Who We Are
Collection and Use of Personal Information
Giwa Gardens understands that protecting and respecting the privacy of your personal information is important. This notice explains the types of information Giwa Gardens and our service providers collect about you, the purposes for which it will be used, and the period it will be retained. “Personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Depending on the circumstances of your interactions with us, Giwa Gardens may collect the types of personal information described in this notice about Guests at our parks, Callers to our support team, Visitors to our Websites, users of our mobile apps; Job Applicants, or Investors.
Personal Information We Collect from Guests and Other Consumers
For individuals who visit our websites, our mobile apps or our parks, call in to our support team or otherwise interact with us in some way, Giwa Gardens collects and processes your personal information as set forth below.
We may collect personal information from the following sources: you; people associated with you, such as people you visit the park with, or in the case of minors, parents; Giwa Gardens employees or representatives with whom you interact; the interaction you have with our websites, mobile apps or chat bots on the websites and mobile apps; Giwa Gardens (or service provider) managed systems (including attractions at the park); third-party resellers such as travel agents, hotel staff, ecommerce sites, that offer Giwa Gardens products and services; data resellers from whom we purchase leads; credit card processors / providers; companies that you have registered with to confirm your status for special discounts (e.g., military status); digital marketing platforms; social media sites, including rating/review sites; the devices you use to access our websites and mobile apps; turnstiles in the park; connecting to the Giwa Gardens computing infrastructure; video cameras in our parks or corporate offices; use of a Giwa Gardens wireless network; emergency services personnel; fraud prevention systems; and point of sale systems, including kiosks in our parks.
Some of the personal information we collect information constitutes “personal information” or “sensitive personal information” under the Nigerian Data Protection Regulation of 2019 (“NDPR”) and other similar international laws.
In particular, within the last twelve (12) months, we collected (whether directly, indirectly (e.g., by observing your actions on our websites) or from third parties) the following types of personal information, including the categories of “personal information” or “sensitive personal information” under the NDPR and other similar international laws, listed in the table below. The table below also includes our expected retention period (subject to any legal obligation to hold any such information for a longer period) and whether we have disclosed such information to third parties for a “business purpose,” “sold” or “shared” the information as such terms are defined in the NDPR.
|Personal Information Category||Examples||
Retention Period(in absence of a deletion request or legal requirement)
|Disclosed for a Business Purpose||Sold or Shared for Cross-Context Behavioral Advertising|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.||6 years after last use||Yes||Not sold or shared|
|Customer Records Personal Information||A name, signature, ID number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health information.
Some Personal Information in this category may overlap with other categories.
|2 years from creation of record||Yes||Not sold or shared|
|Protected classification characteristics under law||Age (40 years or older), national origin, citizenship, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).||6 years after last use||Yes||Not Sold or Shared|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||2 years from creation of record||Yes||Shared to analytics providers, advertising platforms, marketing companies, and co-marketing partners|
|Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||N/A||No||N/A|
|Internet or other similar network activity||Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.||N/A||No||N/A|
|Geolocation data||Physical location or movements.
Does not include precise geolocation, which is Sensitive Personal Information.
|6 years after last use||Yes||Not Sold or Shared|
|Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||N/A||No||N/A|
|Professional or employment-related information||Current or past job history or performance evaluations.||N/A||No||N/A|
|Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||6 years after last use||Yes||Shared to analytics providers, advertising platforms, marketing companies, and co-marketing partners|
We may collect the following categories of Sensitive Personal Information to use for the following purposes:
|Sensitive Personal Information Category||Examples||Retention Period(in absence of a deletion request or legal requirement||Disclosed for a Business Purpose||Sold or Shared for Cross-Context|
|Government identifiers||National ID, driver’s license, state identification card, or passport number||2 years after last use||Yes||Not sold or shared|
|Complete account access credentials||
User names, account numbers, or card numbers combined with required access/security code or password
|Precise geolocation||N/A||While the consumer has the location feature turned on in the apps.||Yes||Not Sold or Shared|
|Racial or ethnic origin||N/A||N/A||No||N/A|
|Religious or philosophical beliefs||N/A||N/A||No||N/A|
|Mail, email, or text messages contents not directed to us||N/A||N/A||No||N/A|
|Unique identifying biometric information||N/A||N/A||No||N/A|
|Health, sex life, or sexual orientation information||N/A||7 years from collection||Yes||Not Sold or Shared|
For the purposes of this Section, “personal information” does not include publicly available information from government records, lawfully obtained, truthful information that is a matter of public concern, deidentified or aggregated consumer information or information specifically excluded from the scope of applicable data protection laws, such as health or medical information or other biomedical research study or personal information covered by certain sector-specific privacy laws.
With regard to geolocation data collected through our mobile apps, when you download the particular mobile app, we may ask your permission to track your precise, real-time location. If you consent, we may track your location even when you are not using the mobile application. You may change your location-tracking preferences at any time through the settings on your device or through the settings section in the particular mobile app. Please note that because of technology limitations, such location-tracking services may be erroneous, inaccurate, incomplete or time-delayed.
With regard to all individuals, your personal information could be relevant during the investigation of an incident or complaint or when a Giwa Gardens incident report is filed. In such instances, your personal information could be used for internal investigative purposes or, if legally required to do so, personal information may be disclosed to and used by government entities.
From time to time, Giwa Gardens may run contests or promotions offering our guests or other consumers special deals, coupons, discounts, chances to win contests, and other prizes. These contests and promotions may involve third parties. In order to participate in these contests or promotions, Giwa Gardens may collect and process certain personal information about you including your first and last name, email address, postal address, date of birth, photos of yourself and family members, and other personal information required for the particular promotion. We use this information for the purposes of running the contest or promotion and to help us better understand how we can design and market our product for you and others. This information may also be shared with any relevant third-party promotional partners involved in the specific contest or promotion for which you choose to sign-up. These third parties may use your information to contact you in order to provide you with more information about their company and with further opportunities to make additional purchases. Please remember that Giwa Gardens cannot be responsible for the information which you choose to disclose to third parties. If you wish to discontinue participating in a contest or promotion, you may contact us by email at [email protected].
Giwa Gardens may provide aggregate (statistical) information about our customers, sales, online traffic patterns and related data to companies that may help us improve our business and services, but these statistics do not include any personal information.
How We Disclose Your Information
We engage other companies, including, without limitation, parent company Digitallandlords.ng, affiliates and subsidiaries (“Agents”), to perform certain services on our behalf. We may disclose your personal information with these Agents to perform the services, and, in fulfillment of the services, these Agents may disclose Personal Data collected on our behalf with us. Pursuant to written agreements with these Agents, which agreements afford appropriate, and all required, protections of your personal information, we use these Agents to provide the following services on our behalf:
- Web development services
- email services;
- consumer relations, including consumer complaint response services.
- third-party sales channels if you purchase our products or services through another company;
- analytics providers, which may considered a “sharing” under privacy laws;
- short lets that you make reservations for through a Giwa Gardens website or app;
- card processors if you make a purchase using a card;
- advertising platforms, marketing companies and co-marketing partners for advertising products and services.
- third-party in-park retailers or service delivery parties;
- shipping companies if you request your in-park purchases to be shipped;
- charitable organizations if you direct us to donate on your behalf;
- governmental entities as required;
- external medical staff or benefits providers if there is an incident requiring medical attention at our parks, offices or other locations;
- legal representation, including with regard to prevention harm to our company, its subsidiaries, our products or services or a person or property (e.g., fraud prevention);
- investor relations, financial services firms and corporate financial accounting and management personnel; and
- shareholder record-keeping, notice, transfer agent and other investor relation services.
Except as described herein, Giwa Gardens does not sell or share the personal information it collects to any unrelated third parties so that they may send you commercial promotions or unsolicited offers for unrelated products or services.
How we safeguard your information
We follow applicable laws and requirements to protect your information. Giwa Gardens uses physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse, alteration, theft, unauthorized access, or unauthorized disclosure. We evaluate these safeguards on an ongoing basis to help minimize risks from new security threats as they become known. However, as is the case with all websites, we unfortunately are not able to guarantee 100% security for data collected through our public websites.
Transfer of your information
This website and our apps are hosted in Germany. When you provide information, you are providing such information to Germany. If we transfer your information outside of Germany, we will only transfer this information in compliance with applicable law. By submitting your personal information, you are agreeing to this transfer, storing, or processing. As such, please note that there may be different standards that apply to how your information may be used and protected than the standards in place in your country. Giwa Gardens has put in place safeguards to ensure that your data is safeguarded and protected. This includes obtaining written contractual assurances from third parties assisting Giwa Gardens with its websites or apps or from third parties that are otherwise given access to your personal information and other data that require them to adopt standards that ensure an equivalent level of protection for your data as that adopted by Giwa Gardens.
Your Rights Regarding Your Personal Information
As provided under applicable data privacy or data protection laws or regulations, you may have the following rights with regard to your personal information: (i) the right to access and know; (ii) the right to rectification (i.e., correction); (iii) the right to erasure (i.e., deletion); (iv) the right to restrict processing; (v) the right to object to processing; (vi) the right to opt out of certain processing; (vii) the right to data portability; and (viii) the right to withdraw consent. If you have such rights, you may exercise any of these rights by contacting us through our WhatsApp numbers on the website or [email protected]
Giwa Gardens will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law governing the use of the given personal information. In most cases, Giwa Gardens will respond to requests within one month; provided, however, if the request is complex, Giwa Gardens may extend its response time in accordance with applicable law.
As applicable, certain state privacy laws, provide their residents, respectively, with specific rights regarding their personal information.
- Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information and sensitive personal information. Once we receive and verify your request (please see Subsection Exercising Access, Data Portability, Correction, and Deletion Rights below for more information), we will disclose to you, as applicable:
- The categories of personal information and sensitive personal information we collected about you.
