Privacy Policy

1. Introduction

Prime Essentials ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website prime-essential.store, use our services, or engage with us for bespoke tailoring commissions.

This policy is designed to comply with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Act (NDPA) 2023, and other applicable data protection laws. By using our website and services, you consent to the practices described in this policy.

If you do not agree with any part of this policy, please discontinue use of our website and services immediately.

2. Information We Collect

2.1 Personal Information You Provide

We collect personal information that you voluntarily provide when you:

• Submit an inquiry through our contact form or consultation request
• Book a bespoke fitting or commission
• Subscribe to our newsletter or marketing communications
• Visit our atelier in person and provide your details
• Engage with us on social media platforms
• Participate in our client feedback or testimonial programs

The types of personal information we may collect include:

• Identity Data: Full name, title, date of birth (for bespoke client profiles)
• Contact Data: Email address, phone number, residential address, billing address
• Body Measurements: For bespoke tailoring purposes — detailed body measurements, posture notes, fitting preferences, and garment specifications
• Style Preferences: Fabric choices, design preferences, colour preferences, and wardrobe requirements
• Transaction Data: Details about payments, commissions, and services you have purchased from us
• Communications: Records of correspondence, including emails, messages, and notes from consultations

2.2 Information We Automatically Collect

When you visit our website, we automatically collect certain information through cookies and similar technologies, including:

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution
• Usage Data: Pages visited, time spent on pages, navigation patterns, referring website, search terms
• Cookie Data: Session identifiers and preferences (see Section 8: Cookies Policy)

2.3 Sensitive Personal Data

Body measurements collected for bespoke tailoring purposes are treated as sensitive personal data. We collect and process this data only with your explicit consent, solely for the purpose of creating your commissioned garments, and we implement enhanced security measures to protect it. We do not use body measurement data for any purpose other than the creation and alteration of your garments.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• Service Delivery: To process and fulfil your bespoke tailoring commissions, schedule fittings, and deliver completed garments
• Client Communication: To respond to your inquiries, provide consultation updates, and send service-related notifications
• Personalisation: To maintain your style preferences, measurement records, and fitting history for future commissions
• Marketing: To send you newsletters, promotions, and information about new collections — only with your consent
• Website Improvement: To analyse how our website is used, diagnose technical issues, and improve user experience
• Legal Compliance: To comply with applicable laws, regulations, and legal processes
• Business Operations: For internal record-keeping, accounting, and business analysis

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose.

4. Legal Basis for Processing

Under the NDPR and NDPA, we rely on the following lawful bases for processing your personal data:

• Contractual Necessity: Processing required to fulfil a commission agreement — including creating garments, processing payments, and scheduling fittings
• Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., marketing communications, body measurements)
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided these do not override your rights and freedoms (e.g., website analytics, business development)
• Legal Obligation: Where processing is necessary to comply with legal and regulatory requirements

You may withdraw consent at any time by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

5. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your data in the following limited circumstances:

• Service Providers: Third-party vendors who assist with website hosting, email delivery, payment processing, and analytics — bound by confidentiality agreements
• Professional Advisers: Lawyers, accountants, and insurers where necessary for professional services
• Legal Authorities: Where required by law, court order, or governmental regulation
• Business Transfers: In the event of a merger, acquisition, or sale of business assets, your data may be transferred to the new entity

5.1 Third-Party Services

Our website may integrate with or link to third-party services (e.g., payment gateways, analytics platforms, social media). These services have their own privacy policies, and we encourage you to review them. We are not responsible for the privacy practices of third-party services.

5.2 International Transfers

As we serve international clients, your data may be transferred to and processed in countries outside Nigeria. When we transfer data internationally, we ensure appropriate safeguards are in place in accordance with applicable data protection laws.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (SSL/TLS)
• Secure server infrastructure with access controls
• Regular security assessments and updates
• Confidentiality obligations for all staff and contractors
• Physical security measures at our atelier for paper records and measurement documents

However, no method of electronic storage or transmission is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security.

7. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including:

• Client Records: Retained for the duration of our client relationship plus 7 years for legal and accounting purposes
• Body Measurements: Retained until you request deletion or after 7 years of inactivity
• Marketing Data: Retained until you unsubscribe or withdraw consent
• Website Analytics: Retained for 26 months
• Inquiry Data: Retained for 2 years after last contact if no commission results

After the retention period expires, we securely delete or anonymise your personal data.

8. Cookies Policy

Our website uses cookies and similar tracking technologies. Cookies are small text files placed on your device to help us provide a better user experience.

8.1 Types of Cookies We Use

• Essential Cookies: Necessary for the website to function properly — including session management and security features
• Analytics Cookies: Help us understand how visitors interact with our website (e.g., page views, time on site)
• Functional Cookies: Remember your preferences and improve your experience

8.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies, but this may affect the functionality of our website. For more information about managing cookies, visit your browser's help documentation.

9. Your Data Protection Rights

Under the NDPR and NDPA, you have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of any inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data where there is no compelling reason for continued processing
• Right to Restrict Processing: Request that we limit how we use your data in certain circumstances
• Right to Data Portability: Request transfer of your data to another organisation or to you in a structured, commonly used format
• Right to Object: Object to processing based on legitimate interests or direct marketing
• Right to Withdraw Consent: Withdraw previously given consent at any time

To exercise any of these rights, please contact us using the details in Section 12. We will respond within 30 days as required by law. We may need to verify your identity before processing your request.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

10. Children's Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal data, we will take steps to delete such information promptly. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. We will post the updated policy on this page and update the "Last updated" date. We encourage you to review this policy periodically. Material changes may be notified to you via email if you are an active client.