Privacy Policy

Sep 18, 2019 03:38pm | khp |

In this privacy policy statement:

Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us through our platform such as the websites, mobile apps, mobile sites or other online properties through which we offer our Services.

  1. Who are we?

The principal controller of your data for purposes of our international services is 234 Connect Limited, a limited liability company with its Head office at #22 Agoro Kesignton Crescent, Amuwo-Odofin, Lagos State, Nigeria. 234 Connect Limited is the company of  Keep Helping People International and all other entities that are providing the services to you according to our Terms and Condition, (hereinafter collectively referred to as “234 Connect Limited, “we”, “us” or “our” in this privacy policy statement). These 234 Connect Limited entities are also considered data controllers for the local services they offer. Relevant contact details are set out in section 13.

  1. Data we collect about you are Data provided through direct interactions

Registration and other account information;

               When you register to use our Services we may collect the following information about you: Full name, Email address, Telephone number, Bank account Details.

Depending on the choices you make during the log-in to our Services or during the process of engaging our Services, you may opt to give the following additional personal data: Your name; E-mail address; Mobile number; and/or  Your credit card details in case you want to upgrade your membership to be able to confirm yourself to move to the next stage as Indicated in our Terms and Condition.

Communication through the chat feature on our Platform;

                When you use our chat feature to communicate with other users, we collect information that you choose to provide to other users through this feature

Data we collect automatically when you use of our Services;

                When you interact with our Platform or use our Services, we automatically collect the following information about you:                    

Device Information; We collect device-specific information such as operating system version and unique identifiers. For example, the name of the mobile network that you are using. We associate the device identifiers with your 234 Connect Limited account.                                                   

Location Information; Depending on your device permissions, if you post an item on our Platform, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and mobile towers. Your location data allows you to see user items near you and helps you in posting items within your location.                                                              

Client and Log data; Technical details, including the Internet Protocol (IP) address of your device, time zone and operating system. We will also store your login information (registration date, date of last password change, date of last successful login), type and version of your browser.                    

Clicks data; We collect information about your activity on our Platform which includes the sites from which you accessed our Platform, date and time of each visit, searches you have performed, listings or advertisement banners you clicked, your interaction with such advertisements or listings, duration of your visit and the order in which you visit the content on our Platform.                                                                                                 

Cookies and Similar Technologies; We use cookies to manage our users’ sessions, to store your preferences language selection and deliver you relevant advertisements. "Cookies" are small text files transferred by a web server to the hard drive of your device. Cookies may be used to collect the date and time of your visit, your browsing history, your preferences, and your username. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services/Platform may become inaccessible or will not function properly.                                                  

Data from third parties or publicly available sources; We may receive personal data about you from various third parties and public sources. If you would like more information about this, please contact us using the relevant contact details set out in section 13.                                                             

  1. Do we collect data from children under 18 years?

Our Services are NOT intended for children under 18 and we do not knowingly collect data from anyone under 18. If we become aware that a person under 18 has provided us with personal data, we will delete it immediately.                                  

  1. Why do we process your personal information?

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

Where it is necessary for our legitimate interests to improve our Services and to provide you a safe and secure Platform.

Where we need to comply with a legal or regulatory obligation.

In certain circumstances, we may also process your personal data based on your consent. If we do this, we will let you know the purpose and the category of personal data to be processed at the time we seek your consent.

We have set out below a description of the ways we use your personal data

For providing access and delivering Services through our Platform.

If you log in using your mobile number or email id, we use your first name and last name, mobile number and/or e-mail address/or telephone number to identify you as a user and provide access to our Platform.

The above log-information data is also used by us to deliver our Services to you in accordance with our Terms and Condition

We use your e-mail address and mobile number (by SMS) to make suggestions and recommendations and advertise to you about our Services or third party servises that may be of interest to you.

We process the above information for adequate performance of our contract with you and on the basis of our legitimate interest in undertaking marketing activities to offer you Services that may be of your interest.

