1. INTRODUCTION

Disone Technologies (“we,” “us,” or “our”) is a business duly incorporated under the laws of the Federal Republic of Nigeria. We are committed to protecting the privacy and personal data of all individuals who interact with our website and digital platforms, in full compliance with the Nigeria Data Protection Act, 2023 (NDPA) and the Nigeria Data Protection General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC).

This Cookie Policy explains what cookies are, the categories of cookies we deploy on our website located at https://www.disone.app/ (the “Website”), the purposes for which we use them, the legal basis for their use, and how you can manage or withdraw your cookie preferences at any time. This Policy should be read together with our Privacy Policy, which sets out the broader framework governing our collection and processing of your personal data.

2. WHAT ARE COOKIES?

Cookies are small text files that are placed on your device including your computer, tablet, or mobile phone when you visit a website. They are widely used to make websites function efficiently, to enhance user experience, and to provide information to the operators of the website. Cookies may be set by the website you are visiting (first-party cookies) or by third parties whose services are embedded within the website (third-party cookies).

Cookies can be either:

• Session cookies– temporary files that are deleted from your device when you close your browser; or
• Persistent cookies– files that remain on your device for a set period of time or until you delete them manually.

In addition to cookies, we may also use similar tracking technologies such as web beacons, pixels, and local storage objects. References to “cookies” in this Policy include all such similar technologies unless otherwise stated.

3. LEGAL BASIS FOR THE USE OF COOKIES

We process personal data collected through cookies in accordance with the NDPA 2023 and the NDP GAID 2025. The lawful basis we rely upon for each category of cookie is set out in the Cookie Table in Section 5 of this Policy. In summary:

• Strictly necessary cookies are deployed on the basis of our legitimate interest in ensuring the proper technical functioning of our website and, where applicable, on the basis of contractual necessity.
• Functional cookies are deployed on the basis of our legitimate interest in providing an enhanced and personalised user experience.
• Analytics cookies are deployed on the basis of your consent, freely given through our cookie consent banner, in accordance with Section 25 of the NDPA.
• Marketing and advertising cookies are deployed solely on the basis of your explicit consent, obtained prior to the placement of such cookies on your device.

Where we rely on consent as our lawful basis, your consent is obtained through our cookie consent banner displayed on your first visit to our website. You have the right to withdraw your consent at any time without detriment, by using the cookie preference settings available on our Website or through the methods described in Section 7 of this Policy.

4. CATEGORIES OF COOKIES WE USE

We deploy the following categories of cookies on our website:

4.1 Strictly Necessary Cookies

These cookies are essential for the basic functioning of our website and cannot be switched off. They are typically set in response to actions you take, such as logging in, completing a form, or setting your privacy preferences. Without these cookies, certain features of the Website would not be available. These cookies do not store any personally identifiable information beyond what is strictly required for the functioning of the Website.

4.2 Functional Cookies

These cookies enable the Website to remember your preferences and choices such as your language settings, region, or previously entered information in order to provide a more personalised experience. The information these cookies collect may be anonymised and they do not track your activity on other websites.

4.3 Analytics and Performance Cookies

These cookies collect information about how visitors interact with our website, including which pages are visited most frequently, the time spent on each page, and any error messages encountered. The information collected is aggregated and used solely to improve the performance and functionality of our website. We rely on your consent before placing these cookies on your device.

4.4 Marketing and Advertising Cookies

These cookies are used to deliver advertisements and promotional content that are relevant to you and your interests, based on your browsing behaviour on our website and across other websites. They are also used to measure the effectiveness of our marketing campaigns. These cookies are only placed on your device with your explicit prior consent. You may withdraw your consent at any time.

4.5 Security Cookies

Given the nature of our business as a provider of customised security solutions, we deploy certain cookies that are specifically designed to support the security and integrity of our website and to protect our users. These include cookies used for fraud detection, authentication, and the prevention of unauthorised access. These cookies are strictly necessary and are deployed on the basis of our legitimate interest in maintaining the security of our digital infrastructure and protecting the personal data of our users.

