Privacy Policy

1. Introduction and Scope

This Privacy Policy (the “Policy”) sets out the basis on which TAOHS Media House (“TAOHS”, “we”, “us” or “our”) collects, uses, stores, discloses and otherwise processes information relating to identified or identifiable natural persons (“Personal Data”) in connection with The Art of High Society website (the “Website”) and the services, communications and other activities made available through or in connection with the Website (collectively, the “Services”).

TAOHS Media House is the data controller in respect of the Personal Data processed in connection with the Website and Services, except where otherwise expressly stated.

This Policy applies, as applicable, to persons who access or use the Website, subscribe to TAOHS newsletters or communications, submit enquiries through the Website, engage with TAOHS in connection with partnerships or collaborations, or otherwise provide Personal Data to TAOHS through the Services.

TAOHS processes Personal Data in accordance with the Nigeria Data Protection Act 2023, regulations and guidance issued by the Nigeria Data Protection Commission (“NDPC”), and such other data protection and privacy laws as may be applicable to the relevant processing activity.

This Policy should be read together with any additional privacy notice or information that TAOHS may provide in connection with a particular service or processing activity.

2. Personal Data We Collect

TAOHS may collect Personal Data directly from you, automatically through your interaction with the Website, or through service providers acting on our behalf.

2.1 Personal Data Provided Directly by You

Depending on the nature of your interaction with TAOHS, we may collect:

• your first and last name;
• email address;
• telephone number;
• country of residence or location;
• areas of interest;
• newsletter subscription preferences;
• information contained in correspondence, enquiries or other communications submitted to TAOHS; and
• such other information as you elect to provide to us.

Where you submit an enquiry through the Work With Us section of the Website, this may include your name, email address, telephone number, country, selected area of interest and the contents of your message.

TAOHS does not intentionally solicit Special Categories of Personal Data through its general website forms. Users are requested not to provide such information unless it is strictly necessary for the purpose of the relevant communication.

2.2 Newsletter and Communications Data

Where you subscribe to a TAOHS newsletter or other electronic communication, we may collect and process your email address, subscription status and preferences and, where applicable, information concerning your interaction with our communications.

TAOHS currently uses Mailchimp for the management and distribution of certain electronic communications.

Where email engagement tracking is enabled, information may be generated concerning whether a communication has been opened and whether links contained within that communication have been accessed.

2.3 Technical and Usage Data

When you access or use the Website, certain technical and usage information may be processed automatically, including:

• pages and articles accessed;
• dates and times of access;
• referring sources;
• device and browser information; and
• information concerning interaction with Website content.

TAOHS currently uses Ghost's native analytics functionality for the purpose of measuring Website traffic and audience engagement.

Ghost's native web analytics are first-party and cookie-free and do not use persistent browser storage for the purpose of identifying visitors across separate sessions, browsers or devices.

Where a user accesses the Website as a logged-in member, certain activity may be associated with that user's member identifier and membership status.

3. Purposes and Lawful Bases of Processing

TAOHS processes Personal Data only where there is an appropriate lawful basis for doing so under applicable law.

Personal Data may be processed for the following purposes:

Purpose of Processing	Principal Lawful Basis
Provision and administration of newsletters and requested communications	Consent
Management of newsletter preferences and subscriptions	Consent and/or legitimate interests
Measurement and analysis of engagement with newsletters	Legitimate interests, subject to applicable law
Receipt, assessment and response to enquiries	Legitimate interests and/or steps taken at the request of the data subject
Management of partnership, collaboration and other business enquiries	Legitimate interests and/or steps taken at the request of the data subject
Operation, administration, maintenance and security of the Website	Legitimate interests
Analysis of Website traffic and audience engagement	Legitimate interests
Compliance with applicable legal and regulatory obligations	Legal obligation
Establishment, exercise or defence of legal claims	Legitimate interests and/or legal obligation

Where TAOHS relies upon consent as the lawful basis for processing, such consent may be withdrawn at any time. Withdrawal shall not affect the lawfulness of processing undertaken prior to withdrawal.

Where processing is undertaken on the basis of TAOHS's legitimate interests, TAOHS shall have regard to the nature of the processing and the rights, freedoms and reasonable expectations of the relevant data subject.

