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Corporate policy framework A practical governance document covering customer service, bookings, payments and refunds, staff and contractors, property and estate services, marketing, safety, privacy, complaints and compliance.
This framework applies to Pinkles Nigeria Ltd ("Pinkles", "the Company", "we", "us" or "our") and its directors, employees, temporary workers, consultants, agents, contractors and approved service partners, subject to their lawful status and written agreements.
It is intended to be read with each quotation, booking confirmation, service order, property mandate, tenancy/short-let agreement, campaign brief, event registration form, employment contract and any service-specific terms. If a signed service agreement gives a more specific lawful term, that term governs that engagement. Mandatory law always prevails over inconsistent wording in this document.
Before use, insert and verify: registered office/business address; customer-service email; telephone/WhatsApp; privacy contact; payment details; complaint escalation contact; operating hours; and any applicable licence, permit, insurance and tax details. Do not publish an unmonitored contact channel.
Pinkles aims to provide reliable, transparent and professional services. The Company will conduct business honestly, treat customers and workers fairly, protect confidential information, maintain accurate records, avoid misleading representations and comply with applicable Nigerian federal, state and local laws and lawful regulatory directions.
The framework covers home interior design and décor; residential and commercial cleaning; brand ambassador and influencer engagements; seminars, workshops and events; fashion design, supply and related services; short-let accommodation and management; conveyance/logistics or passenger transport only where lawfully authorised; spa and wellness services; advertising, promotion and marketing; and property/estate-related consultancy or transactions to the extent the Company is licensed and legally permitted to undertake them.
Staff and representatives must not offer or accept bribes, kickbacks, secret commissions, facilitation payments, undisclosed referral fees or improper gifts. Conflicts of interest must be disclosed in writing to management and, where relevant, to the customer before a decision or transaction. No staff member may misuse client funds, company property, customer data or confidential information.
Customers and workers must be treated respectfully and without unlawful discrimination. Reasonable service adjustments should be considered where practicable. Harassment, intimidation, sexual harassment, exploitation, retaliation and abusive conduct are prohibited.
Management should appoint a person responsible for customer complaints, privacy requests, health and safety, and staff concerns. This policy should be reviewed at least annually and whenever the law, business model, service scope or risk profile materially changes.
Customers may submit a complaint through the Company's published phone/WhatsApp, email or written business address. Pinkles should acknowledge complaints within two business days, aim to provide a substantive response within ten business days, and explain any delay and revised response date. These are internal service targets and do not shorten any statutory deadline or legal right.
A complaint should include the customer's name and contact details, invoice/booking reference, date and description of the issue, supporting photos or records if available, and the remedy requested. Pinkles will investigate fairly, preserve relevant records, give the responsible team an opportunity to respond and communicate the outcome in writing.
If unresolved, the customer may request review by a senior manager. Nothing prevents a customer from approaching the Federal Competition and Consumer Protection Commission (FCCPC), the Nigeria Data Protection Commission (NDPC), a relevant state regulator, a professional body or a court with jurisdiction.
Customers must provide accurate information, safe and lawful access, timely decisions, and respectful treatment of workers. Threats, violence, harassment, discriminatory abuse, illegal requests or unsafe conditions may justify pausing or ending the service, subject to the contract, applicable law and fair handling of any refund due.
A quotation is valid for the period stated on it; if none is stated, it is valid for 14 calendar days unless withdrawn earlier due to a material change in supplier pricing or availability. A contract is formed when the customer accepts the quotation or service terms in writing (including a traceable electronic message) and Pinkles confirms the booking, subject to any stated deposit or verification requirements.
Prices must be communicated clearly in Nigerian naira unless another currency is expressly agreed. The quotation should state whether VAT, delivery, transport, installation, platform charges, government levies, security deposits, utilities, materials and third-party costs are included or excluded. Applicable taxes must be charged, invoiced and remitted as required by law. No undisclosed fee may be added after acceptance.
Any deposit, booking fee, mobilisation payment, milestone or security deposit must be shown separately on the quotation or agreement, with its purpose, due date and treatment on cancellation. Payments must be made only to verified Company or expressly authorised collection accounts. Customers should obtain a receipt. Staff must not request payment into personal accounts without written authorisation and documented safeguards.
Where payment is overdue, Pinkles may give written notice and a reasonable opportunity to remedy the default before suspending work, withholding undelivered items or cancelling future bookings, to the extent lawful and contractually permitted. Any interest, recovery cost or late fee must be expressly agreed in advance, reasonable and lawful. Pinkles will not retain a customer's money or property as leverage where doing so would breach the law.
