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SINIMAX PRIVACY STATEMENT

This Privacy Statement explains how Sinimax Limited (“Sinimax”, “we”, “our”, or “us”) collects, uses, discloses, and protects your personal information when you access or interact with the Sinimax streaming platform, including our website, applications, digital content services, and any other interfaces through which the Sinimax Service is made available (collectively, the “Sinimax Service”).

This Privacy Statement also explains the rights you have in relation to your personal data and how you may exercise those rights under applicable data protection laws, including the Nigeria Data Protection Act (NDPA) 2023, as well as other relevant privacy laws that may apply depending on your location.

By accessing or using the Sinimax Service, you acknowledge that your personal information will be processed (collected, used and disclosed) while using Sinimax services as described in this Privacy Statement.

Certain features of the Sinimax Service may provide additional notices or privacy choices that supplement the information contained in this Privacy Statement. These supplemental disclosures should be read together with this Privacy Statement as they form part of our broader privacy framework.

Please note that this Privacy Statement is designed to be more easily navigated when accessed through a web browser, where full headings and sections are available for clarity and ease of understanding.

Sinimax is a culturally-rooted African streaming platform that provides licensed film and entertainment content to users across Nigeria and the global diaspora. As a digital media and technology company operating across multiple jurisdictions, we are committed to processing personal data lawfully, fairly, transparently, and securely in accordance with applicable data protection requirements worldwide.

CONTACTING US: Privacy Support and Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy, the processing of your personal information, or the exercise of your privacy rights, you may contact Sinimax through the details below.

In compliance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable data protection laws, Sinimax is committed to ensuring that personal data is processed lawfully, fairly, securely, and transparently. Users may exercise their rights to access, correct, update, restrict, object to, or request deletion of their personal information, subject to applicable legal obligations.

For privacy-related enquiries or requests, please contact:

Sinimax Privacy and Compliance Team
Email: privacy@sinimax.ng
Compliance: privacy@sinimax.ng
Support: support@sinimax.ng

For general account, subscription, technical support, or customer service enquiries, users may contact Sinimax through the official support channels available on the platform or website.

Where required, Sinimax may request verification of identity before processing privacy-related requests in order to protect the security and confidentiality of personal information.

If you believe your data has been processed contrary to applicable law, you may lodge a complaint with the relevant regulatory authority, including the Nigeria Data Protection Commission where applicable.

Section A: Our Collection, Use, and Disclosure of Personal Information

Categories of Personal Information We Collect

We collect and process the following categories of personal information about you in connection with your use of the Sinimax service. Our processing is based on applicable legal grounds, including your consent, contractual necessity, compliance with legal obligations, and our legitimate business interests.

1. Personal Identification Information
When you register for or interact with Sinimax, we collect personal details that help identify and secure your account. This may include your email address, username, and login credentials (such as passwords or authentication data for log in activities). Depending on your use of the service, we may also collect information such as your full name, phone number, residential or billing address, date of birth, bank details for payment purposes, gender, and any other identifiers that may be required or you voluntarily provide.

2. Payment and Transaction Information
When you subscribe to or make payments on Sinimax, we collect payment-related information necessary to process transactions and prevent fraud. This includes payment method details (such as card information or third-party payment provider tokens), billing address, transaction history, subscription details, refunds, and records of purchased or redeemed offers, promotions, or gift-based credits.

3. Subscription and Service Interaction Information
We collect information relating to your subscription status and engagement with Sinimax services. This includes your subscription plan, renewal history, service preferences, viewing or content access entitlements, saved items, watch-lists or favorites, and user-generated settings associated with your account or profile.

4. Usage and Behavioral Information
We collect information about how you interact with the Sinimax platform. This includes content you view or engage with, playback actions (such as play, pause, skip, or completion status), search queries, browsing activity within the service, interaction with features, and your general usage patterns (such as time spent on the platform, frequency of use, and navigation behaviour). Where applicable, we may also collect input data from interactive features such as voice commands or in-app engagement tools.

5. Device and Technical Information
We collect technical information from the devices you use to access Sinimax services. This may include device type (such as mobile phone, smart TV, computer, or tablet), operating system, browser type, device identifiers, IP address, network information, and mobile network data. We also collect diagnostic data such as crash reports, system activity, performance logs, timestamps, and connectivity information to ensure service stability and improve user experience.

6. Location and Network Information (Generalized)
We may derive approximate location information from your IP address or device settings to provide regional content, ensure security, and comply with licensing restrictions. We do not intentionally collect precise GPS location unless explicitly permitted by you for specific features.

