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PRIVACY AND COOKIES POLICY

This Policy has 2 PARTS.

PART 1: PRIVACY POLICY

This Policy has 2 Sections. SECTION 1: Privacy Policy and SECTION 2: Image Upload Privacy Disclaimer.

SECTION 1 : PRIVACY POLICY

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Effective Date: 6th May, 2026

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1. INTRODUCTION

Ekanem Orok Limited (“Ekanem Orok”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you visit our website www.ekanemorok.com (the “Website”), purchase products, enroll in courses, subscribe to newsletters, or otherwise interact with us.

This Policy complies with the Nigeria Data Protection Act 2023 (NDPA) and related regulations and applies to all users globally, including those in jurisdictions with additional data protection requirements.

 

2. DATA CONTROLLER INFORMATION

Data Controller: Ekanem Orok Limited
Business Address: 25 Prince Kazeem Eletu Street, Osapa-Lekki, Lagos, Nigeria
Email: info@ekanemorok.com

For all privacy-related inquiries or to exercise your rights, contact us using the details above.

 

3. INFORMATION WE COLLECT

We collect personal data necessary to operate our fashion, e-commerce, publishing, and educational services.

 

A. Information You Provide Directly

  • Full name

  • Email address

  • Phone number

  • Shipping and billing address

  • Payment information (processed securely via third-party providers; we do not store full card details)

  • Course enrollment information

  • Messages sent through contact forms

  • Uploaded content (e.g., coursework submissions, reviews)

  • We may request for additional data e.g National Identity Number (NIN) if required by the government.

 

B. Automatically Collected Information

  • IP address

  • Browser type and version

  • Device identifiers

  • Operating system

  • Referral URLs

  • Pages viewed and interaction data

  • Cookies and tracking identifiers

 

C. Transaction Information

  • Purchase history

  • Course participation data

  • Subscription status

 

4. LEGAL BASIS FOR PROCESSING

We process personal data based on one or more of the following lawful bases:

  • Contractual Necessity – to provide purchased products or enrolled courses

  • Consent – for newsletters, marketing communications, and non-essential cookies

  • Legal Obligation – compliance with tax, accounting, and regulatory requirements

  • Legitimate Interest – improving services, fraud prevention, analytics

You may withdraw consent at any time.

 

5. HOW WE USE YOUR INFORMATION

We use personal data to:

  • Process orders and deliver products

  • Provide online fashion courses and digital materials

  • Respond to inquiries and customer service requests

  • Send transactional communications

  • Send marketing emails (with consent)

  • Improve website functionality and user experience

  • Prevent fraud and ensure security

  • Comply with legal and regulatory obligations​

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6. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to:

  • Ensure proper website functionality

  • Remember preferences

  • Analyze website performance

  • Deliver marketing and remarketing advertisements

You may manage cookies through your browser settings or our cookie consent tool. Disabling cookies may affect website functionality.

For detailed information, refer to our Cookies Policy.

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7. SHARING OF PERSONAL DATA

We may share personal data with:

  • Payment processors

  • Shipping and logistics providers

  • Email marketing platforms

  • Website hosting providers

  • Analytics service providers

  • Professional advisers (legal, accounting)

  • Regulatory authorities when legally required

We do not sell personal data.

All third-party service providers are contractually obligated to safeguard your information.

 

8. INTERNATIONAL DATA TRANSFERS

Your information may be transferred outside Nigeria for processing (e.g., cloud hosting or payment platforms). Where this occurs, we ensure adequate safeguards such as:

  • Data Processing Agreements

  • Standard contractual clauses

  • Compliance with NDPA and GDPR standards

 

9. DATA RETENTION

We retain personal data only as long as necessary to:

  • Fulfill contractual obligations

  • Comply with legal requirements

  • Resolve disputes

  • Maintain business records

Retention periods vary depending on the type of data and legal obligations.

 

10. DATA SECURITY

We implement appropriate technical and organizational measures, including:

  • SSL encryption

  • Secure hosting environments

  • Restricted internal access

  • Password protection

  • Staff confidentiality obligations

While we take reasonable precautions, no online transmission can be guaranteed 100% secure.

 

11. YOUR DATA PROTECTION RIGHTS

Subject to applicable law, you have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request deletion (“right to be forgotten”)

  • Restrict or object to processing

  • Withdraw consent

  • Request data portability

  • Lodge a complaint with a data protection authority

To exercise your rights, contact info@ekanemorok.com.

