Cookie Policy
Table of Contents
Introduction
This Cookie Policy (“Policy”) governs the use of cookies and other technologies capable of storing, retrieving, collecting, recognising or otherwise processing information concerning visitors and users of Sizzle Social websites, applications, account environments, dashboards and other digital properties to which this Policy is expressly applied.
This Policy describes:
the nature and function of cookies and similar technologies;
the categories of cookies and tracking technologies that may be deployed;
the purposes for which such technologies may be used;
the circumstances in which consent is required;
the distinction between necessary and non-essential technologies;
the operation of cookie preference controls;
the involvement of third-party technology providers;
the retention of cookie-related information;
international data transfers arising from tracking technologies;
the rights available to data subjects; and
the procedures for withdrawing consent or raising a privacy complaint.
This Policy forms part of the Sizzle Social privacy and legal framework and shall be read together with the Privacy Policy, Terms of Service, Data Rights & Privacy Requests Policy and other policies published through the Sizzle Social Legal Centre.
General Provisions
Operator and Data Controller
Sizzle Social is operated under Sizzle Digital Technologies.
For the purposes of this Policy:
“Sizzle Social”, “we”, “us” or “our” refers to Sizzle Social and its operator, Sizzle Digital Technologies, as applicable.
Where Sizzle Social determines the purposes and means of processing personal data through cookies or equivalent technologies, Sizzle Digital Technologies acts as the relevant data controller for that processing.
Third parties may separately act as processors, joint controllers or independent controllers depending upon the technology concerned and the nature of their processing.
Applicable Data-Protection Framework
This Policy is intended to operate in accordance with applicable Nigerian privacy and data-protection law, including:
the Nigeria Data Protection Act 2023 (“NDP Act”);
applicable regulations, directives and regulatory instruments issued by the Nigeria Data Protection Commission (“NDPC”); and
the Nigeria Data Protection Act General Application and Implementation Directive 2025 (“GAID”).
In particular, cookies and technologies performing substantially similar tracking functions are subject to the applicable consent and transparency requirements established under the Nigerian data-protection framework.
Where another applicable jurisdiction imposes additional requirements, including where the GDPR, UK GDPR, ePrivacy rules or another applicable privacy framework applies to particular processing, Sizzle Social shall comply with those requirements to the extent legally applicable.
Additional international privacy information may be provided through the GDPR & International Privacy Rights Policy.
Relationship With the Privacy Policy
This Policy supplements the Sizzle Social Privacy Policy.
The Privacy Policy governs the wider collection and processing of personal data by Sizzle Social.
This Cookie Policy deals specifically with cookies and comparable tracking or storage technologies.
Where a technology described in this Policy results in the processing of personal data, the Privacy Policy shall apply to that processing in addition to this Policy.
Definitions
Cookie
A “Cookie” is a small file or item of data stored on or associated with a browser, device or digital environment and capable of being retrieved during a current or subsequent interaction.
Cookies may enable a digital service to:
maintain a session;
recognise a browser or device;
authenticate a User;
retain preferences;
prevent fraud;
measure activity;
understand website usage;
remember consent choices;
support functionality; or
perform another disclosed purpose.
Tracking Technology
For purposes of this Policy, “Tracking Technology” includes a Cookie and any other technology that performs the same or a substantially similar function.
Depending on the technology deployed, this may include:
pixels;
tags;
web beacons;
local storage;
session storage;
browser identifiers;
device identifiers;
tracking URLs;
embedded scripts;
software development kit identifiers;
conversion tags;
advertising identifiers;
server-side tracking mechanisms; and
comparable technologies.
The legal treatment of a technology shall depend upon its actual function rather than merely the name applied to it.
Necessary Cookie
A “Necessary Cookie” means a Cookie or comparable technology required for qualifying core functionality, including functions such as:
security;
network stability management;
accessibility;
authentication;
session integrity;
fraud protection; or
other functionality without which the requested digital service cannot reasonably operate.
Necessary Cookies shall be classified conservatively and shall not be used as a label for technologies whose principal purpose is advertising, profiling, behavioural analysis or optional analytics.
Non-Essential Cookie
A “Non-Essential Cookie” means a Cookie or Tracking Technology that is not strictly necessary for qualifying core functionality.
Depending upon actual implementation, such technologies may include those used principally for:
analytics;
performance measurement;
preference enhancement beyond necessary functionality;
advertising;
retargeting;
behavioural profiling;
campaign attribution;
social media tracking; or
other optional purposes.
First-Party Cookie
A “First-Party Cookie” means a Cookie set or controlled through a Sizzle Social digital property or domain for purposes determined by Sizzle Social.
A First-Party Cookie is not necessarily a Necessary Cookie.
Consent requirements depend upon purpose and function rather than whether a Cookie is technically first-party.
Third-Party Cookie
A “Third-Party Cookie” means a Cookie or Tracking Technology set, accessed, operated or controlled by a third party through or in connection with a Sizzle Social digital property.