7. Communication and Support Information
When you contact Sinimax customer support or engage with us through email, chat, social media, surveys, or feedback forms, we collect the content of your communications and any additional information you choose to provide. We also retain records of our responses and service-related correspondence for quality assurance, training, and dispute resolution purposes.

8. Marketing and Preference Information
Where permitted by law, we may collect information about your interaction with marketing communications from Sinimax, such as emails, push notifications, or promotional messages. This includes whether you open, click, or respond to such communications, as well as your preferences regarding content recommendations and marketing choices.

9. Aggregated and Inferred Information
We may generate or collect inferred data based on your use of Sinimax services. This may include content preferences, viewing trends, user segmentation, and aggregated behavioral insights. This data is used to improve personalization, service functionality, content recommendations, and platform performance. Such data does not directly identify you where it has been anonymized or aggregated.

Legal Compliance Notice (NDPA & Global Standards)

Sinimax processes personal data in accordance with applicable data protection laws, including the Nigeria Data Protection Act (NDPA 2023), the General Data Protection Regulation (GDPR) where applicable, and other relevant international privacy frameworks. We apply appropriate technical and organizational safeguards to ensure your personal data is processed lawfully, fairly, transparently, and securely.

Where We Collect Personal Information From

Sinimax collects personal information from a variety of sources in connection with the operation, improvement, protection, and delivery of our services. The categories of personal information collected depend on how you interact with the Sinimax platform, the services you use, and the permissions you provide.

1. Information You Provide Directly to Us
We collect personal information directly from you when you create or manage a Sinimax account, subscribe to our services, make purchases, contact customer support, participate in surveys, submit forms, or otherwise communicate with us.

Personal identification information

Account and profile information

Payment and transaction information

Subscription preferences

Communications and correspondence

Any other information you voluntarily choose to provide to Sinimax

2. Information Collected Automatically Through Use of the Sinimax Service
When you access or use Sinimax services, we automatically collect certain technical, usage, and interaction data through our systems and technologies.

Device and browser information

IP address and approximate location data

Log-in activity and authentication records

Viewing, browsing, and search activity

Playback interactions and content engagement

App usage statistics and diagnostics

Cookies technologies

Network and performance information

This information helps us maintain security, personalize user experience, improve service functionality, monitor performance, prevent fraud, and comply with legal and regulatory obligations.

3. Information from Business Partners and Integrated Services
We may receive personal information from third parties whose products or services are used in connection with Sinimax (“Partners”). The nature of the information shared depends on your relationship with those Partners and the services involved.

Our Partners may include:

Payment processors and financial institutions

Telecommunications and internet service providers

Smart TV, mobile device, and streaming device manufacturers

App marketplaces and distribution platforms

Authentication and identity verification providers

Content distribution, licensing, or media partners

Sinimax only processes such information in accordance with applicable data protection laws and contractual safeguards.

4. Information from Service Providers and Vendors
We engage trusted third-party vendors, contractors, and service providers to support the operation of the Sinimax platform and related services. These providers may collect or process personal information on our behalf under strict confidentiality and data protection obligations.

5. Information from Marketing, Advertising, and Analytics Partners
Where permitted by applicable law, Sinimax may receive information from advertising, marketing, analytics, and audience measurement partners to improve our services, understand user engagement, and support promotional activities. Where required by law, Sinimax obtains appropriate consent before processing personal information for personalized advertising or related analytics activities.

6. Information from Social Media Platforms and Public Sources
We may collect information from publicly available sources and third-party platforms where legally permitted. Any such collection and use will be carried out in accordance with applicable privacy and data protection laws.

7. Information from Customer Support and Community Platforms
Where Sinimax provides community forums, support portals, help desks, or interactive support channels, we may collect information submitted through those services, including support requests, feedback, complaints, troubleshooting details, and communications with our representatives.

Global Privacy and Data Protection Compliance

Sinimax processes personal information in accordance with applicable privacy and data protection laws, including the Nigeria Data Protection Act (NDPA 2023), the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA) where applicable, and other relevant international privacy frameworks.

How We Use Your Personal Information

Sinimax uses your personal information to operate, provide, maintain, improve, secure, and promote our services in accordance with applicable data protection and privacy laws.

1. To Provide and Personalize the Sinimax Service
We use personal information to provide access to the Sinimax platform and deliver personalized entertainment experiences tailored to your preferences and interactions with our services.

