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PRIVACY POLICY

Effective Date: 01-01-2026
Last Updated: 01-01-2026

Easy Phones LTD (“Easy Phones”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how Easy Phones LTD, RC 9840285, collects, uses, stores, shares, and protects personal information when you visit our website, use our services, purchase a device, apply for financing, communicate with us, or otherwise interact with Easy Phones.

By using our services, you acknowledge that you have read and understood this Privacy Policy.

1. About Easy Phones

Easy Phones LTD is a smartphone retail and technology company that helps customers access smartphones through flexible purchasing and financing options.

Where a customer chooses a financing option, Easy Phones may work with third-party financing or credit partners to facilitate the customer’s application and repayment arrangement.

2. Information We Collect

Depending on the service you use, we may collect the following categories of information:

A. Personal Information

This may include:

  • Full name
  • Date of birth
  • Gender, where required
  • Residential or delivery address
  • Telephone number
  • Email address
  • Identification information
  • National Identification Number (NIN), where required for verification
  • Other information required for customer verification

B. Transaction and Purchase Information

We may collect information relating to your transactions with us, including:

  • Smartphone purchased
  • Device model and specifications
  • Purchase price
  • Payment information
  • Down payment
  • Payment history
  • Order details
  • Delivery information
  • Financing arrangement

C. Device and Technical Information

When you interact with our website or digital services, we may automatically collect certain technical information, such as:

  • IP address
  • Browser type
  • Device type
  • Operating system
  • Website usage information
  • Pages visited
  • Date and time of access
  • Cookies and similar technologies

D. Communications

We may collect information you provide when you:

  • Contact our customer support team
  • Submit an enquiry
  • Complete a form
  • Communicate with us through email, telephone, WhatsApp, social media, or other channels
  • Submit feedback, complaints, or requests

3. How We Use Your Information

We may use your personal information to:

  • Process and fulfil smartphone purchases
  • Process financing applications
  • Verify your identity
  • Assess and facilitate eligibility for financing where applicable
  • Connect you with financing partners
  • Process payments
  • Deliver purchased devices
  • Manage customer accounts and orders
  • Provide customer support
  • Communicate with you regarding your purchase or financing arrangement
  • Prevent fraud, misuse, and unauthorized transactions
  • Maintain and improve our products and services
  • Comply with applicable legal and regulatory requirements
  • Resolve disputes and enforce our agreements
  • Send promotional or marketing communications where permitted by law and, where required, with your consent

We will only collect and process personal information for specified, legitimate purposes and in accordance with applicable data protection laws.

4. Legal Basis for Processing

Depending on the circumstances, Easy Phones may process your personal information on one or more lawful bases permitted under applicable Nigerian data protection law, including:

  • Your consent
  • Performance of a contract or steps taken at your request before entering into a contract
  • Compliance with a legal or regulatory obligation
  • Protection of your vital interests where applicable
  • Legitimate interests, where permitted by law and where those interests do not override your fundamental privacy rights

The Nigeria Data Protection Act requires personal data to be processed in a fair, lawful, and transparent manner and for specified, explicit, and legitimate purposes.

5. Sharing Your Information

Easy Phones does not sell your personal information.

However, we may share relevant information with trusted third parties where necessary to provide our services or comply with our legal obligations.

These parties may include:

  • Financing and credit partners
  • Payment processors and financial institutions
  • Identity and verification service providers
  • Delivery and logistics providers
  • Technology and hosting providers
  • Customer support service providers
  • Professional advisers, auditors, or legal advisers
  • Government agencies, regulators, law enforcement authorities, or courts where required or permitted by law

Where we engage third parties to process personal information on our behalf, we take reasonable steps to ensure that appropriate confidentiality, security, and data protection obligations are maintained.

6. Financing Partners

If you choose to purchase a smartphone through a financing arrangement, certain personal information may need to be shared with the relevant financing partner.

This may be necessary to:

  • Verify your identity
  • Process your financing application
  • Assess eligibility
  • Complete the financing agreement
  • Manage repayments
  • Provide customer support
  • Meet regulatory and legal requirements

The financing partner may have its own privacy policy governing how it processes your information. We encourage you to review the applicable financing partner’s privacy notice before submitting an application.

7. Marketing Communications

We may occasionally send you information about:

  • New smartphones
  • Promotions and discounts
  • Financing offers
  • New products or services
  • Easy Phones updates

Where required by applicable law, we will obtain your consent before sending marketing communications.

