COOKIE POLICY

1. INTRODUCTION AND LEGAL STATUS

This Cookie Policy ("Policy") explains how House Number Five Ltd, a company incorporated under the laws of the Federal Republic of Nigeria ("the Company", "we", "us", or "our"), uses cookies and similar tracking technologies on its websites, portals, platforms, applications, and digital services (collectively, the "Platforms").

This Policy is drafted to comply with:

• The EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679);
• The UK GDPR;
• The ePrivacy Directive (2002/58/EC);
• The Nigeria Data Protection Act, 2023 (NDPA); and
• Applicable international data protection principles.

This Policy forms an integral part of the Company's Privacy Policy and Terms and Conditions. Where inconsistencies arise, provisions most protective of the Company shall prevail to the maximum extent permitted by law.

2. WHAT ARE COOKIES?

Cookies are small text files placed on your device when you visit a website. They enable the Platform to recognize your device, store preferences, enhance functionality, analyse usage, and deliver secure and efficient services.

Cookies may be:

• Session cookies (deleted when you close your browser);
• Persistent cookies (stored until deleted or expired);
• First-party cookies (set by the Company);
• Third-party cookies (set by external service providers).

3. TYPES OF COOKIES WE USE

3.1 Strictly Necessary Cookies

These cookies are essential for the operation, security, and integrity of the Platforms. They enable core functions such as authentication, fraud prevention, load balancing, and system administration.

Legal basis: Legitimate interest and contractual necessity. These cookies do not require user consent.

3.2 Functional Cookies

Functional cookies allow the Platform to remember choices you make, such as language preferences and region settings, to provide enhanced and personalised features.

Legal basis: Consent or legitimate interest, depending on jurisdiction.

3.3 Performance and Analytics Cookies

These cookies collect aggregated and anonymised information on how users interact with the Platform, including page visits, traffic sources, and performance metrics.

They help us improve functionality, stability, and user experience.

Legal basis: Consent.

3.4 Targeting and Marketing Cookies

These cookies track browsing habits to deliver relevant content, measure marketing effectiveness, and limit repeated advertisements.

The Company may use third-party providers for these purposes.

Legal basis: Explicit consent.

4. THIRD-PARTY COOKIES

The Company may permit third-party service providers (including analytics, hosting, security, and marketing partners) to place cookies on the Platforms.

We do not control third-party cookies and disclaim responsibility for their content, policies, or practices. Users are advised to review third-party cookie policies independently.

5. CONSENT MANAGEMENT

Upon first visit, users are presented with a cookie consent banner allowing them to:

• Accept all cookies;
• Reject non-essential cookies; or
• Customise cookie preferences.

Consent may be withdrawn at any time through browser settings or the Platform's cookie management tool, without affecting the lawfulness of processing prior to withdrawal.

6. COOKIE RETENTION PERIODS

Cookies are retained only for as long as necessary to fulfil their purposes, subject to legal, regulatory, and operational requirements.

Retention periods vary depending on cookie type and function.

7. USER CONTROL AND OPT-OUT

Users may control cookies through:

• Browser settings;
• Device preferences;
• Third-party opt-out tools.

Disabling cookies may affect Platform functionality. The Company shall not be liable for any loss of functionality arising from user-imposed restrictions.

8. CROSS-BORDER DATA TRANSFERS

Where cookies involve the transfer of personal data outside Nigeria, the EU, or the UK, such transfers are safeguarded through lawful mechanisms, including adequacy decisions, contractual safeguards, or equivalent protections.

9. LIMITATION OF LIABILITY

To the fullest extent permitted by law:

• The Company disclaims all liability arising from third-party cookies;
• The Company shall not be liable for indirect, incidental, or consequential losses arising from cookie usage;
• The Company's total liability shall not exceed statutory minimums where applicable.

10. CHANGES TO THIS POLICY

The Company reserves the right to amend this Policy at any time to reflect legal, technological, or operational changes.

Continued use of the Platforms constitutes acceptance of the updated Policy.

11. CONTACT INFORMATION

For questions relating to this Cookie Policy, please contact: