WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Publicly Available Personal Information. We collect first name, last name, and nickname; current address; phone numbers; email addresses; business email; business phone number; and date of birth.
Social Media Login Data. We may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. you are solely responsible for the correctness of all data that you transmit or that relates to any activity you have undertaken using our Services platform. As such, you agree that we shall have no liability to you for the correctness of any such data, and you hereby waive any right of action against us arising therefrom
Information collected through our Apps
In Short: We may collect information regarding your geo-location, push notifications, when you use our apps.
If you use our Apps, we may also collect the following information:
- Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
- Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent
We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
- To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To deliver services to the user. We may use your information to provide you with the requested service.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.
We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services or Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
- Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.
DO WE USE GOOGLE MAPS?
In Short: Yes, we use Google Maps for the purpose of providing better service.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. You agree to allow us to obtain or cache your location. You may revoke your consent at any time. We use information about location in conjunction with data from other data providers.
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Our Services or Apps offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process and in line with the Nigeria Data Protection Regulations. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short:You may review, change, or terminate your account at any time.
If you are within Nigeria and you believe we are unlawfully processing your personal information, please contact us with your questions or comments about your violated privacy rights at email@example.com.
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us using the contact information provided.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
- Contact us using the contact information provided.
- Access your account settings and update preferences.
CONTROLS FOR DO-NOT-TRACK FEATURES
DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by post to:
5 Jasper Ike Street,
off New Market Road
Victoria Island Extension. Lagos.
DATA PROTECTION POLICY
1. Who we are
We are AppLeap Limited (owners of the CoupinApp), a software solutions company based in Lagos, Nigeria. We are fully registered under the laws of the Federal Republic of Nigeria with registration number RC 1634119
We reserve the right to update this notice at any time. You will however be notified should we make any substantial update to this notice.
2. We are a Data Controller
By the Nigerian Data Protection Regulation (“NDPR”), we are a data controller. This means that we are in accordance with the NDPR rules, responsible for deciding how we hold and use personal and business data you share with us via our mobile app to ensure the privacy and protection of your information.
3.This Data Protection Notice applies to all clients whether former or prospective along with employees and representatives of business clients of AppLeap Limited.
4. In line with our obligation under the NDPR, we shall endeavour to keep your data safe on the principle of best practice.
5. Should you decide to contact us for any clarification, please reach out to us as follows:
The Compliance Manager
We will endeavour to provide you with a response with 14 days of receipt of your mail.
6. How we collect information
Mobile App User Data
Data is collected from the mobile app user for registration (name, email address,) The user is then later asked for their shopping interest, phone number, age range and gender to help personalise the deals and promotions sent to them via the Coupin app.
Retail Merchant Data
The merchants register on the web platform, where they input their business name, address and contact details (email and phone numbers). To activate a promotion on the mobile app to be viewed and redeemed by users, the merchant will initiate this by entering details of the promotional service or product they offer.
We may also verify information about the merchants from public sources, such as social media and online searches.
7. Purpose for Processing Personal Data
We use the mobile app user data to verify the identity of the user and redeem the discount at the merchant’s retail location. In addition, customer insights and trends are provided to merchants from users who physically visit their business location. These data sets are general and not tied to a specific mobile app user such as gender, age range statistics to help analyse trends.
We will strictly hold in confidence the data of our users to the extent permitted by applicable Nigerian laws.
The personal data collected for all clients:
- email address
- mobile number
- telephone number
- age range
8. Lawful Basis for Processing
The basis for processing this personal data is with your consent. Once given, you may withdraw your consent at any time by informing us via email at email@example.com . You may also choose to change your preferences to control what information you are receiving via the profiles section in the mobile app.
9. The Retention Periods for the Personal Data
AppLeap retention period will in the minimum meet the requirements of relevant legislations within the Federal Republic of Nigeria.
10.Individuals have the following rights in relation to the personal data used for marketing information:
- The Right to be Informed – this Data Protection Notice tells you about the processing of personal data, your rights and our responsibilities. We will keep you informed of any changes to this Notice and where there are any issues that arise that affect you.
- The Right to Access – you can write to the Data Protection Contact on the above details to request what personal data is held about you. We will confirm that you are the correct Data Subject and it will take up to 30 days from the original request to send a full response.
- The Right to Rectification –if any of your data is incorrect or requires updating, please notify the Data Protection Contact on the above details and the data will be rectified with 72 hours.
- The Right to Restrict Processing – you have the right to request that the processing of your personal data be restricted. We may not have to grant this right where processing is for the purpose of contractual or legal obligations. Any request for restriction will receive a response within 14 calendar days.
- The Right to Erasure – you have the right to request that data held on you be erased. We do not have to grant this right where processing is for the purpose of contractual or legal obligations. Any request for erasure will receive a response within 14 calendar days
- The Right to Data Portability – you have the right to request to take the personal data you have given to us with you. Any request for a data transfer will receive a response within 14 calendar days.
11. Where processing is based on consent, you have the right to withdraw such consent whenever you choose.
12. Website Usage
- We only use the information you provide about yourself and your company when using this website to answer your enquiry or to help us improve our service to you. We do not share this information with any third party except to the extent necessary to answer your enquiry if that enquiry requires the involvement of a third party. We use return e-mail addresses to answer the e-mail enquiries we receive. Such addresses are not used for any other purpose and are not shared with outside parties.
- To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online. Where we collect information about you on this website, we will tell you how this information will be used.
- We may store information you have provided so that we may contact you with further information about our services which may be of interest to you or your organisation.
- You have the right at any time to ask us not to contact you for marketing materials by e-mail or at all. If in the future, you decide you would like to stop receiving information from us, please e-mail us at firstname.lastname@example.org
- As part of our commitment to quality service and security, telephone calls may be recorded.