“Process”, in respect of personal data, includes to collect, store, and disclose to others. TABLE OF CONTENTS
• 1. PERSONAL DATA CONTROLLER
• 2. CATEGORIES OF PERSONAL DATA WE COLLECT
• 3. DATA PROTECTION PRINCIPLES
• 4. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
• 5. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA • 6. WITH WHOM WE SHARE YOUR PERSONAL DATA
• 7. AVAILABLE REMEDIES
• 8. NO LIMITATION CLAUSE
• 9. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
• 10. AGE LIMITATION
• 12. DATA RETENTION
• 13. CONTACT US
1. PERSONAL DATA CONTROLLER
NAIJAMART.COM Online Marketplace Nigeria Limited, a company registered in the Federal Republic of Nigeria (with registered office at 350, Borno Way, Yaba, Lagos, Nigeria) will be the controller of your personal data.
Cars45 Limited, a company registered in the Federal Republic of Nigeria (with registered office at 4th Floor, CIPM House, CIPM Avenue, CBD, Alausa, Ikeja, Lagos) will be the joint controller of the categories of personal data as follows:
In relation to certain categories of personal data expressly specified below 2.3.5
• a) car dealers’ transaction data relating to sales at the car auction (paragraph 2.3.5.); • b) personal ID, Bank ID and САС of car dealers (clause 2.1.);
• c) the Required Information of car sellers and car dealers (clause 2.1.).
2. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, an email address). We also collect data automatically (for example, your IP address).
2.1 Data you give us.
You may be asked to provide us information about yourself when you register for and/or use the Service. This information includes: first name, last name, phone number, email, gender, date of birth (together “Required Information”), address details, working hours etc., as well as access to your photos, albums and their metadata. You will need to provide us with your ID or similar identification document if you want to post advertisement in Mobile Phones category, unblock your account or make duplicate account primary. You will need to provide us with your Bank ID and САС (certificate of incorporation of legal entity) if you want to participate in car auction as a dealer.
To use our Service and register an account, you will need to provide Required Information. You will be able to use the Service even if you do not give this data to us, but some Service’s functionality may be limited to you (for example, if you do not register an account, you will not be able to chat with other users, post ads, see contact details of other users).
Sometimes you may also need to provide us additional information in the communication with our Support Team in order to fulfill your request (for example, if your account was previously blocked, we may ask you to confirm your identity by providing an ID document).
While posting an announcement on the Service, you can decide to provide additional personal information on yourself. For example, you can decide to make available your CV or any photos of you or bearing your personal information. You acknowledge that by providing your personal data in the announcement you are making such data publicly available. In addition, you acknowledge and agree that we will make public some personal data from your profile to provide the Service, – it will enable us to facilitate communication and transactions between the users. In particular, you acknowledge and agree that your email will be shown as a part of your advertisement in the Seeking Work CVs section to some users with the posted advertisement in the Jobs section.
You should carefully consider risks associated with the fact that you make certain information – in particular, you phone number, address, photos, passport and financial details or exact location – publicly available.
If you want to apply for a car loan, we shall provide us with your employment Type (Salary Earner or Business Owner), Monthly Income/Salary and Bank Verification Number(BVN). We will use this information for the calculation of amounts for the first and subsequent monthly installments. 2.2. Data provided to us by third parties
When you decide to log in using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID. Unless you opt-out on the Facebook Login screen, we will also collect other data, such as email address, gender, date of birth, friends list, and location as listed in your Facebook profile.
For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the App on their Apps and Websites page.
Apple lets you revoke access provided to the App on your Apple ID Manage Page by following the next steps.
If you were invited to create an account in the Service, the person that invited you can provide personal information about you, such as your phone number, email address, social media account or other contact information.
We may collect your name, official government ID number and photo image to confirm your identity. For this we will share this information with a 3rd party service provider, Smile Identity Inc., in order to validate it with the governmental sources. Smile Identity Inc. may use your ID number to collect the following additional data on you from the governmental sources: full name, date of birth, image, address, phone number, gender, government ID expiry date or other additional information associated with your ID number that the issuing authority may provide. Smile ID may process or store your data outside of the borders of your country.
2.3. Data we collect automatically:
Data about how you found us
We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).