You may opt out of marketing communications at any time by contacting us or using the unsubscribe option provided in the relevant communication.

Please note that opting out of marketing communications will not prevent us from sending important service-related messages, such as information concerning an existing order, payment, financing arrangement, or account.

8. Cookies and Similar Technologies

Our website may use cookies and similar technologies to:

  • Keep our website functioning properly
  • Remember user preferences
  • Understand how visitors use our website
  • Improve website performance
  • Support security and fraud prevention
  • Measure website traffic and performance

Where required, we will provide appropriate cookie controls and allow users to manage applicable cookie preferences.

9. Data Security

Easy Phones takes reasonable technical and organizational measures to protect personal information against:

  • Unauthorized access
  • Unauthorized disclosure
  • Loss
  • Misuse
  • Alteration
  • Destruction
  • Accidental disclosure

Access to personal information is limited to persons and service providers who reasonably require it to perform their responsibilities.

However, no electronic transmission or storage system can be guaranteed to be completely secure. We therefore cannot guarantee absolute security of information transmitted or stored electronically.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including fulfilling contractual, legal, regulatory, accounting, dispute-resolution, and legitimate business requirements.

When personal information is no longer required, we will take reasonable steps to securely delete, anonymize, or otherwise dispose of it in accordance with applicable requirements.

11. Your Privacy Rights

Subject to applicable law and relevant conditions, you may have rights regarding your personal information, including the right to:

  • Be informed about how your personal information is processed
  • Request access to personal information we hold about you
  • Request correction of inaccurate or incomplete information
  • Object to certain forms of processing
  • Request restriction of processing in applicable circumstances
  • Request deletion of personal information where legally applicable
  • Request portability of certain personal information
  • Withdraw consent where processing is based on consent
  • Lodge a complaint regarding the processing of your personal information
  • Exercise other rights available under applicable Nigerian data protection law

The NDPC identifies data-subject rights including access, rectification, objection, restriction, portability, erasure, and rights relating to automated decision-making.

Some rights may be subject to legal or regulatory limitations.

12. Identity Verification

To protect customers and prevent unauthorized requests, Easy Phones may need to verify your identity before processing certain privacy requests.

We will only request information reasonably necessary to verify your identity and process your request.

13. Children’s Privacy

Our services are not intentionally directed toward children who are not legally permitted to enter into the relevant transactions or agreements.

We do not knowingly collect children’s personal information for purposes that are not permitted under applicable law.

If you believe a child has provided personal information to us inappropriately, please contact us so that we can take appropriate action.

14. Third-Party Websites and Services

Our website or communications may contain links to third-party websites, applications, financing platforms, payment services, or other services.

Easy Phones is not responsible for the privacy practices, content, or security of third-party websites or services.

We encourage you to review the privacy policies of third parties before providing them with your personal information.

15. International Data Transfers

Where your personal information is transferred to or processed in a country outside Nigeria, Easy Phones will take reasonable steps to ensure that such transfer and processing is conducted in accordance with applicable data protection requirements.

Where necessary, appropriate safeguards will be implemented to protect your personal information.

16. Data Breaches

In the event of a personal data breach, Easy Phones will take reasonable steps to identify, contain, investigate, and remediate the incident.

Where notification is required by applicable law or regulatory requirements, we will make the appropriate notifications to the relevant authorities and/or affected individuals within the applicable timeframe.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

  • Our services
  • Our business operations
  • Applicable laws or regulations
  • Technology
  • Data protection practices

When we make material changes, we will update the “Last Updated” date and, where appropriate, provide additional notice.

We encourage you to review this Privacy Policy periodically.

18. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have a complaint concerning the handling of your personal information, please contact us.

Easy Phones LTD
RC: 9840285
Email: Info@easyphones.ng
Phone: 0801100
Address: Ajah, Lagos, Nigeria

For privacy-related requests, please include sufficient information to help us understand and respond to your request.

19. Regulatory Authority

Easy Phones is committed to complying with applicable Nigerian data protection requirements, including the Nigeria Data Protection Act 2023 and applicable regulations and guidance issued by the Nigeria Data Protection Commission (NDPC).

Where applicable, individuals may also have the right to lodge a complaint with the relevant data protection supervisory authority.

Easy Phones LTD
Making smartphone ownership easier.