Context & Purpose
We have implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While we try our best to provide security that is commensurate with the industry standards, because of the inherent vulnerabilities of the internet, we cannot ensure or warrant complete security of all information that is being transmitted to us by you.
The type of Personal Information (including Sensitive Personal Data or Information) that MSB collects from the Users;
The purpose of collection, means and modes of usage of such Personal Information by MSB;
How and to whom MSB will disclose such information;
How MSB will protect the Personal Information including Sensitive Personal Data or Information that is collected from the Users; and
How Users may access and/ or modify their Personal Information.
What is Personal Data/Information?
“Personal Data/Information” means any information that relates to an identified or identifiable natural person, which, either directly or indirectly, in combination with other information available with MSB, is capable of identifying the person concerned. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location date, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It includes a name, address, a photo, an email address, bank details, medical information and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others.
“Sensitive Personal Data or Information” means data relating to religious or other beliefs, sexual tendencies, health, race, ethnicity, political views, trades union membership, or any other sensitive personal data. It includes, Personal Information of any individual relating to password; financial information such as bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health condition; medical records and history; biometric information; any detail relating to the above as provided to or received by MSB for processing or storage. However, any data/ information relating to an individual that is freely available or accessible in public domain or furnished under the Freedom of Information Act or any other law shall not qualify as Sensitive Personal Data or Information.
Types of personal information collected by MSB:
A User may have limited access to the Website and utilize some of the Services provided by MSB without creating an account on the Website. Unregistered Users can access some of the information and details available on the Website. In order to have access to all the features and benefits on our Website, a User may be required to first create an account on our Website. As part of the registration process, MSB may collect the following categories of Personal Information from the Users (hereinafter collectively referred to as “User Information”):
Address (including country and ZIP/postal code)
Password chosen by the User
Valid financial account information and
Other details as the User may volunteer.
MSB may keep records of telephone calls received and made for making inquiries, orders, or other purposes for the purpose of administration of Services.
Internet use: MSB may also receive and/or hold information about the User’s browsing history including the URL of the site that the User visited prior to visiting the website as well as the Internet Protocol (IP) address of each User's computer (or the proxy server a User used to access the World Wide Web), User's computer operating system and type of web browser the User is using as well as the name of User's ISP. The Website uses temporary cookies to store certain data (that is not Sensitive Personal Data or Information) that is used by MSB and its service providers for the technical administration of the Website, research and development, and for User administration.
The Website may enable User to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. MSB hereby expressly disclaims any liability for any misuse of such information that is made available by visitors in such a manner.
MSB does not knowingly collect Personal Information from children.
Personal Data Processing and Consent
Personal Data shall be collected and processed in accordance with specific, legitimate and lawful purpose consented to by you; provided that (i) a further processing may be done only for archiving purposes in the public interest, scientific or historical research or statistical purposes; (ii) any data processing hereunder shall exclude the transfer of data to any person. Such consent provided by you shall be obtained without fraud, coercion or undue influence and you must have the legal capacity to give consent. Personal Data collected by us shall be stored only for the period within which it is reasonably needed and secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage or exposure to other natural elements.
We owe you a duty of care of your personal data and shall be accountable for any acts or omissions in respect of data processing.
Purposes for which your information may be used by MSB:
MSB will retain User Information only to the extent it is necessary to provide Services to the Users. The information which MSB collects from you may be utilized for various business and/or regulatory purposes including for the following purposes:
Registration of the User on the Website;
Processing the User’s orders / requests and provision of Services (including provision of safe Services);
Completing transactions with Users effectively and billing for the products/ Services provided;
Technical administration and customization of Website;
Ensuring that the Website content is presented to the Users in an effective manner;
Delivery of personalized information and target advertisements to the User;
Improvement of Services, features and functionality of the Website;
Research and development and for User administration (including conducting user surveys);
Non-personally identifiable information, exclusively owned by MSB may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes including those for the purposes of determining the number of visitors and transactional details;
Dealing with requests, enquiries, complaints or disputes and other customer care related activities including those arising out of the Users’ request of the Services and all other general administrative and business purposes;
In case of any contests conducted by MSB in which the User participates, the User Information may be used for prize fulfillment and other aspects of any contest or similar offering;
Verification of identity of Users and perform checks to prevent frauds; and
Disclosure and transfer of your Personal Information:
To Sellers and other service providers appointed by MSB for the purpose of carrying out the services on MSB’s behalf under contract. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, will have rights to use and disclose the Personal Information collected in connection with the provision of these services in accordance with their own privacy policies.