 

12. CHILDREN’S PRIVACY

Our website and services are not directed to children under 18 years of age. We do not knowingly collect personal data from minors. If we discover such data has been collected, we will delete it promptly.

 

13. THIRD-PARTY LINKS

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. Users should review their privacy policies separately.

 

14. AUTOMATED DECISION-MAKING

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects without human oversight.

 

15. DATA BREACH PROCEDURES

In the event of a data breach that poses a risk to your rights and freedoms, we will:

  • Notify affected individuals without undue delay

  • Notify relevant regulatory authorities as required under applicable law

 

16. POLICY UPDATES

We may update this Privacy Policy periodically. Any changes will be posted on this page with an updated Effective Date. Continued use of the Website constitutes acceptance of the updated Policy.​

SECTION 2: 

IMAGE UPLOAD AND PRIVACY DISCLAIMER

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By uploading any photographs, images, or files (the "Images") to www.ekanemorok.com or any related platform for the purposes of a style, fashion, or image consultation, you (the "Client") acknowledge and agree to the following:

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1. Verification of Ownership & Indemnity

You represent and warrant that you are the sole owner of the Images uploaded or that you have obtained all necessary third-party consents and permissions to share said Images. You agree to indemnify and hold harmless Ekanem Orok and its affiliates against any claims, losses, or damages arising from a breach of this warranty or any third-party intellectual property claims related to the Images.

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2. Purpose of Use & Non-Exclusive License

The Images are uploaded solely for the purpose of receiving professional style and image consultation. By uploading, you grant Ekanem Orok a limited, non-exclusive, royalty-free license to view, store, and process these Images exclusively for the duration of the service. These Images will not be used for marketing, social media, or advertising without a separate, explicit, and written "Media Release Agreement" signed by you.

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3. Limitation of Liability for Service Accuracy

The accuracy and effectiveness of the style analysis, color draping, face type and body type recommendations are directly dependent on the quality, lighting, and accuracy of the Images provided. Ekanem Orok shall not be held liable for any stylistic inaccuracies, dissatisfaction with recommendations, or perceived errors resulting from low-quality, edited, filtered, or misleading Images.

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4. Data Security & "Hold Harmless" Clause

While we employ industry-standard security measures to protect your digital data, no internet-based platform is 100% secure. By using this service, you acknowledge the inherent risks of digital transmission and agree that Ekanem Orok shall not be liable for any unauthorized access, data breaches, or third-party interventions beyond our reasonable control.

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5. Automated Data Retention & Deletion

To protect your privacy, all uploaded Images will be permanently deleted from our active servers within 90 days of the conclusion of your consultation. It is your responsibility to maintain your own copies of any Images you wish to keep.

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6. Prohibited Content 

You agree not to upload any Images that are unlawful, obscene, defamatory, or otherwise inappropriate. Ekanem Orok reserves the right to terminate service immediately and without refund if any uploaded material violates our professional standards or local laws.

 

17. CONTACT INFORMATION

Ekanem Orok Limited
25 Prince Kazeem Eletu Street
Osapa-Lekki, Lagos, Nigeria
Email: info@ekanemorok.com
Website: www.ekanemorok.com

PART 2: COOKIES POLICY

COOKIE POLICY

Ekanem Orok Limited
Effective Date: February 14, 2026
Website: www.ekanemorok.com

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1. PURPOSE AND SCOPE

This Cookie Policy explains how Ekanem Orok Limited (“Ekanem Orok”, “we”, “us”, or “our”) uses cookies, tracking technologies, pixels, tags, scripts, and similar technologies (“Cookies”) when you access or use www.ekanemorok.com (the “Website”).

This Policy forms part of our Privacy Policy and Terms of Use. Where Cookies involve the processing of personal data, such processing is governed by applicable data protection laws including the Nigeria Data Protection Act 2023 (NDPA), NDPR, and, where applicable, GDPR.

By continuing to use the Website, you acknowledge that Cookies may be placed on your device subject to your preferences and applicable law.

 

2. WHAT ARE COOKIES?

Cookies are small data files placed on your device when you visit a website. They allow websites to:

  • Recognize your browser or device

  • Store preferences

  • Enable secure functionality

  • Analyze traffic

  • Deliver targeted advertising

  • Improve performance

Cookies may collect technical identifiers such as IP address, device ID, browser type, and usage patterns.

Cookies themselves do not directly identify you unless combined with other data.