Creating and managing your account

Authenticating users and maintaining account security

Providing access to content, subscriptions, and platform features

Generating personalized recommendations and curated content selections

Customizing the layout, language, and functionality of the service

Remembering viewing history, watchlists, saved preferences, and user settings

Localizing content and services based on your region or jurisdiction

2. To Operate, Administer, and Support Our Business

Processing payments, subscriptions, renewals, and refunds

Managing promotional offers, credits, and gift-based services

Providing customer support and responding to enquiries or complaints

Facilitating password recovery and account verification

Sending transactional or service-related communications

Troubleshooting technical issues and maintaining platform performance

Managing user requests and administrative functions

Monitoring compliance with our Terms of Use and internal policies

3. To Improve, Develop, and Analyze Our Services

Analyzing user engagement and viewing trends

Improving recommendation systems and content delivery

Developing new products, services, and platform features

Conducting internal research, analytics, testing, and quality assurance

Measuring audience engagement and platform performance

Processing survey responses and feedback

Improving accessibility, usability, and operational efficiency

4. To Facilitate Integrations with Partners and Third-Party Services

Enabling account activation through partner platforms

Supporting bundled subscriptions or promotional partnerships

Allowing access through supported devices or ecosystems

Synchronizing authentication and service access

Administering co-branded services or campaigns

Facilitating lawful content distribution arrangements

5. To Send Marketing, Promotional, and Informational Communications
Where permitted by applicable law, Sinimax may use personal information to send updates, newsletters, promotional offers, platform announcements, service updates, and information about new content, products, or features. You may opt out of marketing communications at any time through your account settings, unsubscribe links, or other mechanisms provided by Sinimax, subject to applicable legal requirements.

6. To Deliver and Measure Advertising and Promotional Content
Where Sinimax provides advertising-supported services, we may process personal information to deliver, manage, personalize, analyze, and measure advertisements and promotional campaigns. Sinimax complies with applicable advertising, cookie, and privacy regulations, including consent obligations under relevant data protection laws.

7. For Security, Fraud Prevention, and Platform Integrity

Detecting and preventing unauthorized access or account misuse

Monitoring suspicious or fraudulent transactions

Securing systems, applications, and infrastructure

Enforcing community standards and acceptable use policies

Investigating technical incidents or policy violations

Protecting the rights, safety, and property of Sinimax and its users

8. To Comply with Legal Obligations and Enforce Our Rights

Complying with tax, financial, consumer protection, or regulatory obligations

Responding to lawful requests from public authorities

Enforcing our Terms of Use, contractual rights, and platform policies

Resolving disputes and managing legal claims

Maintaining legally required records

Protecting against activities that may threaten the safety, rights, or integrity of Sinimax, our users, or third parties

Lawful Basis for Processing Personal Information

Where required under applicable law, including the Nigeria Data Protection Act (NDPA 2023), the General Data Protection Regulation (GDPR), and similar international privacy laws, Sinimax processes personal information on one or more lawful bases, including:

Your consent

Performance of a contract

Compliance with legal obligations

Protection of vital interests

Public interest obligations

Legitimate business interests that are not overridden by your fundamental rights and freedoms

Who We Disclose Personal Information To

Sinimax may disclose personal information to selected third parties where necessary for the operation, delivery, security, improvement, and lawful administration of our services. We do not sell personal information in a manner prohibited by applicable law.

1. Sinimax Group Companies and Affiliates
We may share personal information within the Sinimax group of companies, subsidiaries, affiliated entities, and operational divisions where necessary to support the provision and administration of our services globally.

2. Service Providers and Vendors
Sinimax engages trusted third-party service providers, contractors, consultants, and vendors to perform services on our behalf or assist in delivering the Sinimax platform and related services.

3. Business Partners and Integrated Platforms
Where you access Sinimax through a third-party platform, telecommunications provider, smart device manufacturer, payment partner, app marketplace, or other integrated service provider, we may share certain personal information with such parties as necessary to support the relevant integration or business relationship.

4. Marketing, Advertising, and Analytics Providers
Sinimax may disclose limited personal information to advertising, analytics, audience measurement, and marketing partners to support lawful promotional, advertising, and business intelligence activities.

5. Promotional Campaigns, Events, and Collaborations
Sinimax may collaborate with sponsors, promotional partners, content providers, or other third parties in connection with campaigns, events, contests, offers, loyalty programs, or co-branded services.

6. Corporate Transactions and Business Transfers
In the event of a merger, acquisition, restructuring, financing transaction, reorganization, dissolution, sale of assets, or other corporate transaction involving Sinimax, personal information may be disclosed or transferred as part of the transaction process.