A third party may process data independently or on behalf of Sizzle Social depending upon the relationship concerned.
Session Cookie
A “Session Cookie” ordinarily exists for the duration of a browsing or authenticated session and expires or becomes ineffective after the session ends, subject to the technology concerned.
Persistent Cookie
A “Persistent Cookie” remains stored beyond an individual browsing session until:
its designated expiry;
deletion by the User;
withdrawal through applicable controls;
removal by the relevant website or provider; or
another termination condition occurs.
Cookie Preference Centre
The “Cookie Preference Centre” means the mechanism, interface or consent-management tool through which a User may, where implemented:
accept eligible categories;
reject eligible categories;
review consent choices;
modify preferences;
withdraw consent; and
obtain information concerning applicable Cookies and Tracking Technologies.
Data Protection Principles
Application of Data-Protection Principles
The use of Cookies and Tracking Technologies shall be governed by applicable principles of:
lawfulness;
fairness;
transparency;
purpose limitation;
data minimisation;
accuracy where relevant;
storage limitation;
security; and
accountability.
The technical ability to collect information shall not, by itself, constitute authority to collect or retain that information.
Purpose Limitation
A Cookie or Tracking Technology shall be deployed only for an identified and legitimate purpose.
Information collected for one purpose shall not be used for a materially incompatible purpose without an additional lawful basis or consent where required.
Data Minimization
Cookie-related processing shall be limited to information reasonably necessary for the stated purpose.
Sizzle Social shall seek to avoid unnecessary collection of:
sensitive personal data;
financial data;
confidential information;
private content;
excessive device information; or
information unrelated to the stated Cookie purpose.
Transparency
The presence and material purpose of Cookies and Tracking Technologies shall be disclosed in a manner designed to enable an affected User to understand the relevant processing.
Material tracking shall not be intentionally concealed through misleading descriptions, obscure labels or categorisation inconsistent with its actual purpose.
Cookie Consent
General Consent Requirement
Except to the extent permitted for qualifying Necessary Cookies or otherwise permitted by applicable law, Cookies and Tracking Technologies shall not be deployed for processing requiring consent until valid consent has been obtained.
Consent shall be:
freely given;
informed;
specific;
affirmative where required; and
capable of withdrawal.
Mere silence shall not constitute consent to Non-Essential Cookies.
No Reliance on Continued Browsing for Non-Essential Consent
Continued browsing, scrolling, navigation or general use of a Sizzle Social digital property shall not, by itself, be treated as consent to Non-Essential Cookies where an affirmative accept or reject choice is legally required.
Closing a Cookie banner shall not automatically constitute acceptance of optional categories unless the applicable law expressly permits such treatment and the processing concerned is limited accordingly.
Necessary Cookies
Qualifying Necessary Cookies may operate without an affirmative opt-in only to the extent permitted by applicable law.
Under Sizzle Social’s compliance standard, the Necessary classification shall be reserved for technologies genuinely required to provide core functionality.
Where a purportedly necessary technology processes information of a kind for which consent is nevertheless required under applicable law, the technology shall not be exempted merely by being labelled “Necessary”.
Non-Essential Cookies Require a Choice
Non-Essential Cookie categories shall, where consent is required, be presented with an express choice capable of communicating acceptance or rejection.
Non-Essential categories shall not be enabled by default merely because the User has opened the website.
No Preselected Optional Categories
Consent controls for Non-Essential Cookies shall not rely upon:
pre-ticked acceptance boxes;
automatically enabled optional categories represented as consent;
inactivity;
ambiguous interface behaviour; or
another mechanism inconsistent with freely given and specific consent.
Granular Consent
Where reasonably practicable and legally required, consent shall be divided according to relevant categories or purposes.
A User should not be required to consent simultaneously to unrelated optional purposes merely to enable one optional purpose.
For example, consent to analytics should not automatically constitute consent to advertising unless the consent mechanism clearly establishes both purposes.
Refusal of Non-Essential Cookies
Refusal of Non-Essential Cookies shall not, by itself, terminate access to core Sizzle Social functionality that can reasonably operate without such Cookies.
Certain optional functions may be unavailable where they technically depend upon a refused technology.
Sizzle Social shall not misrepresent the refusal of advertising or analytics Cookies as preventing functionality that is not genuinely dependent upon them.
Consent Must Be Voluntary
Access to core Platform functionality shall not ordinarily be made conditional upon consent to unrelated Non-Essential Cookies where such conditioning would prevent consent from being freely given.
Any exception shall require a lawful and documented basis.
Withdrawal of Consent
Consent to Non-Essential Cookies may be withdrawn.
Withdrawal shall not affect the lawfulness of processing already carried out before withdrawal.
Following effective withdrawal:
future optional tracking governed by the withdrawn consent shall cease within the technical control of Sizzle Social;
previously stored Cookies may be removed or disabled where technically supported; and
related data already lawfully collected may remain subject to applicable retention rules.
