TABLE OF CONTENTS
- PERSONAL DATA CONTROLLER
- CATEGORIES OF PERSONAL DATA WE COLLECT
- DATA PROTECTION PRINCIPLES
- FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
- UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA
- WITH WHOM WE SHARE YOUR PERSONAL DATA
- HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
- AGE LIMITATION
- INTERNATIONAL DATA TRANSFERS
- FOR CALIFORNIA RESIDENTS
- FOR VIRGINIA RESIDENTS
- CONTACT US
1. PERSONAL DATA CONTROLLER
Naij.com Media Ltd will be the controller of your personal data.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data automatically (for example, your cookies).
Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).
Device and Location data
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID.
We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Website, how long you are on the Website, your purchases.
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.
3. DATA PROTECTION PRINCIPLES
In our data protection practices we strive to, in particular, to provide that personal data is:
- processed in accordance with specific, legitimate and lawful purpose consented to by you;
- is adequate, accurate and without prejudice to the dignity of human person;
- stored only for the period within which it is reasonably needed;
- secured against reasonably foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.
4. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To provide you with customer support
We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate.
To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service. We also use such data for statistical analysis purposes, to test and improve our news. This enables us to better understand what categories of users use our Services.
To send you marketing communications
We process your personal data for our marketing campaigns or newsletters.
To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website, you might see ads of our products in your Facebook’s feed.
How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.
Android: To opt-out of ads on an Android device, go to Settings >Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.
macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.
Windows: On your laptop running Windows 10, you shall select Start >Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here.
To learn even more about how to affect advertising choices on various devices, please look at the information available here.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
- Network Advertising Initiative – https://optout.networkadvertising.org/
- Digital Advertising Alliance – https://optout.aboutads.info/
- DAA AppChoices page – https://www.aboutads.info/appchoices
Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari web and iOS
Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
We use Criteo, which is an advertising platform, to serve our ads to audiences who have the same browsing habits as you. Criteo’s data collection and privacy policies can be found here.
When you use our website and enter your email address on our website (either to log in, or to sign up for a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR).
LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you.
To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
5. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 4.
We process your personal data under the following legal bases:
Under this legal basis we send you marketing communications or newsletters.
To perform our contract with you
Under this legal basis we:
- provide our Service (in accordance with our Terms and Conditions of Use);
- provide you with customer support.
For our (or others') legitimate interests
We rely on legitimate interests:
to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
To comply with legal obligations.
6. WITH WHOM WE SHARE YOUR PERSONAL DATA
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers
- data analytics providers
- measurement partners
- communication service providers
- marketing partners
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
7. HOW YOU CAN EXERCISE YOUR RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
Deleting your personal data.You can request erasure of your personal data as permitted by law.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
The right to lodge a complaint with a supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority.
To exercise any of your privacy rights, please send a request to firstname.lastname@example.org.
8. AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
9. INTERNATIONAL DATA TRANSFERS
11. FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires us to disclose what personal information we have collected, used, and shared over the last 12 months.
Section 2 describes the personal information we have collected about you, including the sources of that information. We collect this information for the purposes described in Section 4. We share this information as described in Section 6.
Under CCPA you as a California resident have the following rights, which you may exercise by yourself or you may designate an authorized agent to make these requests on your behalf:
Right of Know. You have the right to request that we disclose to you the personal information we collect, use, or disclose.
Right to Delete. You have the right to request that we delete your personal information that we have collected from you.
Right to Opt-Out. CCPA requires that we maintain a separate webpage that allows you to opt out of the sale of your personal information, which can be accessed by clicking the link.
Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights. We will not deny you our services, charge you different prices, or provide you a lower quality of services if you exercise your rights under the CCPA.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
To exercise any of your privacy rights, please send a request to email@example.com.
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to firstname.lastname@example.org which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
12. FOR VIRGINIA RESIDENTS
Disclosures about the use of your personal data
We may collect and use certain information about you, some of which may be personal data (such as email address, IP address or other information which may be reasonably linked to you), in order to operate the Service and to maximize your experience.
If you would like more information about the categories of your personal data we collect or the purposes for which we collect them, please read Section 2 and Section 4. To learn more about sharing of your personal data with our business partners and other third parties, please read Section 6.
Additionally, VCDPA provides Virginia residents with these data rights:
Opt out of the Processing of your Personal Data for Targeted Advertising. In order to exercise your choice as a Virginia resident, please click on “Do Not Sell/Share My Information”. While we may use different wording, this link will opt you out of targeted advertising.
Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
- Confirm whether your Personal Data is being Processed. You may confirm whether your personal data is being processed by emailing us at email@example.com.
- Appeal a Case with regard to your request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us at firstname.lastname@example.org to initiate an appeal of this decision. Please use the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied, you may contact the Office of the Virginia Attorney General via the contact details available at www.virginia.gov/agencies/office-of-the-attorney-general/#vagov.
13. CONTACT US
Effective as of: 31 May 2023