 

3. CATEGORIES OF COOKIES WE USE

We categorize Cookies as follows:

 

A. STRICTLY NECESSARY COOKIES (NON-OPTIONAL)

These Cookies are essential for the Website to function and cannot be disabled in our systems.

They are used to:

  • Maintain security

  • Prevent fraud

  • Enable checkout and payments

  • Manage user sessions

  • Remember cookie consent settings

  • Ensure website stability

Legal Basis:

  • Contractual necessity

  • Legitimate business interest

If you disable these Cookies via browser settings, parts of the Website may not function properly.

 

B. FUNCTIONAL COOKIES

These Cookies enhance user experience by remembering:

  • Language selection

  • Location preferences

  • Login credentials

  • Form inputs

Legal Basis: Consent (where required).

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C. ANALYTICS AND PERFORMANCE COOKIES

These Cookies help us understand how users interact with the Website. We use this information to:

  • Improve website functionality

  • Monitor performance

  • Diagnose technical issues

  • Optimize content and layout

Information collected may include:

  • Page visits

  • Time spent on pages

  • Click behavior

  • Traffic sources

Data may be aggregated and anonymized where possible.

Legal Basis:

  • Consent (where required by law)

  • Legitimate interest (where permissible)

 

D. ADVERTISING AND MARKETING COOKIES

These Cookies track browsing behavior to:

  • Deliver relevant advertisements

  • Enable remarketing campaigns

  • Measure campaign effectiveness

  • Prevent repetitive ads

  • Build audience segments

These Cookies may be set by third-party advertising networks.

Legal Basis: Explicit consent.

We do not guarantee that opting out of marketing Cookies will eliminate all advertisements; it may only make them less personalized.

 

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4. FIRST-PARTY AND THIRD-PARTY COOKIES

First-Party Cookies

Set directly by Ekanem Orok and used solely for our operational purposes.

Third-Party Cookies

Set by service providers such as:

  • Payment processors

  • Website hosting providers

  • Analytics platforms

  • Email marketing services

  • Social media integrations

  • Advertising partners

Third parties operate under their own privacy policies. We do not control third-party Cookie policies and disclaim liability for their independent practices.

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5. COOKIE DURATION

Cookies may be:

  • Session Cookies – deleted when you close your browser

  • Persistent Cookies – stored until expiration or manual deletion

Cookie lifespans vary depending on purpose and provider.

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6. CONSENT MANAGEMENT

Where required by applicable law:

  • Non-essential Cookies are deployed only after your consent.

  • You may accept, reject, or customize Cookie preferences.

  • You may withdraw consent at any time via our Cookie settings tool.

Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

If you reject Cookies, certain Website features may be limited or unavailable.

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7. DATA PROTECTION AND SECURITY

Where Cookies collect personal data:

  • We apply technical and organizational safeguards.

  • We implement encryption and secure hosting standards.

  • We limit access to authorized personnel only.

  • We require contractual protections from third-party processors.

However, internet transmissions are not completely secure. Use of the Website is at your own risk.

 

8. INTERNATIONAL DATA TRANSFERS

Some Cookie-related data may be processed outside Nigeria.

Where such transfers occur, we implement safeguards including:

  • Data Processing Agreements

  • Standard Contractual Clauses

  • Compliance with NDPA and GDPR adequacy requirements

 

9. YOUR RIGHTS

Where Cookie data constitutes personal data, you may have the right to:

  • Access your personal data

  • Request correction

  • Request deletion

  • Restrict processing

  • Object to processing

  • Withdraw consent

  • Request data portability

  • Lodge a complaint with a data protection authority

Requests may be sent to:
info@ekanemorok.com

We may require identity verification before processing requests.

 

10. LIMITATION OF LIABILITY

To the maximum extent permitted by law:

  • We are not liable for third-party Cookie practices.

  • We do not guarantee uninterrupted or error-free tracking technologies.

  • Disabling Cookies may affect functionality, and we are not responsible for reduced Website performance resulting from user preference settings.

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11. UPDATES TO THIS POLICY

We reserve the right to modify this Cookie Policy at any time to reflect legal, technological, or operational changes.

Updated versions will be posted on this page with a revised Effective Date.

Continued use of the Website after updates constitutes acceptance of the revised Policy.

 

12. CONTACT INFORMATION

Ekanem Orok Limited
25 Prince Kazeem Eletu Street
Osapa-Lekki
Lagos, Nigeria

Email: info@ekanemorok.com
Website: www.ekanemorok.com

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