Withdrawal Must Be Accessible
Where Sizzle Social relies upon Cookie consent, reasonable means shall be provided for the User to revisit and modify consent without having to locate an obscure or inaccessible procedure.
The Cookie Preference Centre or comparable control shall serve as the principal mechanism where implemented.
Consent Records
Where consent is relied upon, Sizzle Social may maintain appropriate records demonstrating:
the consent decision;
date and time;
categories selected;
version of the notice presented;
means through which consent was provided; and
subsequent withdrawal or modification.
Consent records may themselves involve limited necessary processing for compliance and accountability.
Renewal or Refresh of Consent
Consent may be requested again where reasonably necessary because:
the purposes of processing materially change;
new Non-Essential categories are introduced;
material third parties are added;
applicable law requires renewed consent;
the original consent is no longer sufficiently specific;
the consent record has become unreliable; or
another circumstance requires a fresh lawful choice.
Sizzle Social shall not rely indefinitely upon consent that no longer accurately reflects the processing being undertaken.
Cookie Notice & Consent Interface
Conspicuous Cookie Notice
Where required, the Cookie notice or banner shall be displayed in a conspicuous manner when a visitor first enters the relevant Sizzle Social digital property.
The notice shall be capable of being seen without requiring the visitor to scroll through the page to discover it.
Information Contained in the Notice
The Cookie notice shall provide, either directly or through readily accessible layered information:
notice that Cookies or Tracking Technologies are used;
the principal purposes for which they are used;
the identity of the organisation responsible for their use;
an explanation of available choices;
means to accept or reject applicable Non-Essential Cookies;
a means of accessing more detailed information; and
information concerning withdrawal or modification of consent.
Accept and Reject Controls
Where the law requires an explicit acceptance or rejection choice for Non-Essential Cookies, the consent interface shall provide both options.
The interface shall not be intentionally designed to make rejection materially more difficult than acceptance.
Manage Preferences
Where multiple optional Cookie purposes are used, the consent interface should provide a mechanism through which each applicable category may be reviewed and managed.
No Misleading Consent Design
Cookie controls shall not intentionally employ deceptive design practices intended to cause a User to accept processing that the User would otherwise reject.
This includes avoiding materially misleading:
button labels;
colour hierarchy;
hidden rejection controls;
confusing double negatives;
false statements concerning functionality; or
repetitive prompts designed primarily to overcome a previous refusal.
Categories of Cookies & Tracking Technologies
Necessary and Core Functionality Cookies
Necessary Cookies may be used, where deployed, to support functions including:
account login;
session maintenance;
request routing;
load balancing;
security;
fraud prevention;
access control;
website stability;
protection against malicious requests;
consent-preference storage; and
accessibility.
These technologies shall not be repurposed for advertising or unrelated profiling merely because they are exempt from consent for their necessary function.
Authentication and Session Cookies
Authentication or session technologies may be used to:
recognise an authenticated session;
maintain login state;
prevent unauthorised session use;
secure Account access; and
support navigation through authenticated areas.
Authentication Cookies shall be limited to the functionality reasonably required for secure Account operation.
Security and Fraud-Prevention Technologies
Security technologies may be used to:
identify suspicious requests;
detect malicious activity;
prevent account takeover;
protect forms;
mitigate automated abuse;
maintain Platform integrity; and
defend against security threats.
Where a security technology exceeds what is strictly necessary and performs additional tracking, its additional processing shall be assessed separately.
Consent-Management Cookies
Sizzle Social may use a necessary Cookie or comparable storage mechanism to record Cookie choices.
Such a technology may store information including:
whether the Cookie notice has been displayed;
categories accepted;
categories rejected;
preference version; and
date of consent or withdrawal.
Without such storage, the Platform may be unable to remember that a User has rejected optional Cookies.
Preference and Functionality Cookies
Where deployed, preference technologies may support functions such as:
language settings;
display preferences;
region preferences;
interface choices;
previously selected options; or
other convenience functions.
Where such functionality is not strictly necessary, the applicable consent requirements shall apply.
Analytics and Performance Cookies
Where deployed, analytics or performance technologies may be used to understand matters such as:
pages visited;
navigation patterns;
traffic sources;
technical errors;
general interaction patterns;
approximate session duration;
aggregate website performance; and
feature usage.
Analytics Cookies that are not strictly necessary shall not be activated before applicable consent has been obtained.
Analytics information shall not be represented as anonymous where the information remains reasonably capable of identifying, singling out or linking activity to an individual or device.
Advertising and Marketing Cookies
Where deployed, advertising or marketing technologies may be used for purposes including:
advertising measurement;
campaign attribution;
conversion measurement;
retargeting;
audience segmentation;
frequency management;
interest-based advertising; or
measuring promotional effectiveness.
Such technologies shall be treated as Non-Essential unless applicable law clearly establishes otherwise.
They shall not be activated before applicable consent is obtained.
Social Media and Embedded-Content Technologies
A Sizzle Social page may contain content, links, widgets, media players or other functionality associated with an external service.