7. Safety, Security, Fraud Prevention, and Rights Protection
Sinimax may disclose personal information where reasonably necessary to detect, investigate, or prevent fraud, abuse, unauthorized access, or unlawful activities, and to protect the safety, rights, property, or security of users, employees, partners, or the public.

8. Compliance with Legal and Regulatory Obligations
Sinimax may disclose personal information where required or permitted by applicable law, regulation, legal process, court order, governmental request, or regulatory directive.

9. International Data Transfers
As a global platform, Sinimax may transfer personal information across national borders and jurisdictions where necessary for the operation of our business and delivery of services. Sinimax takes reasonable steps to ensure that personal information transferred internationally receives an adequate level of protection consistent with applicable privacy and data protection laws.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Sinimax operates globally and may process, store, or transfer personal information across multiple countries and jurisdictions where Sinimax, its affiliates, service providers, partners, contractors, or infrastructure providers operate.

As a result, when you access or use the Sinimax service, your personal information may be transferred to, processed in, or accessed from countries outside your country of residence, including countries that may have data protection laws different from those applicable in your jurisdiction.

Where Sinimax transfers personal information internationally, we implement appropriate safeguards and measures designed to ensure that such transfers comply with applicable privacy and data protection laws, including the Nigeria Data Protection Act (NDPA 2023), the General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA/CPRA) where applicable, and other relevant international privacy and cyber security frameworks.

These safeguards may include:

Data transfer agreements and standard contractual clauses

Intra-group data protection arrangements

Encryption and technical security controls

Access control and authentication procedures

Data minimization and confidentiality obligations

Vendor and third-party due diligence processes

Legal and operational measures designed to challenge unlawful or disproportionate governmental access requests where permitted by law

Supplemental Privacy Disclosures

Certain Sinimax services, products, applications, interactive experiences, promotions, live events, advertising-supported services, or region-specific features may be subject to supplemental privacy disclosures, notices, or terms. Such supplemental disclosures form part of this Privacy Policy and should be read together with this document.

Section B: Your Rights and Controls

Your Privacy Rights

Subject to applicable law and verification requirements, you may have certain rights regarding your personal information and how Sinimax processes it.

1. Right to Access, Correct, Update, or Delete Personal Information
You may request confirmation regarding whether Sinimax processes your personal information and request access to, correction of, or deletion of certain personal information held by us. Sinimax may retain certain information where required or permitted by applicable law.

2. Right to Data Portability
Where applicable law provides, you may request a copy of certain personal information in a structured, commonly used, and machine-readable format, and may request that such information be transferred to another service provider where technically feasible.

3. Right to Object, Restrict Processing, or Withdraw Consent
You may object to certain forms of processing or request restrictions on how your personal information is processed. Where Sinimax relies on consent as the legal basis for processing, you may withdraw your consent at any time.

4. Right to Lodge a Complaint
You may have the right to submit complaints to a relevant data protection authority, supervisory authority, or regulatory body regarding Sinimax's processing of your personal information. However, we encourage users to first contact Sinimax directly so we may attempt to resolve concerns promptly and efficiently.

5. Rights Related to Automated Decision-Making
Where applicable law provides, you may have the right not to be subject solely to automated decision-making processes that produce legal or similarly significant effects concerning you.

6. Exercising Your Rights
You may exercise applicable privacy rights through your Sinimax account settings, designated privacy tools, or by contacting our Privacy Office or Data Protection Officer at privacy@sinimax.ng. Sinimax may request verification information before processing certain requests to protect user privacy and platform security.

Communication and Marketing Preferences

Email and SMS Communication
You may manage your communication preferences through your account settings or by using unsubscribe mechanisms provided in marketing communications. Even where you opt out of promotional communications, Sinimax may still send essential transactional or service-related communications relating to account activity, subscriptions and billing, security notifications, legal notices, and operational updates.

Push Notifications
Sinimax may send push notifications through mobile applications, smart devices, browsers, or supported platforms in accordance with your device or account settings. You may disable push notifications through device settings, browser preferences, or relevant notification settings within the Sinimax service.

Personalized Marketing and Matched Identifier Technologies
Sinimax may use privacy-enhancing technologies such as pseudonymization or hashed identifiers to deliver marketing communications on third-party platforms where permitted by law. You may manage applicable advertising and personalization preferences through your account privacy settings or device privacy controls.

Advertising Choices
Where Sinimax provides advertising-supported services, users may have options to manage advertising preferences, including behavioral advertising settings, cookie preferences, personalized advertisement controls, and device advertising identifier settings. If personalized advertising is disabled, you may still receive non-personalized advertisements. Sinimax does not knowingly engage in behavioral advertising directed toward children or users identified as minors under applicable law.