2.3.2. Device and Location data.
We collect data from your 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, and Facebook ID.
2.3.3. Usage data
We record how you interact with our Service. For example, we log the features, and content you interact with, how often you use the Service, how long you are on the Service, what sections you use, how many ads you watch.
2.3.4. Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
2.3.5. Transaction data
When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.
3. DATA PROTECTION PRINCIPLES
In our data protection practices we strive, 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; and
• 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:
4.1. 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.
4.2. To customize your experience
We process your personal data to adjust the content of the Service and make offers tailored to your personal preferences and interests.
4.3. To manage your account and provide you with customer support
We communicate with you, for example, by push notifications or in the chat. As a result, you may, for example, receive a notification whether on the Website or via email that you received a new message on Naijamart. To opt out of receiving push notifications, you need to change the settings on your browser or mobile device. To opt out of certain type of emails, you need to follow unsubscribe link located in the footer of the email, by contacting our support team at email@example.com.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our users, as well as when they interacted with it, such as by clicking on links included in the message.
4.5. 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 Naijamart and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of Naijamart
our users like more, what categories of users use our Service. As a consequence, we often decide how to improve Naijamart based on the results obtained from this processing. For example, if we discover that Jobs section is not as popular as others, we may focus on improving it.
4.6. To send you marketing communications
We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our products, such as for example, special offers, and products of our partners. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails, by contacting our support team at firstname.lastname@example.org.
We may also show you advertisements on the Website, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device or/and browser.
4.7. 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 have visited our Website, you might see ads of our products, for example, in your Facebook’s feed.
We may target advertising to you through a variety of ad networks and exchanges, using data from advertising technologies on and off of our Services like unique cookie or similar tracking technology, pixel, device identifiers, geolocation, operation system information, email.
How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.
Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. 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.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
• Network Advertising Initiative – http://optout.networkadvertising.org/
• Digital Advertising Alliance – http://optout.aboutads.info/
• Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
• Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
• DAA AppChoices page – http://www.aboutads.info/appchoices
Google allows its users to opt out of Google’s personalized adsand to prevent their data from being used by Google Analytics.
Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.
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.
4.10. To process your payments
We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and use the paid features of the Service.
5. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA We process your personal data, in particular, under the following legal bases:
5.1. your consent;
On this basis we use your cookies.
5.2. to perform our contract with you;
5.3. for our (or others’) legitimate interests; Under this legal basis we, in particular: • communicate with you regarding your use of our Service
This includes, for example, sending you push notifications reminding you that you have unread messages. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you.
• 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 our mobile application easier and more enjoyable, or to introduce and test new features). • send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.
• personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
5.4. to comply with legal obligations.
6. WITH WHOM WE SHARE YOUR PERSONAL DATA
6.1. Service providers
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 (Amazon, DigitalOcean, Hetzner)
• data analytics providers (Facebook, Google, Appsflyer)
• login service providers (Google, Apple, Facebook, Truecaller)
• marketing partners (in particular, social media networks, marketing agencies, email delivery services; such as Facebook, Google)
• payment services providers (Solid)
• local banks and credit organizations (Access Bank, Sterling Bank, Union Bank, Sovereign Finance, Purple Money, etc.);
6.2. Law enforcement agencies and other public authorities
6.3. 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. AVAILABLE REMEDIES
If there is a data breach that may cause a risk for the rights and freedoms of individuals, we will notify competent supervisory authority, when such notification is mandatory. If the risk is assessed by us as “high”, we will also notify the affected data subjects without undue delay. The time frame for such notification will be developed by us on the basis of number of affected data subjects and time needed to collect contact information for notifications.
If the measures taken or proposed to be taken in response to the breach did not address your concerns, you have the right to lodge a complaint with a competent supervisory authority, or to seek redress in a court of competent jurisdiction.
8. NO LIMITATION CLAUSE
No limitation of liability shall avail us in case we act in breach of the principles set out in Section 3. 9. 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 to Naijamart in the settings section on the Website. You may also request a copy of your personal data collected during your use of the Service. Deleting your personal data. You can request erasure of your personal data by sending us an email at email@example.com or you can delete your account via the link.
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 (including for direct marketing purposes). 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 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. 10. AGE LIMITATION
12. DATA RETENTION
13. CONTACT US