notice required by applicable law. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

If you have registered for an account, you may also access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.

Based on the applicable laws, you have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Please note that your exercise of these rights may impact your ability to use some or all of Haird Services' features and functionalities.

To request to review, update, or delete your personal information, please complete and submit a data subject access request or contact us directly via hairdlimited@gmail.com. We will respond to your request in a manner consistent with applicable law and subject to proper verification.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you can contact us through the following methods: