PRIVACY POLICY OF FORTUNE360 PHARMACY

1. Introduction
Welcome to Fortune360 Pharmacy Limited, a duly registered Nigerian company engaged in the selling of pharmaceutical, clinical materials and general merchandise.
At Fortune360 Pharmacy, your privacy, trust, and data protection are our highest priorities. We are committed to safeguarding all personal and health-related information you share with us, whether you visit our pharmacy, make purchases online, use our mobile app, or contact us via digital channels.
This Privacy Policy explains in detail how we collect, use, store, share, and protect your information, as well as your rights under applicable data protection laws particularly the Nigeria Data Protection Act (NDPA) 2023, the National Information Technology Development Agency (NITDA) guidelines, and global best practices (e.g., GDPR principles).

2. Scope of this Privacy Policy
This Privacy Policy applies to:
• Customers and visitors of Fortune360 Pharmacy (in-store and online)
• Users of our website, mobile app, and digital prescription platforms
• All employees, contractors, and third-party partners processing customer data
• All products, services, and operations under Fortune360 Pharmacy
It does not apply to websites or services not owned or controlled by Fortune360 Pharmacy.

3. Information We Collect
We collect information necessary for quality healthcare delivery, business operations, and legal compliance.
3.1 Personal Identification Information
• Full Name
• Date of Birth / Age
• Gender
• Contact Details (email, phone number, home address)
• Identification documents (e.g., National ID, Driver’s License, Voter’s Card)
3.2 Health and Medical Information
• Prescription and medical details
• Doctor’s name and contact information (where applicable)
• Allergies, prior medications, and health notes relevant to dispensing
• Health insurance or HMO details (if applicable)
Health-related data is treated with strict medical confidentiality and accessed only by licensed pharmacists or authorized healthcare personnel.
3.3 Financial and Transaction Data
• Payment details (bank, card, or wallet information)
• Billing and shipping addresses
• Purchase and transaction history
3.4 Technical and Usage Data
• IP address and browser type
• Device identifiers and operating system information
• Cookies and analytics data
• Geolocation data (if enabled for delivery or service location)
3.5 Communication and Marketing Data
• Feedback, inquiries, and survey responses
• Preferences for newsletters, health alerts, or promotional offers

4. How We Use Your Information
We use your information to deliver safe, efficient, and personalized healthcare experiences.
4.1 Core Uses
• To process and fulfill prescriptions and health product orders
• To verify prescriptions and ensure appropriate medical dispensing
• To provide personalized pharmaceutical advice and follow-up
• To contact you about your prescriptions, refills, or appointments
• To deliver products or arrange pick-ups
4.2 Administrative and Operational Uses
• To maintain accurate sales and medical records
• To manage accounts, payments, and invoicing
• To prevent fraud, theft, or misuse of services
• For audits, internal monitoring, and service improvement
4.3 Marketing and Customer Engagement
• To send health awareness messages, reminders, and offers
• To inform you about promotions, new products, or loyalty programs
• To enhance website functionality and tailor digital experiences
You can opt out of marketing communications anytime by clicking “unsubscribe” in emails.

5. Legal Basis for Processing
Fortune360 Pharmacy processes personal data under the following legal bases:
1. Consent – When you voluntarily provide information or accept communications.
2. Contractual Necessity – When processing is required to deliver products or services.
3. Legal Obligation – When required by law or regulation (e.g., health records, NAFDAC reporting).
4. Vital Interest – When processing protects your life or health in emergencies.
5. Legitimate Interest – For quality assurance, research, and business efficiency.

6. Data Sharing and Disclosure
We respect your confidentiality and only share data when necessary, under lawful and secure conditions.
6.1 Possible Recipients
• Licensed healthcare professionals and pharmacists
• Payment processors and banks
• Delivery or logistics partners
• Regulatory agencies (e.g., NDPC, NAFDAC, NHIS)
• IT or cloud service providers under strict data protection agreements
We do not sell, rent, or trade your personal information to third parties.

7. International Data Transfers
If your information is stored or processed outside Nigeria (for example, on cloud servers), we ensure:
• Transfers comply with the Nigeria Data Protection Act (NDPA)
• Appropriate safeguards like encryption and data protection agreements are in place

8. Data Retention
We retain your personal and health data only as long as necessary for:
• Legal and professional record-keeping obligations
• Regulatory and tax compliance
• Quality assurance and customer service
After this period, data is securely deleted, anonymized, or archived according to NDPA requirements.

9. Data Security
Fortune360 Pharmacy uses multiple levels of data protection, including:
• Secure servers and encrypted systems
• Access controls and authentication mechanisms
• Staff confidentiality training
• Regular security audits and vulnerability testing
• Physical security of paper and digital records
In the unlikely event of a data breach, we will promptly notify affected individuals and the Nigeria Data Protection Commission (NDPC) as required by law.

10. Your Data Protection Rights
You have the following rights under the NDPA 2023:
1. Right to Access – Request a copy of your personal data.
2. Right to Correction – Request correction of inaccurate data.
3. Right to Deletion – Request deletion of data under certain conditions.
4. Right to Withdraw Consent – Withdraw consent for processing at any time.
5. Right to Object – Object to certain processing activities like direct marketing.
6. Right to Data Portability – Request your data in a structured digital format.
7. Right to Lodge a Complaint – File a complaint with the Nigeria Data Protection Commission (NDPC).
To exercise these rights, contact our Data Protection Officer (DPO) (see Section 18).

11. Cookies and Tracking Technologies
Our website and mobile app use cookies and similar technologies to:
• Improve navigation and user experience
• Remember preferences and login sessions
• Analyze site usage and improve performance
You can disable cookies through your browser, but some features may not work properly without them.

12. Children’s Privacy
We do not knowingly collect personal data from individuals under 18 years without the supervision of a parent or guardian. If we discover such data, we will delete it immediately.

13. Third-Party Links
Our digital platforms may contain links to external sites. Fortune360 Pharmacy is not responsible for their content or privacy practices. We encourage you to review the privacy policies of those websites before sharing information.

14. Data Breach Notification
In case of a data breach:
• We will investigate immediately.
• Notify affected users and the NDPC within legally required timeframes.
• Take corrective measures to prevent recurrence.

15. Updates to this Privacy Policy
This policy may be updated periodically to reflect legal or operational changes. The updated version will be published on our website with a new “Effective Date.” Continued use of our services after updates implies acceptance of the revised terms.

16. Contact Information
For all privacy inquiries, complaints, or data requests, please contact:
Fortune360 Pharmacy Limited

📧 Email: privacy@fortune360limited.com
📞 Phone: 0700-000-3360, 0700-000-F360
🏢 Address: Shop 8 and Shop 13 at Plot No. GS1, 1(R) Crescent, Lugbe Estate, Abuja

17. Data Protection Officer (DPO) Section
17.1 DPO Contact Information
Name:
Designation: Data Protection Officer (DPO)
Organization: Fortune360 Pharmacy Limited
📞 Phone: 0700-000-3360, 0700-000-F360
🏢 Address: Shop 8 and Shop 13 at Plot No. GS1, 1(R) Crescent, Lugbe Estate, Abuja

17.2 DPO Responsibilities
The DPO is responsible for:
• Monitoring and ensuring compliance with the NDPA 2023
• Advising management and employees on data protection matters
• Handling data subject requests and privacy complaints
• Conducting periodic data protection audits and impact assessments
• Serving as the primary liaison with the Nigeria Data Protection Commission (NDPC)
• Coordinating data breach responses and training sessions

17.3 Compliance Declaration
As required by the Nigeria Data Protection Commission (NDPC), this Privacy Policy has been reviewed and approved by the appointed DPO.
By signing below, the DPO confirms that:
• Fortune360 Pharmacy complies with the NDPA 2023 and related regulations.
• Proper security, organizational, and technical controls are implemented.
• Employees and partners are trained on responsible data handling.

17.4 Data Protection Registration & Filing
Fortune360 Pharmacy maintains active data protection compliance filings with the Nigeria Data Protection Commission (NDPC), including:
• Annual compliance audit reports
• DPO registration
• Data impact assessments
• Privacy risk management framework
All filings are updated annually or as required by law.

18. Regulatory Contact
If you believe your data rights have been violated, you may also contact the national regulator:
Nigeria Data Protection Commission (NDPC)
Plot 1070, Zone A07, Wuse II, Abuja, Nigeria
🌐 Website: https://ndpc.gov.ng
📧 Email: info@ndpc.gov.ng