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FOLM Manufacturing Limited
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Folm Manufacturing Privacy Policy

Effective Date: 21 November 2025

Introduction
FOLM Manufacturing Limited (“FOLM”) is a registered Nigerian furniture manufacturing company.  This Privacy Policy (“Policy”) is provided in line with the extant data protection regulations and laws.  The Policy details the information collected by FOLM, how it is collected, shared, used, and how FOLM protect your data when you visit or use FOLM website or FOLM’s digital platforms. 

Assurances
As our customer, prospects or other data subjects, we express our commitment to the extant data protection laws and we urge you to be assured that we will keep protecting your data and use such data only in a manner permissible by law. As a law-abiding organisation, FOLM allows its customers and other data subjects to make choices about how their data may be shared, and we encourage you to make choices that enable us to provide you with quality products and services.

What Constitutes Consent?
By using our digital channels, you consent to FOLM’s use of your personal information for the purpose of servicing you, promoting its products to you and consummating a business relationship with you.  You may withdraw such consent in writing at any time.

Security of Personal Information
At FOLM, safeguarding your data and other personal information is our primary objective. We maintain necessary safeguards in line with extant laws to protect your data from unauthorized access and use, accidental or unlawful alteration and destruction; and other unlawful or unauthorized forms of processing.  We engage in the continuous training of our employees in the proper management of personal information. When we use other third parties such as courier, artisans, consultants and professionals to provide services, we require them to protect the confidentiality of the personal information they receive.

The Information we Collect
We collect your personal information necessary to market our products to you, process your orders and deliver our goods to you.  They may include name, address, telephone number, email address, contact address for product delivery, interest in our products, account details, information on interior design preferences, means of identity etc. All these require that personal data are collected voluntarily and clearly when you access our digital platforms or place orders using our website or other digital platforms. We may also capture or record your images when you visit our warehouse or accept delivery from our courier agents.  This is solely to be used as proof of delivery or for security reviews.

How do we Collect Information?
We may collect information from a range of sources and it may relate to any of our products or services we currently provide or may have provided in the past.

We collect your personal information when:
  • you visit our digital channels, make enquiries or view our products.
  • you call our contact centers or send us emails
  • you seek advice about our products
  • you seek information from our customer service provider, information concerning complaints and disputes
  • we process delivery to you
  • you provide address information for the purpose of receiving orders.  We may share this data with other relevant service providers involved in the logistics chain
  • you provide information concerning your identity e.g. photo ID, passport information, National ID card and nationality
  • you complete our policies and terms of sale e.g finger prints, facial images, signatures and other personal information.
  • we conduct necessary investigations i.e., due diligence checks and obtain information that we need to support our regulatory obligations.
  • we may collect information about your device, including where available your IP address, location, operating system, email, and browser type, for system administration or for our own commercial purposes. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

Basis for Processing Information
We shall process your information on the following basis:
  • To market and introduce our products and services to you.
  • To enter and perform our contractual obligations.
  • To comply with our legal obligations
  • For the performance of a statutory duty
  • For the legitimate interest of FOLM and our Data Subjects.
  • To satisfy a public interest
  • To conduct cyber security review.
  • Prior consent has been obtained from data subjects for the use and processing of personal data.

How we Use Your Information
  • FOLM will only use your information when you have provided your consent or when required by law to do so or when our services (contract) require same.
  • We use the information we collect to provide customers with excellent products and services, to manage our business and to offer an enriched and enhanced customer experience.
  • We make appropriate use of your data to manage transactions, respond to your requests, and to provide you with more relevant products and services.
  • We use your information to deliver our products and services, carry out your instructions, and provide furniture related services and other online products and services.
  • We use this information to detect and prevent financial crimes including fraud, financing for terrorism and money laundering, this is to ensure security and business continuity.
  • We will use your information to meet our compliance obligations, to comply with laws and regulations and to share it with regulators when absolutely necessary.
  • We may also use personal information we have about you such as your email address to deliver advertising to you directly or on our websites, provide updates on special deals and offers that might interest you (unless you tell us otherwise).
  • We may send you general announcements or important news about your orders, request your feedback and we believe you should be able to select what kinds of information you receive from us via email.
  • We may need to record conversations you have with us including phone calls, face-to-face meetings, letters, emails, and any other kinds of communication. These recordings may be used to check your instructions to us and improve our product and service delivery.
  • When you visit our branches or warehouses, we use CCTV cameras for security reasons and record keeping.

Who we Share Your Information with
Towards enhancing our service delivery, we may share data with our technical support and other service providers, partners, associates, and subsidiaries in the group. However, where applicable, we execute compliant data-sharing agreements or data-processing agreements to provide an extra layer of protection for personal information shared in the process.