5. COOKIE TABLE

The following table sets out the specific cookies deployed on our website, their purposes, and their retention periods:

Cookie Name	Type	Provider	Purpose	Lawful Basis	Retention Period
[Cookie Name]	Strictly Necessary	First Party	Session management and security authentication	Legitimate Interest / Contractual Necessity	Session
[Cookie Name]	Strictly Necessary	First Party	Fraud detection and prevention	Legitimate Interest	12 months
[Cookie Name]	Functional	First Party	Remembering user preferences and language settings	Legitimate Interest	6 months
[Cookie Name]	Analytics	Third Party (e.g. Google Analytics)	Website traffic and performance analysis	Consent	24 months
[Cookie Name]	Marketing	Third Party	Targeted advertising and campaign measurement	Consent	12 months
[Cookie Name]	Security	First Party	Detection of unauthorised access attempts	Legitimate Interest	30 days

Note: This table will be updated whenever new cookies are introduced or existing cookies are modified. We recommend that you check this Policy periodically for updates.

6. THIRD-PARTY COOKIES

Some cookies on our website are placed by third-party service providers whose services we have integrated into our website, including but not limited to analytics providers, advertising networks, and social media platforms. We do not control the operation of third-party cookies and are not responsible for the privacy practices of third-party providers. We encourage you to review the privacy and cookie policies of any third-party providers whose cookies may be active on your device.

Where third-party cookies involve the transfer of your personal data outside Nigeria, such transfers shall only be carried out in accordance with the conditions for cross-border data transfers prescribed under Section 43 of the NDPA and the applicable provisions of the GAID, including the existence of an adequacy determination or the implementation of appropriate safeguards.

7. MANAGING YOUR COOKIE PREFERENCES

You have full control over the cookies placed on your device, subject to the exception of strictly necessary cookies, which are essential for the functioning of the Website and cannot be disabled. You may manage your cookie preferences through any of the following means:

7.1 Cookie Consent Banner

On your first visit to our website, you will be presented with a cookie consent banner through which you may accept or decline specific categories of cookies. Your preferences will be saved and applied on all subsequent visits. You may update your preferences at any time by clicking the “Cookie Settings” link available at the footer of our website.

7.2 Browser Settings

Most internet browsers allow you to control cookies through their settings. You may set your browser to refuse all or certain categories of cookies, or to alert you when cookies are being placed on your device. Please note that disabling certain cookies may affect the functionality of our website. For guidance on managing cookies through your browser, please refer to your browser’s help documentation.

7.3 Third-Party Opt-Out Tools

For cookies placed by third-party providers, you may also use the opt-out tools provided by those providers directly. Information on how to opt out of specific third-party cookies is available on the relevant providers’ websites.

8. RETENTION OF COOKIE DATA

Personal data collected through cookies is retained only for as long as is necessary for the purpose for which it was collected, in accordance with the storage limitation principle under the NDPA and our internal data retention policy. The specific retention period applicable to each cookie is set out in the Cookie Table in Section 5 of this Policy.

Upon expiry of the applicable retention period, personal data collected through cookies will be securely deleted or anonymised in accordance with our data retention and disposal procedures.

9. YOUR RIGHTS AS A DATA SUBJECT

In relation to the personal data we collect through cookies, you have the following rights under the NDPA 2023:

• Right of Access: You have the right to request confirmation of whether we process your personal data and to obtain a copy of such data.
• Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data held about you.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn your consent and no other lawful basis applies.
• Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interest as our lawful basis.
• Right to Withdraw Consent: Where we rely on your consent as the lawful basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe that your personal data has been processed in a manner inconsistent with the NDPA.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 11 of this Policy.

10. UPDATES TO THIS POLICY

We reserve the right to update or amend this Cookie Policy from time to time to reflect changes in our cookie practices, applicable law, or regulatory guidance issued by the NDPC. Any material changes to this Policy will be communicated to you through a prominent notice on our website and, where appropriate, through direct communication. The date of the most recent revision will be indicated at the top of this Policy.

We encourage you to review this Policy periodically to stay informed of how we use cookies and how you can manage your preferences.

11. CONTACT US AND DATA PROTECTION OFFICER

If you have any questions, concerns, or requests relating to this Cookie Policy or the processing of your personal data through cookies, please contact our Data Protection Officer at the following details:

Data Protection Officer

Esther Ajogi

Disone Technologies

2, Anike Apena street, Mobolaji Bank Anthony Way, Lagos State, Nigeria

Email: esther.ajogi@gmail.com

Telephone: +234 816 744 9095

If you are not satisfied with our response, you have the right to escalate your complaint to the Nigeria Data Protection Commission (NDPC) at:

Nigeria Data Protection Commission (NDPC) Website: www.ndpc.gov.ng

This Cookie Policy is issued pursuant to the Nigeria Data Protection Act, 2023 and the Nigeria Data Protection General Application and Implementation Directive (GAID) and shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.