1. Introduction This Data Protection Policy (the Policy) stipulates the commitment of Lekki Port LFTZ Enterprise Limited (LPLEL) in ensuring protection of data in line with the Nigeria Data Protection Act 2023 and other applicable global standards and regulations on data privacy.

2. Scope This Policy has been developed by LPLEL and is applicable to all users of this Data Management System (DMS) and all references to ‘LPLEL’, 'our', 'us', 'we', or ‘company’ within this Policy are deemed to refer to LPLEL its affiliates and associates.

3. Data Data means any and all information relating to LPLEL’s information on the DMS including any information by a user of the DMS used for the obtaining, recording, organisation, retention, adaptation or alteration, calculating, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, deletion or destruction of LPLEL’s information on the DMS.

4. Security and Confidentiality LPLEL will take reasonable precautions to secure the Data against accidental unlawful destruction or loss, alteration, unauthorized disclosure or access. These precautions include technical, physical and organizational security measures to prevent unauthorized access.

5. Conditions of Use Please note that by you using this DMS you are deemed to have accepted and understood this Policy. LPLEL reserves the right to amend this Policy at any time without notice and at its sole discretion. As a user of this DMS, it is your sole responsibility to review this Policy periodically for updates, which shall come into effect immediately it is posted. You agree that your continued use of this DMS constitutes an acceptance of this Policy. LPLEL may also impose limits on certain features or restrict your access to parts of or the entire DMS without notice or liability.

6. Rights All rights in all material and content (including, but not limited to, text, images, web pages, sounds, software and video, and the look and feel, design, and compilation thereof) on this DMS are owned or licensed by us. You agree that you are permitted to use this material and/or content only as set forth in and to the extent permitted by this Policy.

7. Intellectual Property Unless otherwise indicated, LPLEL is the owner of all information shared on the DMS and the owner and authorised user of all trademarks, service marks, design marks, trade dress, patents, copyrights, database rights and other intellectual property (collectively, the “Intellectual Property”) appearing on or contained within the DMS. Except as provided in this Policy, your use of this DMS does not grant you any right, title, interest, or license to any such Intellectual Property you may access on this DMS. Except as provided in this DMS, any use or reproduction of the Intellectual Property is prohibited.

8. Restrictions on Use Except as expressly authorized by law, by us, or by the applicable licensor in writing, you are not entitled to reproduce, transmit, license, sell, publicly perform, distribute, adapt, translate, modify, bundle, merge, share, or otherwise make available to any person, or to create derivative works of, any or all of the materials or content available on this DMS, or to use it for any other purpose expect for LPLEL’s work and in case of sharing the information on this DMS, it must be strictly related to your work for LPLEL, in this case, the sharing must be to only LPLEL personnel for official purposes only.

9. Misuse We may restrict, suspend or terminate your use of this DMS in our sole discretion, where we believe that there may have been such a misuse such as:

• using the DMS for any improper, fraudulent, unlawful, or immoral purpose;
• causing any nuisance by your use of the DMS or causing the operation of the DMS to be negatively affected in any way;
• using the DMS to create, host, or transmit any defamatory, offensive, or obscene material, or engaging in activities which would cause offence to others on grounds of race, religion, creed, or sex;
• using the DMS to cause harm or attempt to harm in any way;
• using the DMS to create, host, or transmit material which infringes the copyright, trademark, patent, trade secret, privacy, right of publicity, or other intellectual property or proprietary rights of LPLEL;
• adding, removing, or modifying identifying network header information or copyright management information in an effort to deceive or mislead;
• using the DMS for any activity which adversely affects the ability of other people or systems to use the services or the Internet generally, including, without limitation, flooding and hacking.
This list only serves to provide examples and is not meant to be an exhaustive list of the type of unacceptable uses of this DMS that may result in the restriction, suspension, or termination of your use of the DMS.