Where an embedded service places or accesses a Tracking Technology, the technology shall be assessed according to its function.
Third-party social or media technologies shall not be treated as necessary merely because the underlying third-party content is convenient to display.
Where technically feasible, optional third-party embeds may be blocked or limited until applicable consent is obtained.
Payment-Related Technologies
Payment pages or Payment Providers may use technologies for purposes such as:
transaction security;
fraud detection;
authentication;
payment-session continuity; and
payment processing.
Where such technologies are deployed directly by an independent Payment Provider, that provider may determine some or all of the relevant processing.
Payment-related technologies shall not automatically be classified as exempt from consent merely because they appear during a payment transaction.
Their actual function and the nature of the information processed shall determine the applicable treatment.
Customer-Support Technologies
Where customer-support tools, chat interfaces, ticket systems or related functionality deploy Cookies or Tracking Technologies, those technologies shall be classified according to their actual purposes.
A technology required to maintain a support session may receive different treatment from a technology used to profile support visitors for marketing.
Email Tracking Technologies
Where Sizzle Social communications use technologies capable of indicating matters such as whether an email was opened or a link was selected, such processing shall be subject to applicable privacy, direct-marketing and consent requirements.
This Cookie Policy shall apply to such technologies where they perform functions materially equivalent to online tracking tools, notwithstanding that the technology may operate outside a conventional website Cookie.
Cookie Register
Maintenance of a Cookie Register
Sizzle Social shall maintain, either within this Policy, the Cookie Preference Centre or another readily accessible location, a current register of material Cookies and Tracking Technologies deployed through the Platform.
The Cookie Register shall form part of the transparency framework established by this Policy.
Information to Be Included in the Cookie Register
For each material Cookie or Tracking Technology, the Register should identify, where applicable:
| Field | Required Information |
|---|---|
| Name | Technical Cookie, tag or technology name |
| Provider | Sizzle Social or relevant third-party provider |
| Domain | Domain or digital property through which it operates |
| Category | Necessary, Preference, Analytics, Marketing or other applicable category |
| Purpose | Material reason for deployment |
| Type | First-party or third-party where applicable |
| Duration | Session duration or applicable persistence period |
| Consent | Whether prior consent is required |
| Data | Material categories of information processed where relevant |
| Transfer | Whether data may be transmitted outside Nigeria where applicable |
Accuracy of the Cookie Register
The Cookie Register shall reflect actual technologies in production.
A technology shall not be added to the Register merely because Sizzle Social could theoretically use it.
Likewise, a live material Tracking Technology shall not be intentionally omitted merely because it is technically deployed through:
tag management;
embedded content;
server-side infrastructure;
an advertising platform;
a payment provider;
a customer-support tool; or
another third party.
Technical Cookie Audits
Sizzle Social should periodically review its websites and digital properties to identify:
newly introduced Cookies;
obsolete Cookies;
changed providers;
changed retention periods;
uncategorised tracking;
tags activated without consent;
technologies no longer required; and
discrepancies between the Cookie Register and the live Platform.
Technical deployment shall be reconciled with published legal disclosures.
New Technologies
Where a new Non-Essential Cookie or Tracking Technology is introduced, Sizzle Social shall:
identify its purpose;
determine the appropriate category;
assess whether consent is required;
update the Cookie Register;
update the consent mechanism where required; and
obtain fresh consent where the existing consent does not validly cover the new processing.
Third-Party Cookies & Technologies
Third-Party Service Providers
Sizzle Social may engage third parties that provide digital functionality involving Cookies or Tracking Technologies.
Depending upon the services actually deployed, such third parties may provide:
infrastructure;
security;
analytics;
payment processing;
communications;
customer support;
advertising;
embedded media;
content delivery; or
other technical services.
No particular third-party provider shall be deemed in use merely because its category is described in this Policy.
The live Cookie Register shall identify applicable providers.
Processor and Controller Roles
A third-party provider may process information:
on behalf of Sizzle Social as a processor;
jointly with Sizzle Social where the parties jointly determine relevant processing; or
as an independent controller for purposes determined by that provider.
The applicable role shall depend upon the actual processing arrangement.
Independent Third-Party Policies
Where a third party independently determines how personal data is processed, its own privacy and Cookie terms may apply.
Sizzle Social’s Cookie Policy does not replace the independent privacy notice of an external provider.
Third-Party Links
A link from Sizzle Social to another website does not mean that Sizzle Social controls Cookies placed by that destination after the User leaves Sizzle Social.
The destination’s own policies shall ordinarily govern its independent Cookies.
Embedded Third-Party Services
Embedded third-party content may communicate with an external provider without requiring the User to leave the Sizzle Social webpage.
Where such communication can result in tracking, the technology shall be disclosed and consent controls applied where required.
Information Processed Through Cookies
Technical Information
Depending upon the technology and consent provided, Cookie-related processing may include technical information such as:
IP address;
browser type;
browser version;
device type;
operating system;
device or browser identifiers;
language settings;
time zone;
approximate location derived from technical information;
referring page;
requested page;
timestamps;
session information; and
technical error information.
The presence of this provision does not mean every listed category is collected through every Cookie.
Usage Information
Where optional analytics or comparable processing is enabled, information may concern:
pages viewed;
features used;
navigation sequence;
referral source;
general engagement with website elements;
session duration;
repeated visits; and
aggregate usage patterns.
Account-Associated Information
Where a User is authenticated, certain necessary technologies may associate a session with the relevant Sizzle Social Account.
Optional analytics or marketing activity shall not automatically be linked to an identified Account unless that processing has an appropriate lawful basis and has been disclosed.
Advertising and Attribution Information
Where advertising or marketing technologies are lawfully deployed, the processed information may include:
campaign identifier;
referral source;
advertising interaction;
conversion event;
device or browser identifier;
audience segment; or
other information necessary for the disclosed advertising purpose.
Sensitive and Financial Data
Sizzle Social shall not intentionally use ordinary advertising or analytics Cookies to collect sensitive personal data, complete payment credentials or private Account content.
Where a technology processes sensitive, financial or otherwise highly private information, the processing shall be separately assessed under applicable law and shall not be assumed to fall within the ordinary Necessary Cookie exemption.
Purpose & Lawful Basis
Necessary Processing
Processing strictly required to provide core functionality may be based upon the lawful grounds applicable to that underlying processing, including contract, legitimate interests, legal obligation or another recognised basis where appropriate.
The Cookie consent exemption for qualifying Necessary Cookies shall not eliminate the requirement for the underlying personal-data processing itself to remain lawful.
Consent for Non-Essential Technologies
Where consent is required for a Cookie or Tracking Technology, Sizzle Social shall rely upon consent rather than attempting to reclassify the same optional Cookie processing under another lawful basis solely to avoid obtaining Cookie consent.
Analytics
Optional analytics technologies shall operate only following applicable consent.
The purpose of analytics may include assessing Platform performance, identifying usability issues and understanding aggregate interaction with Sizzle Social digital properties.
Advertising and Direct Marketing
Cookies used for direct marketing, behavioural advertising, retargeting or comparable promotional profiling shall require the appropriate consent where applicable.
Consent to receive marketing communications shall not automatically constitute consent to marketing Cookies unless the consent specifically covers both.
Likewise, Cookie consent shall not automatically constitute consent to receive email, SMS or other direct marketing.
Retention
Cookie Duration
Cookies may be session-based or persistent.
Persistent Cookies shall not remain active longer than reasonably necessary for their stated purpose.
The applicable Cookie Register shall identify the material duration or expiry period of each persistent technology where reasonably available.
Session Cookies
Session Cookies should expire or cease to function when the relevant session ends, except where a limited continuation is technically necessary for security or another disclosed lawful purpose.
Persistent Cookies
Persistent Cookies may remain on the User’s device for the stated retention period unless:
deleted by the User;
withdrawn through relevant controls;
replaced;
expired;
removed by Sizzle Social; or
terminated by the relevant third-party provider.
Consent Records
Records demonstrating Cookie consent or refusal may be retained for a period reasonably necessary to:
respect the User’s preference;
demonstrate compliance;
resolve a dispute;
investigate alleged unlawful tracking; or
meet another legal obligation.
Consent records shall not be retained indefinitely without a continuing legitimate reason.
Data Derived From Cookies
Withdrawal of Cookie consent does not necessarily require immediate deletion of every item of information lawfully obtained before withdrawal.
Retention of previously collected information shall be governed by:
the Privacy Policy;
the original processing purpose;
applicable law;
legal obligations;
limitation periods; and
applicable data-subject rights.
User Cookie Controls
Cookie Preference Centre
Where Non-Essential Cookies are deployed, the Platform shall provide a mechanism through which applicable Cookie choices may be managed.
The Cookie Preference Centre should permit the User to:
review categories;
accept applicable categories;
reject applicable categories;
modify previous selections; and
withdraw consent.
Browser Controls
Most browsers provide tools capable of:
blocking Cookies;
deleting stored Cookies;
limiting third-party Cookies;
deleting site data; or
applying other privacy restrictions.
Browser settings operate independently of Sizzle Social’s consent interface.
Blocking all Cookies through a browser may prevent certain necessary functions from operating correctly.
Browser Deletion Does Not Necessarily Record Withdrawal
Deleting Cookies through a browser removes applicable information from that device but may not always communicate a formal withdrawal instruction to Sizzle Social or an independent third party.
Where available, the Cookie Preference Centre should be used to record consent changes in addition to browser-level deletion.
Multiple Browsers and Devices
Cookie preferences may be device-specific or browser-specific.
A choice recorded in one browser may not automatically apply to:
another browser;
another device;
private browsing mode;
another profile; or
an environment in which consent-storage information has been deleted.
A User may therefore need to manage Cookie preferences separately across multiple environments.
Clearing Consent Cookies
Where the Cookie used to remember consent preferences is deleted, Sizzle Social may no longer be able to recognise the previous selection.
The Cookie notice may consequently be displayed again.
Browser Privacy Signals
Browsers and devices may transmit privacy-related signals or settings.
The effect of such signals may depend upon:
the signal concerned;
technical implementation;
applicable law; and
industry standards.
Nothing in this Policy shall be interpreted as representing that Sizzle Social supports a particular automated browser privacy signal unless the Platform expressly confirms such support.
The Sizzle Social Cookie Preference Centre remains the principal mechanism for communicating Cookie choices directly to Sizzle Social where available.
Registered Users & Account Sessions
Login Sessions
Authenticated Sizzle Social functionality may require session technologies capable of distinguishing an authenticated User from an unauthenticated visitor.
Such technologies may be necessary to:
maintain login state;
prevent session hijacking;
enforce security controls;
apply Account permissions; and
provide requested dashboard functionality.
“Remember Me” or Persistent Login Features
Where Sizzle Social provides a persistent login or “remember me” feature, use of that feature may require a persistent authentication-related Cookie.
The purpose and duration of such technology shall be disclosed where applicable.
Sizzle Social Domains and Subdomains
This Policy may apply across Sizzle Social websites, application environments and subdomains where expressly incorporated.
Different digital properties may use different Cookies because their technical functions differ.
The existence of a Cookie on one Sizzle Social property does not mean the same Cookie operates across every Sizzle Social domain or subdomain.
Cross-Domain Technologies
Where a technology permits activity to be recognised across more than one Sizzle Social property, its operation shall be disclosed where material and subject to the appropriate legal basis and consent requirement.
Cookie Security
Security Measures
Where technically appropriate, Sizzle Social shall apply reasonable safeguards to Cookies under its control.
Depending upon purpose and implementation, measures may include:
secure transmission;
HTTPS;
Secure Cookie attributes;
HttpOnly attributes;
SameSite restrictions;
limited duration;
scope restrictions;
access controls; and
other appropriate measures.
No representation is made that every Cookie can be secured using every technical attribute listed above.
The appropriate configuration shall depend upon its function.
Session Security
Session identifiers shall not intentionally contain unnecessary confidential personal information in plain text.
Authentication Cookies should be designed to reduce foreseeable risk of:
unauthorised access;
session theft;
cross-site request abuse;
disclosure; and
other common web-security threats.
Third-Party Security
Where a third party operates a Cookie or Tracking Technology, the security of that technology may partly depend upon the third party’s systems.
Sizzle Social shall seek to select and manage service providers in accordance with applicable data-protection obligations but cannot represent that an independent provider’s infrastructure is incapable of security failure.
International Transfers
Processing Outside Nigeria
Certain third-party technology providers may process Cookie-derived information outside Nigeria.
The deployment of such a provider may therefore constitute or result in an international transfer of personal data.
Transfer Safeguards
Where Sizzle Social transfers personal data outside Nigeria, the transfer shall be subject to the requirements of the NDP Act and applicable NDPC rules.
Depending upon the destination and circumstances, an appropriate transfer basis may include:
a legally recognised adequate level of protection;
contractual safeguards;
approved transfer mechanisms;
an applicable statutory exception;
consent where legally appropriate; or
another lawful transfer mechanism.
Consent Does Not Cure Every Unlawful Transfer
Obtaining Cookie consent shall not, by itself, excuse Sizzle Social from complying with separate legal requirements applicable to international data transfers.
Where both Cookie consent and an international-transfer safeguard are required, both requirements shall be addressed.
Children & Minors
Age Requirements
Sizzle Social is intended for persons who meet the eligibility requirements established by the Terms of Service, including the applicable age requirement for holding a Sizzle Social Account.
Sizzle Social does not intentionally use Non-Essential Tracking Technologies to profile children.
Child Data
Where Sizzle Social becomes aware that Cookie-related processing concerns a child in circumstances requiring parental or guardian authorisation or another special safeguard, the processing shall be addressed in accordance with applicable law.
Data-Subject Rights
Personal Data Processed Through Cookies
Where Cookie information constitutes personal data, applicable data-protection rights may apply.
Depending upon the circumstances and legal basis, those rights may include rights relating to:
information;
access;
correction;
deletion;
restriction;
objection;
portability;
withdrawal of consent; and
complaint.
Cookie Consent and Data Deletion Are Distinct
Withdrawal of consent prevents future consent-based processing within the relevant scope.
A request for deletion concerns personal data already held.
The two actions are legally distinct and one shall not automatically be treated as the other.
Data Rights Requests
Formal privacy-rights requests relating to Cookie data shall be handled through the Data Rights & Privacy Requests Policy.
Sizzle Social may require sufficient information to identify the relevant data, browser, Account or consent record.
Complaints
Cookie and Tracking Complaints
A complaint may be raised where a person believes that:
Non-Essential Cookies were placed without valid consent;
a rejection choice was not respected;
withdrawal was ineffective;
a tracking purpose was not disclosed;
a Cookie was incorrectly classified as necessary;
Cookie-derived personal data was misused; or
another Cookie-related privacy obligation was breached.