To our affiliates in Nigeria or in other countries who may use and disclose your information for the same purposes as us.
If otherwise required by an order under any law for the time being in force including in response to enquiries by Government agencies for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.
In case of contests conducted by MSB in which the User participates, the concerned User’s information may be disclosed to third parties, also be disclosed to third parties to the extent necessary for prize fulfillment and other aspects of such contest or similar offering as authorised by the User.
MSB makes all User Information accessible to its employees and data processors only on a need-to-know basis. All MSB employees and data processors, who have access to, and are associated with the processing of User Information, are obliged to respect its confidentiality.
Non-personally identifiable information may be disclosed to third party ad servers, ad agencies, technology vendors and research firms to serve advertisements to the Users. MSB may also share its aggregate findings (not specific personal information) based on information relating to the User’s internet use to prospective, investors, strategic partners, sponsors and others in order to help growth of MSB’s business.
MSB may also disclose or transfer the User Information, to another third party as part of reorganization or a sale of the assets or business of a MSB corporation division or company. Any third party to which MSB transfers or sells its assets will have the right to continue to use the Personal Information and/ or other information that a User provide to us and such third party shall adhere to the applicable laws and regulations governing data protection in Nigeria.
Retention of the information:
Part of the functionality of the Website is assisting the Sellers to maintain and organize such information to effect sale and purchase of products. MSB may, therefore, retain and submit all such records to the appropriate authorities, or to Sellers who request access to such information, and the Sellers shall abide by the laws and regulations governing data protection in Nigeria.
The Website is also designed for assisting the Users to access information relating to pharmaceutical products. MSB may, therefore, retain and submit all such records to the relevant Users.
Security Practices and Procedures:
MSB adopts reasonable security practices and procedures to include, technical, operational, managerial and physical security control measures in order to protect the Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
MSB takes adequate steps to ensure that third parties to whom the Users’ Sensitive Personal Data or Information may be transferred adopt reasonable level of security practices and procedures to ensure security of Personal Information.
You hereby acknowledge that MSB is not responsible for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
Users’ rights in relation to their personal information collected by MSB:
In case the User does not provide his/ her information or consent for usage of Personal Information or subsequently withdraws his/ her consent for usage of the Personal Information so collected, MSB reserves the right to discontinue the services for which the said information was sought.
Additional notes to the User:
MSB shall not be responsible in any manner for the authenticity of the Personal Information or Sensitive Personal Data or Information supplied by the User to MSB or any Seller. If a User provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or MSB has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, MSB has the right to suspend or terminate such account at its sole discretion.
MSB shall not be responsible for any breach of security or for any actions of any third parties that receive Users' Personal Information or events that are beyond the reasonable control of MSB including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.
The User is responsible for maintaining the confidentiality of the User's account access information and password. The User shall be responsible for all uses of the User's account and password, whether or not authorized by the User. The User shall immediately notify MSB of any actual or suspected unauthorized use of the User's account or password.
MSB will communicate with the Users through email and notices posted on the Website or through other means available through the Service, including text and other forms of messaging. The Users can ask MSB, by sending an email to email@example.com containing the rectification required.
Complaints and Grievance Redressal:
MSB addresses discrepancies and grievances of all Users with respect to processing of information in a time bound manner. For this purpose, MSB has designated Mr. Arjun Udani, Executive Director who will redress the grievances of the Users expeditiously but within one month from the date of receipt of grievance, and who can be reached by:
Sending a letter marked to the attention of “Executive Director, Me Cure Smartbuy Nigeria Limited to 23, Coker Road, Ilupeju, Lagos. Nigeria, or
Sending an email to firstname.lastname@example.org