10. Passwords You are responsible for maintaining the strict confidentiality of your account password, and you are responsible for any activity using your account and password. You agree to (a) immediately notify us of any unauthorised use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your account, and notify us when you desire to cancel your account. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.

11. No Warranties The DMS is provided “as is, ” and your use thereof is at your own risk. LPLEL, its officers, directors, employees, agents and assigns disclaim, to the fullest extent permitted by law, any and all express and implied warranties, including, without limitation, any warranties of merchantability, fitness for a particular purpose, performance, title, and non-infringement. We do not warrant that the DMS will be free from viruses, available, accessible, error-free, uninterrupted, or that the contents will be accurate. Although we take reasonable steps to secure the DMS, you acknowledge that the internet is not a completely secure medium and we make no warranties, express or implied, that any information or materials you post on or transmit through the DMS will be safe from unauthorised access or use. If you are dissatisfied with the DMS, your sole remedy is and shall be to discontinue using the DMS.

12. No Liability To the fullest extent permitted by law, we and our officers, directors, employees, agents and assigns shall not be liable to you the user of the DMS in any manner whatsoever. LPLEL hereby disclaims any and all liability for any loss, cost or damage (direct, indirect, consequential, or otherwise) suffered by you as a result of your use of the DMS or from any computer virus transmitted through the DMS, or other sites accessed from the DMS, regardless of whether such loss, cost or damage arises from our negligence or otherwise, and regardless of whether we are or have been expressly informed of the possibility of such loss or damage.

13. Indemnity You shall hereby indemnify us and our officers, directors, agents, employees, and representatives against any loss, damage, or cost arising out of your use of the DMS, any of its services, or any information accessible over or through the DMS, including information obtained from other websites, your submission or transmission of information or material on or through the DMS or interfacing sites, or your violation of this Policy, the terms of use of any interfacing sites, or any other laws, regulations, and rules. You also hereby indemnify us and our officers, directors, agents, employees, and representatives against any claims that any information or material you have submitted or will submit to us is in violation of any law or in breach of any third party rights (including, but not limited to, claims in respect of defamation, invasion of privacy, breach of confidence, infringement of copyright, or infringement or violation of any other intellectual property right). We reserve the right to exclusively defend and control any claims arising from the above and any such indemnification matters, and you hereby agree to cooperate fully with us in any such defences.

14. Restriction, Suspension and Termination We are entitled to restrict, suspend, or terminate your access to the DMS and/or your ability to avail of any of the services on the DMS, including interactive services, at any time if we believe that you have breached this Policy. Any such restriction, suspension, or termination will be without prejudice to any rights that we may have against you in respect of your breach of this Policy. We may also remove the DMS as a whole or any sections or features of the DMS at any time. Please note that we have the ability to trace your IP address and if necessary contact your internet service provider in the event of a suspected breach of this Policy.

15. Entire Agreement This Policy constitute the entire agreement between you and LPLEL in relation to its subject matter and supersedes any and all prior promises, representations, agreements, statements, and understandings of any sort whatsoever between us. To the extent that software is available through the DMS, such software may be subject to a license agreement that is distributed or included with such software, and you agree to abide by this Policy of any such license agreements. Our failure to exercise or enforce any right or provision of this Policy shall not constitute a waiver of such right or provision. If any provision of this Policy is found by a Court of competent jurisdiction to be unenforceable or invalid, the parties nevertheless agree that the Court should endeavour to give effect to the parties’ intentions as reflected in that provision, and the other provisions of this Policy shall remain in full force and effect. We may, at our option, cede, assign, or otherwise transfer any or all of our rights and obligations under this Policy to any third party or parties at any time. 16. Law and Jurisdiction This Policy and any matter relating to the DMS, shall be governed by Nigerian law without regard to its conflict of law rules. Any legal proceeding arising out or relating to this Policy that is against or relating to us or any indemnified party will be subject to the exclusive jurisdiction of the Courts of Nigeria and you hereby irrevocably consent to the jurisdiction of such Courts.