The customer is responsible for ensuring that supplied designs, photographs, logos, text, measurements, instructions and materials may lawfully be used. Pinkles may rely on customer-approved specifications but must flag obvious inconsistencies or safety concerns reasonably apparent to it. Changes requested after approval may affect price and timing and must be documented.
This policy must be displayed or provided before payment. It is a general framework: the Federal Competition and Consumer Protection Act 2018 (FCCPA), including applicable statutory cancellation, return, quality and refund rights, takes precedence. No blanket 'no refunds under any circumstances' rule is intended or permitted where it would remove a non-excludable legal right.
| Timing | Proposed handling |
|---|---|
| More than 7 calendar days before service | Refund payment less reasonable, evidenced, non-recoverable costs already incurred and disclosed, where legally permitted. |
| 2–7 calendar days before service | Offer rescheduling first; if cancelled, deduct only a pre-disclosed, reasonable amount reflecting actual committed costs, where lawful. |
| Less than 48 hours / no-show | A reasonable fee may apply only if clearly disclosed, proportionate and lawful. Statutory cancellation/refund rights remain unaffected. |
| Pinkles cancels / material non-performance | Offer a suitable alternative or refund for the undelivered portion; no charge for services not supplied, subject to applicable law. |
This schedule is not automatic. It must be adapted to each service, disclosed before the customer pays and applied consistently with the FCCPA and any applicable sector rules. The law prevails if it provides a stronger remedy.
Where Pinkles or its representatives carry out estate agency activity, they must first confirm and maintain all registrations/licences required in the state where the property is located. In Lagos State, the Lagos State Real Estate Regulatory Authority (LASRERA) framework and any applicable current law and guidance must be checked before estate agency work is undertaken.
The term 'conveyance' must be defined in each contract as passenger transport, goods transport, logistics or property-related conveyancing. If it involves transport of people or goods, confirm relevant vehicle/driver licences, roadworthiness, permits, insurance, load and safety requirements, and any state or local transport rules. If it means legal transfer of property, use a qualified legal practitioner where required. Do not accept prohibited or dangerous cargo or transport passengers beyond authorised capacity.
Conduct an inventory/condition report at check-in, check-out or handover where practicable. Distinguish ordinary wear and tear from damage beyond ordinary use. Any claim against a customer or contractor should be supported by reasonable evidence, and any disputed amount should be reviewed by a manager.
Each worker must receive a written agreement appropriate to their actual status: employee, fixed-term worker, casual worker, consultant, independent contractor, volunteer or brand ambassador. Labels alone do not determine legal status; the real working relationship and applicable law do.
Contractors must hold any licences, qualifications, insurance and permits needed for their work and comply with relevant safety, privacy, anti-bribery and customer-service requirements. Pinkles should use written agreements that define scope, quality standards, payment, confidentiality, ownership of work, subcontracting, liability, insurance and termination.
Management must assess foreseeable risks, provide safe systems of work and suitable training/equipment, and comply with applicable workplace health and safety laws and regulations. Workers must follow instructions, use protective equipment, report hazards and stop work where there is an immediate serious risk.
Cleaning products and spa supplies must be stored, labelled and used according to instructions. Staff must not mix chemicals, decant products into unlabelled containers or use unsafe equipment. Maintain hygiene, ventilation, protective equipment, first-aid arrangements and incident reporting appropriate to the service.
Staff must maintain professional boundaries with children and vulnerable people, never exploit or intimidate them, and report suspected abuse or immediate danger through appropriate management and lawful safeguarding channels. Any role requiring background checks or specialist safeguarding procedures must not begin until the applicable requirements are met.
Report injury, damage, theft, suspected data breach, unsafe property condition, lost keys, chemical exposure, transport incident or safeguarding concern to management as soon as possible. Preserve relevant evidence, prioritise immediate safety and contact emergency services where appropriate. Management must investigate, record corrective actions and make any legally required notifications.
Pinkles Nigeria Ltd is the intended data controller for personal information it determines how and why to process, subject to the facts of each engagement. Before publication, insert a monitored privacy contact: [PRIVACY EMAIL] / [PHONE OR POSTAL ADDRESS]. If another organisation determines the purpose and means of processing, the parties must document their respective roles.
We process information to respond to enquiries; quote and deliver services; manage bookings, payments and refunds; verify authority and prevent fraud; meet tax, employment, regulatory and other legal obligations; protect people, property and legal claims; manage staff and contractors; and send marketing where permitted. The applicable lawful basis may be contract, legal obligation, consent, vital interests or another basis recognised by the Nigeria Data Protection Act 2023. We will not rely on consent where it is not freely given or where another lawful basis is appropriate.
Information may be shared on a need-to-know basis with employees, professional advisers, payment providers, booking platforms, landlords/hosts, approved contractors, insurers, auditors, regulators, law enforcement or courts where necessary and lawful. We do not sell personal information. Where information is transferred outside Nigeria, we will assess and implement safeguards and conditions required by applicable data protection law.