Data Subject Access Request (DSAR) Form
As part of our commitment to protecting your privacy, we provide a Data Subject Access Request (DSAR) Form. This form allows you to exercise your rights under applicable data protection laws to access your personal data that we hold.
Individual rights
  • The right to be informed
To emphasize the need for transparency over the usage of personal data, we ensure fair processing and adequate provision of information typically through this privacy policy.
  • The right of access
Individuals have the right to access information that FOLM holds, access their personal data and other supplementary information and obtain information about how we process it.
  • The right to restrict processing
Individuals have a right to ‘block’ or withdraw their consent to our processing of your information, which you can do at any time. When processing is restricted, we are permitted to store personal data, but not further process it.
  • The right to rectification
Individuals are entitled to have personal data rectified if it is inaccurate, outdated, or incomplete. If this personal data in question has been disclosed to third parties, they must be informed of the rectification where possible. FOLM would also inform the individuals about the third parties to whom the data has been disclosed where appropriate.
  • The right to erasure/deletion
Individuals have the right to request the deletion or removal of personal data where there is no compelling legal or regulatory requirement for its continued processing. FOLM will make sure that this right is protected.
  • The right to data portability
Where practicable, we will ensure that personal data is moved, copied or transferred easily from one IT environment to another in a safe and secure way, without hindrance to usability.
  • The right to object
Individuals have the right to object to our processing of their information in some circumstances.

Available remedies
In the event of an infringement of data protection rights, we will ensure any damage is remedied within the shortest possible time. However, you are at liberty to report to the Nigeria Data Protection Commission (the NDPC) or seek other legal remedies.

Time Frame for Remedy
At FOLM, we are committed to promptly addressing any violations of data subjects' rights. Upon receiving a complaint or becoming aware of a breach, we will acknowledge the issue within 72 hours. We aim to fully resolve all issues within one (1) month. In cases where more time is required due to complexity, we will inform the data subject of the extension and the reasons for it within the initial one-month period.

Cookies Policy
A cookie is a small file that is placed on your computer’s hard drive. Its functions include storing your login and session statuses, recording your user preferences, and analyzing web traffic.

Cookies enable websites and applications to store your user preferences in order to enhance your overall website experience by better understanding your preferences, likes and dislikes. They also allow websites to identify when users are logged on their site and when they return to their site, test new content and analyse web traffic with data analytics. Apart from the data that you elect to disclose and share with us, we cannot access your computer or any other information about you with cookies.

Although most browsers automatically accept cookies, you can amend your browser settings to disable cookies. This may however prevent you from fully experiencing the website as it was intended. 

How Long we Keep Your Information
FOLM shall keep your information for as long as it is necessary and relevant to the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we may either delete or anonymize 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 information and isolate it from further processing.

Children
FOLM understands and acknowledges the importance of safeguarding children’s privacy, hence, our sites are not intentionally designed for or directed at children under the age of eighteen years of age. It is our policy never to knowingly collect or maintain information about anyone under the said age, except when you order for furniture products meant for children, in such instance, FOLM shall ensure the data rights of the child is protected.

Cross-Border Data Transfer
As part of our global operations, we may transfer your personal data to third-party service providers located in outside Nigeria, for purposes of providing furniture related services to you.  We are committed to protecting your privacy and ensuring that your personal data is treated securely and in accordance with applicable data protection laws. When your personal data is transferred across border, we take appropriate measures to ensure that it remains protected, including but not limited to:
  1. Adequate Safeguards: We will implement standard contractual clauses, binding corporate rules, or other mechanisms to ensure that your personal data is protected to the same standard as it would be within Nigeria. 
  2. Security and Confidentiality: We ensure that your personal data is securely handled during cross-border transfers through encryption, pseudonymization, and other data protection measures. 
  3. Compliance with Applicable Laws: We will ensure that all cross-border transfers comply with applicable data protection and privacy laws, including the Nigeria Data Protection Act (NDPA) and General Application and Implementation Directive (GAID) 2025. 

Data security and integrity
We have implemented reasonable and effective security policies and procedures to protect your personal information from unauthorized access, data loss and misuse, alteration, or destruction. To the best of our ability, access to your personal information is limited to those who have a need to know and are required to always maintain the confidentiality of such information. Despite our best efforts and intentions, we acknowledge that security cannot be absolutely guaranteed against all threat actors. Hence, we also make reasonable efforts to retain personal information only for so long;
  • as the data subject asks that the information be deleted
  • as necessary to comply with legal, regulatory, internal business or policy requirements, or
  • the information is necessary to comply with an individual’s request.

Principles of data protection
The Nigeria Data Protection Act 2023 mandates us to provide a highlight of the principles of data processing which FOLM fulfills as follows:
  • We ensure our processing of personal data is lawful, fair, and transparent.
  • We only collect the required and relevant personal data for our services and activities.
  • We retain personal data for only as long as necessary or permitted by law.
  • We ensure the personal data kept are updated and accurate. 
  • For as long as practicable, we enable the transfer of data from FOLM to other entities when requested.
  • We only use the data collected for the purpose disclosed or contemplated.
  • We remain accountable for the personal data controlled by us.

Automated decision making
Except as otherwise declared by the NDPC, we do not engage in automated decision-making as all our processes have human intervention.

If you would like further information on anything included in this Privacy Policy, contact us at hello@folm.co
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