Privacy Policy

Effective Date: September 15, 2025.
This privacy policy describes Xhale Media Limited’s data practices, including the collection, use, and
sharing of data through Websites that link to this privacy policy, along with the choices and rights you have
to control those data practices.

WHO WE ARE
Websites that link to this privacy policy are operated by Xhale Media Limited (hereinafter referred to as
“Xhale”), located at Victoria Island, Lagos, Nigeria. As used in this policy, “Xhale,” “we,” and “our” refer to
this entity, which acts as a data controller and is responsible for the processing of personal data by the
Websites under applicable privacy and data protection laws.
Other entities in the Xhale Group of companies may receive or process data in connection with the
operation of the Websites, including XHALE Media (magazine), Xhale Music (NoLabel stars & City without
walls), and XHALE Communications, each of which is also located at aforementioned location in West
Africa. Where applicable, each of these entities separately makes the disclosures in this privacy policy.
Websites may be operated on behalf of clients, artists and/or partners who may process personal data in
connection with the Websites. In such cases, we will disclose the relevant third parties on the Websites
and/or at the point of data collection.

CONTACT US
Questions or comments about this privacy policy, our data practices, or requests regarding your privacy
rights may be submitted through our Privacy Request Form by clicking here. We are only able to respond
to requests related to our data practices through this form.

ALL NON-PRIVACY QUESTIONS: Please see this FAQ regarding how to contact Xhale with questions or
requests not related to our privacy practices or your privacy rights.
You may also contact XHALE’s Data Protection Officer by writing to Xhale (ATTN: “Data Protection Officer”)
using this email address: legal@xhaleng.com
INFORMATION WE COLLECT
In our operation of the website, we collect the following categories of data:
Category of information
What may be collected
How it is collected, where applicable
Information you choose to
provide via the website or
through other interactions with
XHALE, such as e-mail, social
 your name,
 country of residence,
 e-mail address,
 phone number,

Forms you fill out on our Website,
including subscribing to direct marketing,
creating
an
account,
searches,
uploading/downloading documents or
media, or linking a social media account;
media, SMS, telephone, or other
methods
 login information, including
certain social media profile
information if you login with a social
media account,
 gender,
 age or date of birth,
 payment card information,
 billing and/or shipping address,
 personal description,
 photographs, videos, or images,
 comments.
 Correspondence with us (e-mails,
phone transcripts or otherwise);
 Purchases or orders placed on
the Website;
 Participation in forums, chats, or other
social media functions on the Website;
 Entering a competition, promotion,
or survey;
 Reporting a problem on the Website or
requesting support.

Information collected through
your use of a Website
 IP address and network
information,
 location (based on IP lookup),
 user agent string including
browser and OS version,
 language and time zone,
 identifiers set by cookies or
similar tracking information (see
cookies disclosure below),
 unique device identifiers and
hardware version,
 page response times,
 download or content errors,
 page interaction information
(such as scrolling, clicks, and mouse
overs, length of visit, pages viewed),
 methods used to browse away
from the page.
Visiting our Website or interacting with us
Information collected from third
parties
 name or username,
 age or birthdate,
 address,
 phone number,
 gender,
 device OS,
 brand affinities,
 consumer profile category,
 media/music intent scores,
 media/music concert spend
category,
 music genre interests, etc.
Consistent with applicable laws, we may
match and supplement information you
provide, such as your email address or
phone number, with data held by third
party data providers or data brokers.

