Privacy Policy

1. INTRODUCTION

Dufil Prima Foods Limited ("Dufil", "we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy applies to the "Show Some Love to Mum" campaign - an AI-powered Praise Poetry experience hosted at showsomelovetomum.indomie.ng (the "Campaign").

This policy explains what data we collect from you during the Campaign, why we collect it, how we use it, and how we protect it. It also outlines your rights under applicable Nigerian data protection laws.

By participating in this Campaign, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy.

2. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy defines the data collected and processed as part of your participation in the Show Some Love to Mum Campaign. The Campaign allows users to upload photographs, provide personal details about their mothers, and generate a personalised AI-powered Praise Poetry (Oriki) video.

In cases where a child's data or a mother's photograph is submitted, we will apply appropriate consent standards. By submitting such data, you confirm that you have the legal authority to do so on behalf of the individual whose data is being provided.

We keep this Privacy Policy under regular review (at least once every 2 years). The latest version is published at showsomelovetomum.indomie.ng.

3. WHAT DATA DO WE COLLECT?

The following categories of personal data may be collected during your participation in this Campaign:

a. Identity Data — Includes your name, phone number, email address, and social media username where provided. Used to identify you as a participant and link your Campaign activities to your submission.

b. Contact Data — Includes your phone number and email address, used to deliver your generated video and send campaign-related communications.

c. Photographic Data — One or more photographs of your mother or the person you are celebrating. These images are processed solely to generate the personalised AI Praise Poetry video and are not used for any other purpose without your explicit consent.

d. Campaign Preferences — Includes language preference for the Praise Poetry (e.g. Yoruba, Igbo, Hausa, Pidgin), the name of the person being celebrated, and personal memories or descriptions shared during the submission process.

e. Technical & Behavioural Data — Includes device type, browser information, referral codes, UTM parameters, and usage data collected via Google Analytics 4 (GA4). This data is used for campaign performance tracking and is not linked to your personal identity.

f. WhatsApp Opt-in Data — If you provide your WhatsApp number, you consent to receiving your generated video and relevant campaign communications via WhatsApp. This is optional.

4. HOW DO WE COLLECT YOUR DATA?

We collect your personal data through the following touchpoints:

• Campaign submission form at showsomelovetomum.indomie.ng - where you upload photos, enter names, select language, and provide personal memories.
• WhatsApp communications - where you opt in to receive your video or campaign updates via WhatsApp.
• Referral and invite links - unique short links (/s/[code] and /invite/[code]) used to track how participants discover and share the Campaign.
• Cookies and analytics tools - including Google Analytics 4, which collects anonymised behavioural data during your visit.
• Social media interactions - where you tag @IndomieNigeria or use #ShowSomeLoveToMum.

5. LEGAL BASIS FOR PROCESSING YOUR DATA

We process your personal data under the following lawful bases in accordance with the Nigeria Data Protection Act 2023 (NDPA) and the NDPA General Application and Implementation Directive (GAID) 2025:

• Consent - You have given clear consent for us to process your personal data for Campaign purposes, including generating your personalised video and sending you communications.
• Legitimate Interests - To analyse Campaign performance, prevent fraud, and improve our services, where your interests and rights do not override ours.
• Legal Obligation - Where we are required by law to process or retain certain data.
• AI-Based Processing - Where third-party AI services process your submitted data (photographs and text) solely to generate the Praise Poetry video output. These processors are contractually bound to handle your data in compliance with applicable data protection laws.

You may withdraw your consent at any time. Where withdrawal prevents us from completing your video or delivering certain services, we will inform you accordingly.

6. HOW DO WE USE YOUR DATA?

Your data is used for the following purposes:

• To generate your personalised AI-powered Praise Poetry video.
• To deliver your video to you via the Campaign website and/or WhatsApp.
• To send you campaign-related communications and updates where you have consented.
• To track and measure Campaign performance using anonymised analytics data.
• To manage referral chains and viral attribution for Campaign reporting.
• To comply with legal obligations under Nigerian data protection law.
• To promote the Campaign on Indomie Nigeria's digital channels, including social media, where you have tagged or shared your video publicly.