4. Newsletters and Direct Communications

Where you have subscribed to a TAOHS newsletter or otherwise consented to receive electronic communications from us, TAOHS may use your contact information to provide editorial updates, newsletters and other communications relating to TAOHS and its activities.

TAOHS currently uses Mailchimp as a third-party service provider for the administration and distribution of certain electronic communications. Personal Data relating to newsletter subscriptions may accordingly be processed by Mailchimp on behalf of TAOHS.

TAOHS may utilise email engagement functionality made available through Mailchimp to measure interactions with its communications, including email opens and link activity. Such information is used for the purposes of measuring audience engagement, evaluating the performance of communications and improving the relevance and quality of TAOHS content.

Users may withdraw their consent to marketing communications at any time by selecting the unsubscribe facility contained within the relevant communication or by contacting TAOHS at admin@theartofhighsociety.com.

Following an unsubscribe request, TAOHS may retain limited information to the extent reasonably necessary to record and give continuing effect to that request.

5. Website Analytics and Tracking Technologies

TAOHS uses Ghost's native analytics functionality to obtain aggregated and other information concerning Website traffic, audience growth and engagement with TAOHS content.

Ghost's native web analytics are first-party and cookie-free. TAOHS does not currently use Google Analytics, Meta Pixel or comparable third-party advertising or website analytics technologies.

Where a user accesses the Website as a logged-in member, certain engagement information may be associated with the relevant member identifier and membership status.

Email analytics undertaken in connection with TAOHS newsletters are separate from the Website analytics described above and may include technologies capable of recording email opens and link interactions.

Where TAOHS subsequently introduces non-essential cookies, advertising technologies or other tracking technologies requiring consent or additional notice under applicable law, TAOHS shall implement such notice and consent mechanisms as may be required.

6. Disclosure of Personal Data

TAOHS does not sell Personal Data.

TAOHS may disclose Personal Data, to the extent reasonably necessary and subject to applicable law, to:

• website hosting, content management and technology service providers;
• newsletter and communications service providers, including Mailchimp;
• professional advisers, including legal, accounting and other professional consultants;
• contractors and other service providers engaged in connection with the operation of TAOHS;
• governmental, regulatory, judicial or law-enforcement authorities where disclosure is required or permitted by law; and
• prospective purchasers, investors, successors or other relevant persons in connection with any actual or proposed restructuring, financing, merger, acquisition, sale or transfer of all or any material part of TAOHS or its assets.

Where a third party processes Personal Data on behalf of TAOHS, TAOHS shall take reasonable steps to ensure that such processing is subject to appropriate confidentiality, security and data protection obligations.

7. International Transfers of Personal Data

Certain service providers engaged by TAOHS may process or store Personal Data outside Nigeria.

In particular, Personal Data processed in connection with TAOHS newsletters may be transferred to or processed by Mailchimp, its affiliates or its service providers in jurisdictions outside Nigeria, including the United States.

TAOHS's website infrastructure and technology providers may similarly process or store information outside Nigeria depending upon the applicable hosting arrangements.

Where Personal Data is transferred outside Nigeria, TAOHS shall take such measures as are required under applicable data protection law to ensure that the transfer is subject to an appropriate legal basis and, where required, appropriate safeguards.

Such safeguards may include contractual protections, recognised transfer mechanisms or such other measures as may be permitted under applicable law.

8. Retention of Personal Data

TAOHS shall retain Personal Data only for so long as is reasonably necessary to fulfil the purposes for which it was collected or subsequently processed and to satisfy applicable legal, regulatory, accounting, operational and reporting requirements.

In determining the appropriate retention period, TAOHS may have regard to the nature and sensitivity of the Personal Data, the purposes of processing, the duration of the relationship with the relevant data subject, applicable statutory or regulatory requirements and the need to establish, exercise or defend legal claims.

Without limiting the foregoing:

• newsletter subscription information may be retained for the duration of the relevant subscription;
• following an unsubscribe request, limited information may be retained for the purpose of maintaining a suppression record and giving continuing effect to the request;
• enquiries and correspondence may be retained for so long as reasonably necessary to address the relevant enquiry, administer any resulting relationship and maintain appropriate business records; and
• information required for legal, regulatory or dispute-resolution purposes may be retained for such additional period as is reasonably necessary for those purposes.