Cookie and Tracking Technology Choices
Sinimax and authorized third parties may use cookies, software development kits (SDKs), pixel tags, browser storage, device identifiers, and similar technologies to provide and secure the service, remember preferences and settings, improve functionality and performance, analyze traffic and engagement, personalize experiences, and support lawful advertising and marketing activities. Disabling certain technologies may affect the availability or functionality of parts of the Sinimax service.

Section C: Access to Accounts and Profiles

Account Sharing and Household Access
If you allow others to access your Sinimax account, those individuals may be able to view or interact with profile information, viewing activity, saved preferences, watchlists and recommendations, subscription details, and certain account-related settings. You are responsible for maintaining the confidentiality and security of your account credentials and ensuring that authorized users understand this Privacy Policy and applicable Terms of Use.

Profiles and Personalized Experiences
Sinimax may provide profile functionality that enables individualized experiences within a shared account environment, including personalized recommendations, separate watch histories, viewing preferences, saved content, parental control settings, and individualized interactions with the service.

Parental Controls and Minor Protections
Sinimax may provide parental control features, profile restrictions, content limitations, PIN protections, and other family-oriented safeguards designed to help parents and guardians manage minors' access to content and platform features.

Account Security and Device Access
Users are responsible for maintaining secure passwords and login credentials, restricting unauthorized access to devices, logging out from shared or public devices, and promptly reporting suspected unauthorized access or security incidents. Sinimax may provide account management features allowing users to review connected devices, terminate active sessions, sign out from devices remotely, and manage login and authentication preferences.

Section D: Cookies and Similar Technologies

Sinimax, its service providers, analytics providers, advertising partners, and authorized third parties may use cookies and similar technologies to collect information relating to your interactions with the service.

These technologies may include cookies, browser storage technologies, software development kits (SDKs), web beacons and pixel tags, advertising identifiers, hashed identifiers, session tokens, and device or network identifiers.

These technologies help Sinimax to authenticate users, maintain platform functionality, improve service performance, personalize content and recommendations, measure engagement and analytics, detect fraud and abuse, support security operations, and provide lawful marketing and advertising services. Sinimax may also use pseudonymized or aggregated identifiers designed to reduce direct identification risks while supporting analytics and advertising functionality.

Section E: Other Important Privacy Disclosures

Sharing and Social Features
Certain Sinimax features may permit users to share content, invitations, recommendations, reviews, watch activity, or interactive experiences through messaging services, social media platforms, integrated third-party applications, or collaborative viewing or gaming features. Such third-party platforms operate independently and are governed by their own terms, privacy notices, and policies.

Security Measures
Sinimax maintains administrative, technical, organizational, and physical safeguards designed to protect personal information against unauthorized access, misuse, disclosure, alteration, destruction, or loss. While Sinimax strives to implement appropriate security measures, no system or transmission method can be guaranteed to be completely secure.

Retention of Personal Information
Sinimax retains personal information only for as long as reasonably necessary to provide and maintain services, fulfill contractual obligations, comply with legal and regulatory requirements, resolve disputes, enforce agreements and policies, maintain security and fraud prevention systems, and support legitimate business and operational purposes. Where personal information is no longer required, Sinimax takes reasonable measures to securely delete, anonymize, or de-identify such information.

Third-Party Platforms, Websites, and Services
The Sinimax service may contain links to or integration with third-party platforms, websites, devices, services, applications, or advertising networks. These third parties operate independently and maintain their own privacy notices, terms, and practices. Sinimax is not responsible for the privacy, security, or data handling practices of third-party services.

Children and Minors
Sinimax services are intended for users who have reached the age of majority in their jurisdiction unless otherwise permitted under applicable law and supervised by a parent or legal guardian. Where required by applicable law, Sinimax implements age-appropriate protections, limits behavioral advertising directed at minors, provides parental control tools, and applies additional safeguards relating to the processing of minors' personal information.

Changes to This Privacy Policy
Sinimax may update or modify this Privacy Policy from time to time to reflect legal or regulatory developments, technological changes, operational or business updates, security requirements, or modifications to Sinimax services and practices. Where required by law, Sinimax will provide notice of material changes through appropriate channels, which may include website notices, in-service notifications, email communications, or account alerts. Your continued use of the Sinimax service following the effective date of an updated Privacy Policy constitutes acknowledgment of the updated terms to the extent permitted by applicable law.

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