- The categories of sources for the personal information and sensitive personal information we collected about you.
- Our business or commercial purpose for collecting, selling, or sharing that personal information and sensitive personal information.
- The categories of third parties with whom we disclose that personal information and sensitive personal information.
- The specific pieces of personal information and sensitive personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information and sensitive personal information for a business purpose, two separate lists disclosing:
- the personal information and sensitive personal information categories that we sold and for each category identified, the categories of third parties to whom we sold that particular category of personal information or sensitive personal information; and
- the personal information and sensitive personal information categories that we disclosed for a business purpose and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information or sensitive personal information.
- Correct Specific Information. You may have the right to request that we correct inaccurate personal information about you. Once we receive and verify your request (please see Subsection Exercising Access, Data Portability, Correction, and Deletion Rights below for more information), we will use commercially reasonable efforts to correct the information to comply with your request. This right is not afforded to residents of Utah.
- Deletion Request Rights. You have the right to request that we delete any of your personal information or sensitive personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request (please see Subsection Exercising Access, Data Portability, Correction, and Deletion Rights below for more information), we will delete (and direct our service providers to delete) your personal information or sensitive personal information from our records, unless an exception applies. In responding to your request, we will inform you whether or not we have complied with the request, and, if we have not complied, provide you with an explanation as to why. A service provider shall not be required to comply with a deletion request submitted by the consumer directly to the service provider. We may deny your deletion request if retaining the information is necessary for us, or our service provider(s), to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
- Help to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his/her free speech rights, or exercise another right provided for by law.
- Comply with the Nigerian Data Protection Regulation of 2019 (“NDPR”).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Limit Use and Disclosure of Sensitive Data. Consumers have the right, at any time, to direct Giwa Gardens to limit our use and disclosure of your sensitive personal information to use which is necessary for certain purposes enumerated in applicable law (“Enumerated Purposes”). To the extent we use or disclose your sensitive personal information for purposes other than the Enumerated Purposes (described below), you would have the right to limit such use or disclosure. Currently, we do not use sensitive personal information for purposes other than the Enumerated Purposes. To the extent applicable, you may also have the right to withdraw consent you provided for our use and disclosure of your sensitive personal information.
The Enumerated Purposes include the following:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information, including sensitive personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with us, provided that we will not disclose the Sensitive Personal Information, to another third party and will not use it to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with us.
- To perform services on behalf of us, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business.
- To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us.
- For purposes that do not infer characteristics about you.
Custom Audience Targeting
When you sign up for any Giwa Gardens email marketing or newsletter list, you expressly give us permission to provide your email address to Facebook for use solely in connection with its Custom Audience Targeting program. Facebook will match your email address to its database and will display advertisements for Giwa Gardens parks and services on your Facebook portal. If you do not wish to see such targeted advertisements, you may update your preferences by using the “Unsubscribe” link found in the emails or newsletter that we send to you or by contacting us by email at [email protected]
Our Commitment to Children’s Privacy
The Giwa Gardens websites are not intended for use by children under the age of 13 or any children outside Nigeria. Giwa Gardens does not market any of its products online for children under the age of 13, nor does Giwa Gardens design its online applications, advertisements and other features to attract an audience of children under the age of 13. Although certain pages within the website may reference “kids,” “children,” or “students,” Giwa Gardens strictly intends for such portions of the website to be used only by adults (such as parents and teachers) or children residing in Nigeria of the age 13 or older.
Giwa Gardens does not share information obtained from minors with other companies for their own use. The third parties who may have access are those assisting us with, or cosponsoring, our order fulfillments, bookings or registrations, such as for purposes of filling orders, camp registrations or processing payments. We do not share a child’s information with blogs or other sites where the information would be publicly accessible. We may collect limited information for a one-time contact. In such a situation, we do not keep the information, nor disclose it or use it for any other purpose.
If Giwa Gardens should inadvertently collect information from a child under the age of 13, or from a minor outside of Nigeria, we delete that information, except to the extent needed to seek verifiable parental consent from the minor’s parent or legal guardian. When verifiable parental consent is obtained, we collect only that personal information from a minor that is relevant to the registration or purchase. We protect the information with security safeguards and confidentiality measures that are commensurate with the sensitivity of the information. Parents or legal guardians have the right to review their child’s personal information, delete it, or withdraw permission to allow further collection or use of that information.
Links to other websites
Our websites may contain links to sites operated, controlled, and maintained by independent third parties. We do not control the use of information you may provide to such third parties. If you access other websites using the links provided in our websites, the operators of the third-party sites may collect information from you that will then be used by them in accordance with their own privacy policies, not ours. Those policies may differ from ours. It is your responsibility to familiarize yourself with privacy policies on this website and other websites.
This Policy is governed by the laws of the Federal Republic of Nigeria without giving effect to any principles of conflicts of law