Internal Complaints
Cookie-related complaints may be submitted through the Sizzle Social privacy or complaints process.
Applicable procedures are contained in the Complaints & Dispute Resolution Policy and the Data Rights & Privacy Requests Policy.
Regulatory Complaints
Nothing in this Policy prevents a data subject from exercising any right available to lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority.
Use of the internal Sizzle Social complaint process shall not constitute a mandatory waiver of an external regulatory remedy.
Changes To Cookies & This Policy
Changes to Technology
Sizzle Social may:
introduce new Cookies;
remove existing Cookies;
replace technology providers;
change Cookie purposes;
modify retention periods;
change consent-management technology; or
modify Platform functionality.
Any such change remains subject to applicable consent, transparency and data-protection requirements.
Policy Updates
This Policy may be amended to reflect:
changes to Sizzle Social technology;
changes to tracking practices;
new service providers;
legal developments;
NDPC guidance;
security requirements;
changes in international privacy law; or
other legitimate operational changes.
The Last Updated date shall be revised when this Policy is materially updated.
Material Changes Affecting Consent
Where a change materially expands a purpose for which previously collected Cookie consent was obtained, Sizzle Social shall assess whether fresh consent is required.
A materially new purpose shall not automatically be treated as covered merely because an earlier consent existed for another purpose.
Version Control
Sizzle Social may maintain previous versions of this Policy or relevant Cookie disclosures where reasonably necessary for:
compliance;
evidence of consent;
dispute resolution;
regulatory review; or
legal claims.
Relationship With Other Sizzle Social Policies
Privacy Policy
The Privacy Policy governs the wider processing of personal data, including personal data derived from Cookies and Tracking Technologies.
Terms of Service
The Terms of Service govern the general contractual relationship between Sizzle Social and its Users.
This Cookie Policy governs Cookies and Tracking Technologies specifically.
Data Rights Policy
Rights concerning Cookie-derived personal data shall be exercised in accordance with the Data Rights & Privacy Requests Policy.
GDPR and International Privacy Rights
Where additional international privacy or electronic-communications requirements apply, the GDPR & International Privacy Rights Policy shall supplement this Policy.
Mandatory Law
Where any provision of this Policy conflicts with a mandatory requirement of applicable law, the mandatory legal requirement shall prevail to the extent of the conflict.
The remaining provisions shall continue in force to the fullest extent permitted by law.
Operational Cookie Compliance
Prior Blocking of Non-Essential Technologies
Where consent is required, Sizzle Social shall configure the Platform, so far as reasonably technically possible, to prevent Non-Essential Cookies or Tracking Technologies from being activated before the required consent is received.
A banner that merely describes optional tracking while optional trackers operate before consent shall not constitute effective Cookie compliance.
Tag Management
Where a tag-management system or comparable deployment tool is used, technologies triggered through that system remain subject to this Policy.
The technical use of a tag manager shall not permit an analytics, advertising or other Non-Essential tag to bypass the consent controls applicable to the underlying technology.
Server-Side Tracking
A Tracking Technology shall not cease to be subject to applicable privacy rules merely because tracking occurs through server-side infrastructure rather than a browser Cookie.
Where server-side tracking performs a function substantially similar to Cookie-based tracking, its legal treatment shall be assessed according to its actual purpose, data and effect.
Local and Session Storage
Information written to local storage, session storage or comparable browser storage shall be subject to appropriate consent and transparency requirements where the technology performs a function substantially similar to Cookies.
Renaming a tracking mechanism does not remove the obligations applicable to it.
Device Fingerprinting
Sizzle Social shall not use device fingerprinting or comparable techniques to circumvent a User’s rejection of Cookies.
Where device-fingerprinting technology is deployed for a legitimate purpose, it shall be separately assessed for:
necessity;
lawfulness;
proportionality;
consent requirements;
transparency; and
data-protection impact.
Consent Bypass Prohibited
A User’s rejection or withdrawal of consent shall not intentionally be circumvented through:
local storage;
server-side identifiers;
fingerprinting;
alternate domains;
pixels;
URL identifiers; or
another technical mechanism
where the alternate mechanism performs the same optional tracking purpose for which consent was refused.
Third-Party Tag Responsibility
Before permitting a material third-party tag to operate through a Sizzle Social property, Sizzle Social should identify:
the provider;
the purpose;
the information processed;
the applicable consent category;
retention information where available;
relevant international transfers; and
the contractual role of the provider.
Periodic Consent Review
Sizzle Social shall periodically assess whether:
the consent banner remains operational;
rejection blocks applicable technologies;
withdrawal is effective;
consent categories reflect actual technologies;
Cookies are correctly classified;
third-party tags remain necessary;
the Cookie Register remains accurate; and
obsolete consent records should be removed.
