PRIVACY POLICY

Saharan Distillers Limited

Last Updated: 15 April 2026

1. Introduction

Saharan Distillers Limited (“we”, “our”, “us”) values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and safeguard your information when you interact with our products, services, websites, events, and promotions.

This Policy applies to all individuals who engage with our brands, including customers, website visitors, distributors, vendors, partners, and other stakeholders. It sets out our responsibilities under the Nigeria Data Protection Act (NDPA) 2023 and other applicable data protection regulations, and describes your rights in relation to the personal data we process.

We encourage you to read this Privacy Policy carefully, as it contains important information about how we handle your personal data, the purposes for which it is used, and the safeguards we apply to ensure its confidentiality, integrity, and lawful processing.

2. Legal Framework

This Privacy Policy is issued in compliance with the Nigeria Data Protection Act 2023 (NDPA), Sector specific regulations, International standards and other applicable data protection regulations.

Our processing of personal data is guided by the following principles:

·Lawfulness and Transparency: All data is processed fairly and openly.

·Purpose Limitation: Information is collected only for specific, legitimate purposes.

·Data Minimization: We collect only what is necessary.

·Accuracy: Personal data is kept up to date.

·Storage Limitation: Data is retained only as long as it's needed.

·Security: Appropriate measures are taken to protect personal Information against unauthorized access or misuse.

·Accountability: We take responsibility for compliance with applicable laws.

Where personal data is transferred outside Nigeria, we apply safeguards consistent with NDPA and recognized international standards to ensure its adequate protection. 

3. Personal Data We Collect

We collect different types of personal information depending on your use of our services.

Our website can be used without needing to process any personal information. However, for certain services (like placing an order, joining a campaign, or contacting us), we may need specific details. Where required information is not provided. we may not be able to deliver the service or allow you to participate in the activity.

4. How We Collect Your Data

We collect personal information in different ways, depending on how you interact with us:

·Direct interactions: When you make a purchase, register an account, join a promotion, or contact us directly.

·Website forms and subscriptions: When you fill out forms on our website, such as signing up for newsletters or submitting a contact request.

·Social media: When you engage with us on social platforms.

·Third‑party partners: From distributors, payment processors, or other service providers who help us deliver our services.

·Cookies and tracking technologies: When you visit our website, we collect information like your IP address, browser type, device details, and pages you view. This helps us improve our services, keep the site secure, and personalize your experience.

5. Purpose of Processing Personal Data

We process your personal data only for legitimate and specified purposes, in line with the Nigeria Data Protection Act 2023. These purposes include:

·Age Verification: To confirm that you meet the legal drinking age requirement (18+).

·Order Fulfillment: To process, deliver, and manage purchases and related services.

·Customer Relationship Management: To respond to inquiries, handle complaints, and maintain effective communication with you.

·Product and Service Improvement: To analyze usage, feedback, and preferences in order to enhance our offerings.

·Marketing and Promotions: To send newsletters, promotional offers, and marketing communications, subject to your consent.

·Legal and Regulatory Compliance: To meet obligations under applicable laws, regulations, and valid legal processes.

·Fraud Prevention and Security: To protect our systems, networks, and customers against fraud, cyberattacks, and unauthorized access.

·Website Maintenance and Optimization: To monitor performance, improve availability, and enhance user experience.

·Events and Campaigns: To manage participation in competitions, activations, and similar activities, which may involve collecting images, videos, or other personal information in line with the terms of such events.

If you don’t provide certain information when it’s required, we may not be able to offer you the service or let you partake in the activity.

6. Legal Basis for Processing

We are committed to ensuring that we process your personal data lawfully and transparently. We rely on one or more of the following legal bases, as permitted under the Nigeria Data Protection Act 2023:

·Consent: Where you have given explicit consent for specific purposes, such as receiving marketing communications, participating in promotions, or the use of non‑essential cookies.

·Contractual Necessity: Where processing is necessary to fulfill a contract with you or to take steps at your request prior to entering into a contract, such as order fulfillment or service delivery.

·Legal Obligation: Where processing is required to comply with applicable laws, regulations, or valid legal processes.

·Legitimate Interests: Where processing is necessary for our legitimate business interests, such as improving services, fraud prevention, and maintaining system security, provided that such interests do not override your fundamental rights and freedoms.

˙Vital Interests: Where processing is necessary to protect your vital interests or those of another natural person.

·Public Interest/Official Mandate: Where processing is necessary for the performance of a task carried out in the interest of the public or in the exercise of an official mandate vested in us.

7. Disclosure of Personal Data

We may share your personal data with trusted third parties where necessary to provide our services, comply with legal obligations, or protect our legitimate interests. Such disclosures may be made to the following:

·Payment Service Providers: To process transactions securely.

·Logistics and Delivery Partners: To fulfill and deliver orders.

·Marketing and Analytics Providers: To analyze usage, improve services, and deliver relevant communications.

·Regulatory Authorities: Where required by law, regulation, or valid legal process.

·Professional Advisors: Including legal, audit, and compliance consultants.

·Customer Service and Technical Support Providers: To assist in resolving inquiries and maintaining service quality.

We may also disclose personal data in the following circumstances;

·To comply with applicable laws, regulations, or court orders.

·To protect the rights, safety, and property of our customers, employees, and the public.

·To operate and maintain the security of our systems and networks, including fraud prevention and cybersecurity measures.

·To enforce our agreements, terms, and policies.

·In connection with corporate transactions such as mergers, acquisitions, or asset transfers.

All third parties with whom we share personal data are contractually required to protect your information and process it only for the specified purposes for which it was disclosed.

8. International Data Transfers

Where personal data is transferred outside Nigeria, we ensure that adequate safeguards are in place in line with the Nigeria Data Protection Act 2023 (“NDPA”) and any applicable directives or regulations.

We may share personal data with:

·Group Companies: Data may be shared with affiliated companies for technical support, storage, shared IT systems, and responding to inquiries.

·Service Providers and Data Processors: Trusted third‑party vendors may assist with analytics, marketing, IT support, and other services. These parties are contractually required to handle your data securely and in accordance with applicable laws.

·Legal Obligations and Transactions: Personal data may be shared where necessary to comply with legal obligations, regulatory requirements, or in connection with corporate transactions such as mergers or asset transfers.

Safeguards for International Transfers

We implement appropriate contractual and technical safeguards, including Data Processing Agreements, to ensure that your personal data is protected when transferred to a foreign country.

Where personal data is transferred to a country deemed to have inadequate data protection laws, we will take all necessary steps to obtain your informed consent and ensure you are aware of the risks involved.

In such cases, we will ensure that personal data is transmitted in a safe and secure manner, consistent with NDPA requirements.

9. Data Retention

We retain your personal data for the minimum duration necessary to fulfill the purposes outlined in this Privacy Policy. Once your data is no longer required, it will be securely deleted or de-identified, unless retention is required by law or necessary to protect our legitimate interests.

We will only retain your personal data under the following circumstances:

·Marketing purposes: Up to 6 years, or until you withdraw your consent or opt out of communications.

·Contractual purposes: For the duration of the contract and up to 6 years after its termination, for legal or audit purposes.

·Legal compliance: As required by applicable law or for as long as necessary to demonstrate compliance.

After these periods, we will securely delete or anonymize your data to ensure that it can no longer be associated with you unless retention is required by law or necessary to protect our legitimate interests.

10. Your Privacy Rights Under the Nigeria Data Protection Act 2023

This Privacy Policy describes your rights regarding our collection, use, storage, sharing, and protection of your personal information. Under the Nigeria Data Protection Act 2023, you have the following rights with respect to your personal data:

·Access: You may request information from us as to whether and what personal data we hold about you.

·Rectification: You may request correction of any inaccurate, incomplete, or outdated personal data of yours with us.

·Erasure (Right to be Forgotten): You may request deletion of your personal data, provided such deletion does not conflict with our legal or regulatory obligations.

·Restriction of Processing: You may request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.

·Withdrawal of Consent: Where processing is based on your consent, you may withdraw that consent at any time.

·Data Portability: You may request to receive the personal data you have provided to us in a structured, commonly used, and machine‑readable format, and in certain circumstances, request that we transmit such data to another controller.

·Object to Processing: You may object to the processing of your personal data, including for direct marketing purposes.

˙Automated Decision‑Making: You have the right not to be subjected to a decision based solely on automated processing, including profiling, where such decision significantly affects you.