We may send service-related messages needed to administer a booking or contract. Promotional messages will be sent only where permitted by law and, where required, with consent or an appropriate opt-out mechanism. You may opt out of marketing at any time. We will obtain appropriate permission before using identifiable customer photographs, testimonials or private premises in advertising, except where another lawful basis clearly applies.
We use reasonable organisational and technical measures proportionate to the risks, such as access controls, confidentiality duties, secure storage, backups and staff training. No method is perfectly secure. We retain data only for as long as reasonably necessary for the stated purpose, legal retention periods, dispute handling and legitimate business needs, then securely delete or anonymise it where practicable. If a personal data breach occurs, we will assess it and notify the NDPC and affected individuals where and when required by law.
Subject to applicable law and any lawful exceptions, you may request access to your personal data, correction of inaccurate information, deletion, restriction or objection to certain processing, data portability where applicable, withdrawal of consent where consent is the basis, and information about how your data is used. You may also complain to the Nigeria Data Protection Commission. We may need to verify your identity and explain if a request cannot lawfully be fully granted.
If our website uses cookies or analytics, provide a clear notice explaining their purpose and choices, and obtain consent where required. Third-party platforms such as social networks, payment services and booking websites have their own privacy terms. Pinkles is not responsible for independent processing by those platforms, but will take reasonable steps when selecting service providers.
We do not knowingly collect children’s personal information beyond what is necessary for a lawful service or event. Where required, we will obtain consent or authorisation from a parent/guardian and apply additional safeguards. Do not publish images or identifying details of children without an appropriate lawful basis and permission.
All advertising, offers, testimonials, endorsements, prices, discounts, before-and-after images and performance claims must be accurate, substantiated and not misleading. Material conditions must be prominent and communicated before purchase. Staff must not create fake reviews, misrepresent availability, hide compulsory fees or imply official endorsement without evidence.
Before running an advertising campaign, management must determine whether ARCON registration/licensing, pre-exposure vetting or approval, sector-specific advertising rules, promotion permits, broadcast/platform rules or other approvals apply. Campaigns involving health, beauty, financial, property, food, alcohol or other regulated products may require additional review. Do not publish regulated advertising until required approvals are secured.
Each contract should identify ownership and licence rights in designs, photographs, videos, copy, logos, campaign assets, clothing patterns, event materials and other deliverables. Unless expressly assigned in writing, pre-existing intellectual property remains with its owner. Customers grant Pinkles only the limited licence needed to perform the agreed service. Pinkles will obtain permissions for third-party material it supplies and expects customers/ambassadors to do the same.
Neither party may disclose the other's confidential commercial or personal information except as required to perform the contract, with permission, or by law. Pinkles may list a client or show project work in its portfolio only with permission or another lawful basis and subject to agreed confidentiality restrictions.
Product descriptions, fabric composition, origin claims, sustainability statements, discounts and endorsement claims must be supportable. Brand ambassadors must disclose material connections and must not claim to have used a product or received a result unless truthful.
Each party is responsible for its own acts and omissions as provided by law and the applicable contract. Pinkles will take reasonable care in performing agreed services. Nothing in these terms excludes or limits liability where exclusion or limitation is prohibited by Nigerian law, including liability that cannot lawfully be excluded for fraud, misrepresentation, negligence, defective performance or statutory consumer rights.
Where a third party supplies part of a service, Pinkles will identify that role where material and will remain responsible for obligations imposed on it by law and the contract. Neither party is automatically excused from every obligation by an event beyond its control. The affected party should notify the other promptly, mitigate the impact and agree a reasonable solution. Payments for undelivered services and statutory rights will be handled under the refund policy and applicable law.
The parties should first attempt to resolve disputes through the complaint process and good-faith discussions. If unresolved, either party may use mediation or another agreed dispute-resolution process, without preventing urgent court relief or access to a regulator. No clause requires a consumer to waive mandatory legal rights or prevents a lawful complaint to a regulator.
These general terms are governed by the laws of the Federal Republic of Nigeria and, where relevant, the applicable laws of the state in which the service or property is located. Courts with lawful jurisdiction may hear disputes. State-specific terms may be required for property, tenancy, transport, spa, events and other regulated services.
Pinkles may update these policies to reflect operational or legal changes. The current version and effective date should be made available to customers. Material changes will not retrospectively remove accrued rights or alter an existing contract without a lawful basis and any required agreement. For a new booking, the version supplied before acceptance applies.
The following are starting points for legal review, not an exhaustive list. Always check the current legislation, amendments, state-specific rules and official guidance that apply to the actual service and location:
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