HOW YOUR INFORMATION MAY BE USED

We may use information we collect to:
 Respond requests and/or queries, including customer support queries,
 Fulfil orders, process payments, and provide order-related updates,
 Send requested marketing communications via email, SMS, or direct messages,
 Advertise our products or the products of third parties that we believe may be of interest,
 Create segments of users with similar features for ad targeting or seeding lookalike audiences,
 Operate, measure, and audit online advertisements,
 Build user profiles to assist us in understanding your interests, create marketing or advertising
segments, and predict likely sales, marketing, or advertising outcomes,
 Train AI or machine learning models that analyze or predict music preferences, sales, marketing, or
advertising outcomes,
 Personalize and improve our Websites, products, and services,
 Administer promotions, contests, or surveys,
 Operate and administer our Websites, including troubleshooting, data analysis, testing, research,
statistics, and other internal operations,
 Manage your access to our Websites, including notifying you of changes to the Websites,
 Analyze usage of our Websites,
 Secure our Websites and prevent fraud or other illegal activities,
 Resolve disputes and/or enforce our agreements,
 Comply with legal and regulatory obligations.
HOW YOUR INFORMATION MAY BE SHARED
In compliance with applicable laws, we may share information about you with third parties to facilitate
the uses described above, including:
 Our affiliates and joint venture partners that we have now or may have in the future,
 Our business partners, suppliers, agents, and sub-contractors who provide services on our behalf;
 Relevant XHALE artists and/or their representatives,
 With other users where you leave comments or otherwise contribute content to an Website,
 Advertisers, advertising networks and social networks,
 As part of an actual or potential corporate sale, merger, or acquisition, or other transfer of all or part
of XHALE,
 Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise
required by law, to protect our rights or the rights of third parties, or to protect the safety or security
of any person or entity, or
 With your consent or as otherwise disclosed at the time of data collection or sharing.
STORAGE AND RETENTION OF INFORMATION
We will retain the information we collect in accordance with applicable laws and as reasonably necessary
for our processing purposes set out under this privacy policy, including resolution of disputes,
enforcement of agreements, securing the Websites, and to comply with our legal obligations. When
personal data is no longer necessary for our purposes we will delete or de-identify the data.
We will also take steps to ensure that the information we collect is treated securely and in accordance
with this Privacy Policy. We have put in place technical and organisational procedures designed to
safeguard the information we collect.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will
do our best to protect the information we collect, we cannot guarantee its security.
CHILDREN
Our websites are not directed toward children (as defined by applicable law) nor does XHALE knowingly
collect information from children without parental consent except where in compliance with applicable
laws.
YOUR RIGHTS
You may have certain rights regarding our processing of personal data about you. These rights may include
access to, rectification, erasure, and/or portability of your personal data. You can exercise these rights by
contacting us as described in the “Contact” section. We may take steps to verify your identity before
completing your request. Our verification measures vary based on the risk to the individual and may
involve confirming access to the relevant email account, providing a government-issued ID or other
identification documents, or providing other account details or information that indicates a valid request.
You may also be entitled, in accordance with applicable law, to lodge a complaint with a supervisory
authority if you consider that our processing of your personal data infringes applicable law.
Specific information regarding rights related to data processing of Nigeria data and personal data about
citizens of Nigeria can be found in the Nigeria Data Privacy Act 2023.
Dispute Resolution
If you have any questions or complaints regarding XHALE’s handling of your personal information, please
contact/ email us at legal@xhaleng.com. We will respond promptly. If you are not satisfied with our
resolution of your privacy or data use complaint you may contact our external legal partners via email at
info@jmlegals.com. It may be possible, under certain conditions, for individuals to invoke binding
arbitration.
CHANGES TO OUR PRIVACY POLICY
Any material changes we may make to our privacy policy in the future will be posted here. Please check
back frequently to see any updates or changes to our privacy policy.

DIGITAL ADVERTISING
We use third party partners to enable targeted advertising on third-party social media platforms,
websites, and mobile websites. These companies collect information through our Websites to target users
and serve ads. Some of these ads may be personalized, meaning that these ads are intended to be relevant
to you based on information the companies collect or receive about your use of our Website and third
party sites and websites over time, including through the use of cookies and other tracking technologies.
You may elect to opt out of targeted advertising by companies participating in the promotional self
regulatory program. If you delete your cookies or use a different browser or mobile device, you may need
to renew your opt-out choices exercised through the same program.
You can also limit data collection and use by third parties for targeted advertising in your mobile device
settings, where available.
Note that electing to opt out will not stop advertising from appearing in your browser or applications. It
may make the ads you see less relevant to your interests.
COOKIES
Our Websites use cookies and other similar technologies to improve your experience and support
targeted advertising. For the purpose of this Cookies Policy, cookies, and other similar technologies (like
scripts, plug-ins, tags, device fingerprints, Local Stored Objects, beacons, and pixels) are all referred to as
“cookies.”
You can find more information about the cookies and other tracking technologies we use, the purposes
for which we use them, and make certain choices about cookies through the cookie choices tools available
on our Websites.
Most internet browsers are automatically set up to accept cookies. However, if you want to refuse or
delete any cookies (or similar technologies), please refer to the help and support area on your internet
browser for instructions on how to block or delete cookies. Please note you may not be able to take
advantage of all the features of our Website, including certain personalised features, if you delete or
disable cookies.