·Lodge a Complaint: You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or other relevant authority if you believe your rights have been violated.

You can exercise these rights by contacting us through the details provided in the Contact Information section of this Privacy Policy.
Do note that requests which do not meet the requirements set out by applicable law may need to be clarified or may be lawfully denied. Certain personal data may also be exempt from such requests under applicable data protection or other laws.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our Platform. Cookies are small text files stored on your device that help us recognize you and improve our services.

Our use of cookies includes:

·Improving website functionality by remembering your preferences such as language and location.

·Analyzing user behavior to understand how visitors interact with our website and improve performance.

·Personalizing content and advertisements to provide a more tailored browsing experience.

In addition to cookies, we may use similar technologies such as tracking pixels, tags, and web beacons to measure and analyze website usage and deliver relevant advertising.

You can manage or disable cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our website. Non‑essential cookies, including those used for personalized advertising, will only be used with your explicit consent.

12. Data Security

We take the protection of your personal information seriously. We implement appropriate technical and organizational measures designed to safeguard your data against unauthorized access, loss, misuse, alteration, or disclosure. These measures are intended to ensure a level of security appropriate to the risks associated with the processing of your information.

Our security practices include, but are not limited to:

·Access Controls: Limiting access to personal data to authorized personnel only.

·Data Minimization: Collecting and retaining only the information necessary for the purposes outlined in this Privacy Policy.

·Encryption and Secure Storage: Using industry-standard methods to protect data during transmission and storage.

·Monitoring and Testing: Regularly reviewing our systems to detect and prevent potential vulnerabilities or breaches.

Despite our efforts, no method of electronic transmission or storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. In the event of a data breach, we will take prompt steps to mitigate the impact and notify affected individuals and regulatory authorities in accordance with the Nigeria Data Protection Act (NDPA) and any other applicable law

13. Age Restriction (Alcohol-Specific Clause)

Our products and services are intended strictly for individuals aged 18 years and above, or the applicable legal age for consuming alcoholic beverages in your jurisdiction. We may request proof of age before processing orders or granting access to certain services.

We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from an individual under the legal age, we will take immediate steps to delete such information from our records.

14. Marketing Communications

We may send you promotional messages, special offers, or updates about our products and services if you:

·Opt-in via our website, applications, or promotional campaigns.

·Subscribe to our newsletters.

·Purchase our products, in which case we may contact you with related offers or updates.

We process your personal data for marketing purposes only with your consent. You have the right to unsubscribe or withdraw your consent at any time through our communications link or by contacting us directly through the details listed in the Contact Information section of this Privacy Policy.

If you unsubscribe or object to our use of your personal data for direct marketing, we will promptly update our records and ensure you no longer receive promotional messages. In the case of newsletters, we will also delete the personal data used for distribution once you opt out.

Please note that even if you unsubscribe from marketing communications, you may still receive non-marketing messages such as service updates, account notices, or information required by law. These communications are necessary to maintain your relationship with us and ensure compliance with our legal obligations.

15. Third-Party Links

Our Platform may contain links to third‑party websites, applications, or services. These links are provided solely for your convenience and informational purposes. Please note that we do not control, and are not responsible for, the privacy practices, content, or security of such third‑party websites.

We strongly encourage you to review the privacy policies and terms of use of any third‑party sites you visit, as their practices may differ from ours. Your use of third‑party websites is subject to their own terms and conditions, and we expressly disclaims any liability arising from your interaction with such sites.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or other operational needs. Updates will be posted on our website with the revised effective date, and where reasonably possible, we will communicate significant changes directly to you through appropriate channels.

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your personal information and the choices available to you. Your continued use of our Platform after any updates constitutes acceptance of the revised Privacy Policy.

17. Contact Us

For questions, compliant, data requests, or any concerns about this Privacy Policy, please contact:

Saharan Distillers Limited Address: The Landmark, Km 24 Berger Bus Stop, Ikota Complex, Lekki–Ajah, Lagos

Email: customerservice@saharandistillers.com

Phone: +234 707 235 7873

18. Regulatory Authority

You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

Nigeria Data Protection Commission (NDPC)

Website: https://ndpc.gov.ng

Email: info@ndpc.gov.ng