Cookie Register Requirement Before Deployment
Production Cookie Inventory
The production version of Sizzle Social shall maintain an accurate technical inventory of Cookies and comparable Tracking Technologies actually deployed.
The inventory shall be based upon the live Platform rather than assumptions concerning software that may or may not be installed.
No Assumed Vendors
No analytics, advertising, customer-support, payment, security or other technology provider shall be represented in the public Cookie Register unless its relevant Cookie or Tracking Technology is actually deployed through Sizzle Social.
Accordingly, the presence of references in general documentation to services such as analytics, advertising or payment tools shall not, by itself, establish that a particular provider deploys Cookies.
Cookie Register Updates
Where a live technical scan identifies a Cookie or Tracking Technology not contained in the public Cookie Register, the discrepancy shall be reviewed and corrected.
If the technology requires consent and was operating without valid consent, deployment shall be corrected and any further compliance action required by applicable law shall be taken.
Cookie Register Availability
The current Cookie Register should be made available through:
the Cookie Preference Centre;
this Cookie Policy;
a linked Cookie Details interface; or
another location directly accessible from the Cookie notice.
Responsibility & Accountability
Organisational Responsibility
Sizzle Digital Technologies is responsible for implementing reasonable governance measures intended to ensure that Cookies and Tracking Technologies deployed under its control comply with this Policy.
Such governance may include:
technical audits;
consent configuration;
vendor reviews;
records of processing;
privacy assessments;
contract review;
staff access controls; and
periodic compliance review.
Third-Party Compliance
Where Sizzle Social instructs a processor to deploy or operate a Tracking Technology on its behalf, appropriate contractual and organisational measures should address the processor’s handling of relevant personal data.
Where a third party acts independently, Sizzle Social shall provide appropriate transparency concerning that relationship where required.
No Waiver Through User Agreement
A User’s acceptance of the Terms of Service shall not be treated as blanket consent to all Cookies or Tracking Technologies.
Where Cookie consent is separately required, consent shall be obtained through the applicable Cookie-consent process.
No Waiver Through Account Creation
Creation of a Sizzle Social Account shall not constitute advance consent to future optional analytics, advertising or other Non-Essential tracking unless a legally valid consent mechanism separately establishes such consent.
Contact Information
Privacy and Cookie Enquiries
Questions concerning this Policy or the use of Cookies and Tracking Technologies by Sizzle Social may be directed to:
Sizzle Digital Technologies
Platform: Sizzle Social
Website: https://sizzlesocial.ng
Email: contact@sizzlesocial.ng
Privacy-rights requests should be submitted in accordance with the Data Rights & Privacy Requests Policy.
Legal Centre
The complete Sizzle Social legal framework is available through the Sizzle Social Legal Centre.
Related policies include:
Final Provisions
User Choice
Except in respect of qualifying Necessary Cookies or another lawful exception, Sizzle Social’s use of Cookies and equivalent Tracking Technologies shall remain subject to the choices required by applicable law.
Non-Essential tracking shall not be justified solely by reference to a User having visited Sizzle Social, created an Account or accepted the Terms of Service.
Cookie Classification Is Determined by Function
The legal treatment of a Cookie shall be determined by what the technology actually does.
A Cookie shall not be treated as Necessary solely because:
it is first-party;
it is convenient;
it improves marketing performance;
it helps Sizzle Social analyse visitors;
a third-party vendor describes it as necessary; or
disabling it would reduce access to optional functionality.
Conversely, a genuinely necessary security or session technology shall not be treated as advertising merely because it processes a limited technical identifier.
Privacy-Preserving Interpretation
Where more than one reasonable technical configuration is available for achieving the same legitimate purpose, Sizzle Social should prefer an implementation that avoids unnecessary personal-data processing where reasonably practicable.
No Circumvention of Consent
Neither Sizzle Social nor a provider acting on its instructions shall knowingly deploy alternative tracking methods for the purpose of defeating or disregarding a valid Cookie rejection or withdrawal.
Entire Cookie Policy
This Policy, together with the current Cookie Register, the applicable Cookie Preference Centre, the Privacy Policy and any additional jurisdiction-specific privacy notice, constitutes the principal Sizzle Social disclosure concerning Cookies and Tracking Technologies.
No informal statement shall amend the operation of this Policy unless expressly authorised and legally effective.
Effective Date
This Policy takes effect from the date specified as its effective or last-updated date and supersedes any earlier Sizzle Social Cookie disclosure to the extent that the earlier disclosure is inconsistent with this Policy.
Any processing occurring before the effective date remains subject to the law and policies applicable at the relevant time.
Preservation of Statutory Rights
Nothing in this Policy shall be interpreted as:
limiting the authority of the Nigeria Data Protection Commission;
removing a data subject’s statutory rights;
validating tracking that is otherwise unlawful;
converting invalid consent into valid consent;
preventing withdrawal of consent;
preventing a lawful privacy complaint; or
excluding another privacy protection that cannot lawfully be excluded.
Where mandatory law provides greater protection than this Policy, the mandatory protection shall prevail.