7. STORAGE AND RETENTION OF YOUR DATA

Your personal data will be:

a. Retained for as long as necessary — We retain your personal data only for as long as required to fulfil the purpose for which it was collected, to comply with applicable laws, and to meet our legitimate business interests. Campaign data will be reviewed for deletion within 12 months of the Campaign closing date.

b. Protected with appropriate security measures — Dufil Prima Foods and our processing partners use physical, technical, and administrative security measures to safeguard your data from unauthorised access, collection, use, disclosure, modification, or disposal, in line with applicable Nigerian data protection regulations.

c. Shared only with trusted partners — We may share your data with the following categories of third parties strictly for Campaign purposes:

• AI video generation service providers - to process your photos and text into a Praise Poetry video.
• WhatsApp Business API providers - to deliver your video via WhatsApp.
• Analytics platforms - including Google Analytics 4, for anonymised Campaign performance tracking.
• Marketing and communications agencies supporting the Campaign.

We do not sell your personal data to any third party. All third-party processors are contractually required to apply equivalent data protection standards.

d. Stored within secure environments — Where data is transferred outside Nigeria for processing (e.g. AI video generation), we ensure that adequate protections are in place in accordance with the NDPA 2023 and its directives.

8. COOKIES AND TRACKING TECHNOLOGIES

The Campaign website (showsomelovetomum.indomie.ng) uses cookies and similar tracking technologies to:

• Track your session and referral source during your visit.
• Measure Campaign engagement and conversion through Google Analytics 4.
• Store your referral code to correctly attribute your participation to the person who invited you.

We use session cookies that are erased when you close your browser, as well as persistent cookies for analytics purposes. These cookies do not collect personally identifiable information by themselves.

You may manage or disable cookies through your browser settings. Please note that disabling cookies may affect certain Campaign features, including referral tracking and video delivery.

9. YOUR PRIVACY RIGHTS

Under the Nigeria Data Protection Act 2023, you have the following rights with respect to your personal data:

• Right to Access - Request information about the personal data we hold about you.
• Right to Correction - Request correction of inaccurate or incomplete personal data.
• Right to Erasure - Request deletion of your personal data, subject to legal retention requirements.
• Right to Restriction - Request that we limit how we process your data.
• Right to Object - Object to processing for direct marketing purposes.
• Right to Data Portability - Request transfer of your personal data to another party.
• Right to Withdraw Consent - Withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact us using the details in Section 12 of this policy. We will respond to your request within the timeframes stipulated by applicable Nigerian law.

10. SPECIAL NOTE ON PHOTOGRAPHIC AND BIOMETRIC DATA

Photographs submitted as part of this Campaign may constitute sensitive personal data under applicable law. By submitting a photograph, you confirm that:

• You have the right and authority to submit the photograph of the person depicted.
• You consent to the photograph being processed by AI systems solely for the purpose of generating the personalised Praise Poetry video.
• The photograph will not be used for facial recognition, profiling, or any purpose beyond video generation without your explicit additional consent.

Photographs will be deleted from our processing systems within 90 days of your video being generated, unless you have consented to extended use for Campaign promotional purposes.

11. MODIFICATION & TERMINATION

• Dufil Prima Foods Limited reserves the right to modify or update this Privacy Policy at any time. Changes will be communicated via the Campaign website.
• If material changes are made, we will notify participants via WhatsApp or email where contact details are available.
• Continued participation in the Campaign following notification of changes constitutes acceptance of the updated Privacy Policy.

12. GOVERNING LAW & DISPUTE RESOLUTION

• This Privacy Policy shall be governed and interpreted in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act 2023 and its directives.
• Any disputes arising from data collection and processing activities shall first be resolved amicably. If unresolved, the matter may be referred to the Lagos Multi-Door Courthouse for mediation or to the Nigeria Data Protection Commission (NDPC) for regulatory review.

13. CONTACT INFORMATION

For inquiries, data access requests, or assistance regarding this Privacy Policy, please contact:

Dufil Prima Foods Limited

44 Jimoh Odutola Street, Off Eric Moore Road, Surulere, Lagos, Nigeria

Email: contactus@dufil.com

Phone: 234(0)8004636643 | (0)7004636643

Campaign Website: showsomelovetomum.indomie.ng