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Privacy Policy

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Portraits By EMEM Website – PRIVACY POLICY



Portraits By Emem (PBE) located at Carlton Gate Estate, Chevron Drive, Lekki, Lagos, Nigeria (“PBE” or “we” or “us” ) is the controller of the processing of all personal data collected through this website dedicated to PBE (the “Website”) and other PBE channels (e.g. PBE events). PBE respects your privacy and is committed to keeping your Personal Data secure and managing it in accordance with our legal responsibilities under applicable data protection laws.

Please read this Privacy Policy carefully as it contains important information to help you understand our practices regarding any personal information that you give to us or that we collect otherwise in the context of the Website (“Personal Data”).



You can use the majority of our Website without being required to provide any Personal Data to us. For certain services or activities, you will need to provide Personal Data for us to be able to provide you the requested service or product or for you to participate in the activity. Requested information on the Website marked with an asterisk is mandatory. If you do not provide the requested information, we will not be able to deliver the service or product to you or you cannot participate in the activity. In addition to the information you are required to provide to us in order to participate in activities/campaigns, we collect certain information when you visit our Website.


  • Information When You Contact Us: If you visit our Website and have a question or other remark, you can submit our Contact Form or Chat with LiveChat. You will be asked to provide your name and email address and obviously information about your request. We will only use this information to respond to your question. We will register your requests, questions, and our responses, and other actions to handle your request.


  • Information About Your Visit To And Use Of Our Website: We collect certain information when you visit our Website, such as your IP address, which web pages you visit, device category, browser, and type of internet browser, clicks, and views. We use this Personal Data as it is necessary in our legitimate interests to do so to be able to promote our products and services to our consumers and website visitors, to enable us to attract more consumers, and to improve the sale of our products and services.


  • Marketing: If you subscribe, we will send you newsletters. You can always opt-out of receiving our newsletter and you can always object to our use of your Personal Data for direct marketing purposes (for more information about how to do this, read the paragraphs below). We use this Personal Data with your consent. We will delete your Personal Data when you opt-out of receiving our newsletter.


  • Maintenance and Optimisation Of Our Website: Your Personal Data will also be used for maintenance and analysis of our Website to solve performance issues, to improve the availability and user experience. We log all use of our Website.


  • PBE Events, Competitions, Activations, And Other Similar Activities: We may collect videos/images, photographs, social handles, drawings/sketches, and other similar or related personal information in line with the terms and purposes of such events, competitions, activations and similar activities.


Our use of your Personal Data for these purposes is necessary in our legitimate interests and the information will be retained for as long as is legally permissible.



We may need to share Personal Data with third parties to help us provide services and products to you and to run our Website. These third parties are:

  • Our sister companies if another affiliate is best suited to answer a question you have posted on the Website.
  • Our sister companies for the purpose of storing Personal Data processed via the Website, due to shared IT systems.
  • Service providers where this is needed to provide us with a service and to provide data analytics services.
  • Media agencies for marketing purposes and research purposes.
  • In case PBE Plc sells all or some of the assets or shares of an PBE group company to which Personal Data was transferred to a third party, your Personal Data may be provided to this third party.


These parties may be located in Nigeria or elsewhere in the world. When Personal Data is stored by us outside Nigeria we will ensure an adequate level of protection of the transferred Data. We require service providers to use appropriate measures to protect the confidentiality and security of the Personal Data.

We may also need to provide Personal Data to law enforcement bodies in order to comply with any legal obligation or court order.



We take appropriate measures to ensure that your Personal Data is only Processed for the minimum period necessary in line with the purposes set out in this Policy or as required under applicable laws. Once your Personal Data is no longer required, we destroy it in a safe and secure manner.

Our Website may contain links to other websites. We are not responsible for the privacy practices, content, or security used by such other websites, which shall not be governed by this Privacy Policy. We advise you to always carefully read the privacy policies on these other websites.



We will retain your Personal Data for as long as legally required or for as long as necessary to provide you with any requested services or for any of the other purposes listed in this Privacy Policy. The specific retention term are listed in this Privacy Policy for each of the relevant purposes. We will take reasonable steps to destroy or de-identify Personal Data we hold if it is no longer needed for the purposes set out above or after the expiration of the defined retention term.



A major part of the information referred to in this Privacy Policy is collected via our use of cookies and similar techniques. Cookies are small text files containing small amounts of information which are downloaded and may be stored on your user device, e.g. your computer, smartphone or table. Techniques we use that may be similar to cookies are tracking pixels, Java scripts, tags, and web beacons. These cookies and similar techniques are sometimes necessary to remember your account settings, language and country, but also enable us to measure and analyse your behaviour on our Website and for showing you personalized advertisements on our Website or on third-party websites. Where required, you will be asked for consent to our use of cookies. To view more information on what cookies we use and how we use them please review our separate Cookie Policy in the footer of this Website.



You may choose to share information on our Website via social media, such as Facebook, Instagram, LinkedIn, and YouTube. This means that the information you share, with name and preferences, shall be visible to visitors of your personal pages. We advise you to carefully read the privacy policies of the social media parties as these are applicable to the processing of your Personal Data by these parties.



The Website is not intended for use by individuals under the age of 18 (or the applicable legal age for viewing images and other audio-visual materials in question). We do not knowingly collect Personal Data from individuals under the age of 18.



You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: You have the right to

  • withdraw consent where you have previously given your consent to the processing of your information;
  • object to the processing of your information if the processing is carried out on a legal basis other than consent;
  • learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing;
  • verify the accuracy of your information and ask for it to be updated or corrected;
  • under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it;
  • under certain circumstances, to obtain the erasure of your Personal Information from us;
  • receive your information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre- contractual obligations thereof.


Please note that requests that do not meet the requirements set out by applicable law or PBE’s data protection policy may be requested to be re-issued or ultimately denied and that certain Personal Data may be exempt from such access, rectification and deletion requests pursuant to applicable data protection laws or other laws and regulations.

Please note that you can also delete Personal Data by de-activating your user, however, we will retain Personal Data where it is legally required for us to do so.



You also have a right, in certain circumstances, to require us to stop processing your Personal Data, but where we have compelling legitimate grounds, we will continue processing your Personal Data. However, you have the right to object to our use of your Personal Data for direct marketing purposes, including profiling, and when you do so, we will accommodate your request. Where you have provided consent to our use of your Personal Data, you have the right to withdraw your consent without this affecting the lawfulness of our use of this Data before your withdrawal.

We shall take immediate steps to remedy any violation of your rights, without prejudice to your right to seek redress under the Nigerian Data Protection Regulations, 2019 (NDPR) and other applicable laws.



In the event we become aware that the security of the Website and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably

appropriate measures, including, but not limited to, investigation and reporting, as well as noti<cation to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.






You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this

Policy, you are not authorized to access or use the Website and Services.



We will keep this Privacy Policy under review and make updates from time to time. Any changes to this Privacy Policy will be posted on our Website page and to the extent reasonably possible, will be communicated to you.



If you have any other questions, objections to our use of your Personal Data, or a complaint about this Privacy Policy or about our handling of your Personal Data, please contact us via email or post with a data privacy request.