Upon expiry of the applicable retention period, Personal Data shall, as appropriate, be securely deleted, anonymised or otherwise disposed of.

9. Security of Personal Data

TAOHS implements reasonable and appropriate technical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and other forms of unlawful processing.

TAOHS also takes reasonable steps to engage service providers that maintain security measures appropriate to the nature of the Personal Data processed on its behalf.

Notwithstanding the foregoing, no method of electronic transmission or storage is capable of providing absolute security.

In the event of a Personal Data breach, TAOHS shall take such investigative, remedial and notification measures as may be required under applicable law.

10. Rights of Data Subjects

Subject to applicable law and any relevant statutory limitations or exemptions, a data subject may have the right to:

• obtain information concerning the processing of his or her Personal Data;
• request access to Personal Data held by TAOHS;
• request rectification of inaccurate or incomplete Personal Data;
• request erasure of Personal Data in circumstances prescribed by law;
• object to certain processing;
• request restriction of processing where applicable;
• withdraw consent at any time where processing is based upon consent;
• request portability of Personal Data where applicable;
• exercise applicable rights in relation to automated decision-making; and
• lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority.

Requests concerning the exercise of data protection rights may be submitted to:

admin@theartofhighsociety.com

TAOHS may request such information as is reasonably necessary to verify the identity and authority of the person making the request.

The exercise of data protection rights is subject to applicable law, including any lawful grounds upon which TAOHS may retain or continue to process Personal Data notwithstanding a request.

11. Personal Data Relating to Children

The Website is a media and cultural publication intended for a general audience and is not specifically directed at children.

TAOHS does not knowingly solicit Personal Data from children in circumstances in which parental or guardian consent is required by applicable law.

Where TAOHS becomes aware that Personal Data relating to a child has been collected in circumstances requiring consent that was not validly obtained, TAOHS shall take reasonable steps to delete or otherwise lawfully address such Personal Data.

Concerns relating to Personal Data submitted by a child may be directed to admin@theartofhighsociety.com.

12. Third-Party Websites and Services

The Website may contain links to, or content and functionality provided by, websites, social media platforms and other services operated by third parties.

Such third parties may process Personal Data independently of TAOHS and in accordance with their own privacy policies and terms.

Except to the extent required by applicable law, TAOHS is not responsible for the privacy practices of third-party websites or services that it does not own or control. Users are encouraged to review the applicable privacy information before providing Personal Data to such third parties.

13. Editorial, Journalistic and Public-Interest Processing

As a media and cultural publication, TAOHS produces and publishes editorial content concerning individuals, organisations, artists, creators, brands, events and matters of cultural or public interest.

Personal Data contained in or processed for the purposes of journalistic, artistic, literary or editorial activities may be subject to legal provisions, exemptions and considerations different from those applicable to Personal Data collected directly from users of the Website.

Nothing in this Policy is intended to limit any lawful journalistic, artistic, literary or editorial activity undertaken by TAOHS or any right, exemption, defence or other protection available under applicable law.

14. Future Membership and Subscription Services

TAOHS may introduce membership and paid subscription services in the future.

Such services are not presently addressed as active processing activities under this Policy. Prior to or in connection with their introduction, TAOHS may revise this Policy or provide supplementary privacy information setting out, as applicable, the categories of Personal Data processed, purposes and lawful bases of processing, payment and subscription service providers, applicable retention periods and relevant international data transfers.

15. Amendments to this Policy

TAOHS may amend this Policy from time to time to reflect changes in its operations, Services, technology, legal obligations or regulatory requirements.

Any revised Policy shall be published on the Website and the “Last Updated” date shall be amended accordingly.

Where required by applicable law, TAOHS shall provide additional notice of any material change to the manner in which Personal Data is processed.

16. Complaints

Any question or complaint concerning TAOHS's processing of Personal Data should, in the first instance, be directed to:

admin@theartofhighsociety.com

Nothing in this Policy affects a data subject's right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another competent supervisory authority.

17. Contact Information

For questions concerning this Policy, the exercise of data protection rights or TAOHS's processing of Personal Data, please contact:

TAOHS Media House
Nigeria
Email: admin@theartofhighsociety.com