For improving your experience on the Platform

We use clicks data to:

Offer you good content, such as giving you more relevant search results when using our Services;

To determine how much time you spend on our Platform and in what manner you navigate through our Platform in order to understand your interests and to improve our Services based on this data. For example, we may provide you with suggestions on content that you can visit based on the contents you have clicked; and

To monitor and report the effectiveness of the campaign delivery to our business partners and for internal business analysis.

We use your location data for following purposes:

To compile anonymous and aggregated information about the characteristics and behavior of 234 Connect users, including for the purposes of business analysis, segmentation and development of anonymous profiles;

To enhance the performance of our Services and to personalize the content we direct towards you. For example - with the help of location data we display ad listings which are in your vicinity to improve your buying experience; and

To measure and monitor your interaction with the third-party advertisements banners we place on our Platform.

With the help of your log-in information which includes your email id and phone number, we map the different devices (such as desktop, mobile, tablets) used by you to access our Platform. This allows us to associate your activity on our Platform across devices and helps us in providing you a good experience no matter which device you use.

We process the above information on the basis of our legitimate interest to improve your experience on our Platform and for adequate performance of our contract with you.

To provide you a safe and secure Platform

We use your mobile number, log data and unique device identifiers to administer and protect our Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting and hosting of data).

We analyze your communications done through our chat feature for fraud prevention and to promote safety by blocking spam or abusive messages that may have been sent to you by any other user.

We process the above information for adequate performance of our contract with you, to improve our services and on the basis of our legitimate interest to prevent fraud.

  1. How will we inform you about changes in our privacy statement

We may amend this privacy statement from time to time. We will post changes on this page and will let you know by e-mail or through our Platform/App. If you do not agree with the changes, you may close your account by going to account setting and select delete account.

  1. Your Rights

You may have certain legal rights regarding your personal data depending on the country you are in or how we interact with you. You can learn more about this in this section.

Right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Right to request correction of any of the data we have about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to withdraw your consent to the processing of your personal data at any time. This does not affect the legality of any processing we have already carried out based on the consent given previously.

Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish your data's accuracy

Right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Right to request for the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

To lodge a complaint at any time with your local supervisory responsible for you as outlined in section 13. However, before you make a complaint to the data protection authority, we would appreciate the chance to deal with your concerns in the first instance, please reach out to our Privacy Officer at privacy@khpinternational.com

No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). Alternatively, we may refuse to comply with your request in these circumstances.

                 Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

  1. Communication and marketing

We will communicate with you by email, SMS or in app notification in connection with our Services/Platform to confirm your registration, to inform you in case your ad listing has become live/expired and for other transactional messages in relation to our Services. As it is imperative for us to provide you such transactional messages you may not be able to opt-out of such messages.

                     However, you can ask us to stop sending you marketing communication at any time by clicking on the opt-out link in the email or SMS sent to you or by reaching out us on privacy@234connect.com

                     You may receive marketing communications from us if you:

  1. Have requested such information from us;
  2. Use our Platform or Services;

iii. Provided us with your details when you entered a competition; or                      iv. Registered for a promotion.

  1. Who do we share your data with?

We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.

Corporate affiliates;

We may share your data with other 234 Connect Limited companies which are located within as well as outside Nigeria and help us in providing business operation services such as business enhancements, customer support and fraud detection mechanism. 234 Connect Limited will always be subject safeguards as described in section 9 or to a data transfer agreement which clearly defines the obligations of the parties and ensures appropriate technical and organizational measures to protect your data.

We conduct checks on our third-party service providers and require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Advertising and analytics providers;

In order to improve our Services, we will sometimes share your non-identifiable information with analytics providers that help us analyze how people are using our Platform/Service. We share your information with them in non identifiable form for monitoring and reporting the effectiveness of the campaign delivery to our business partners and for internal business analysis. For further details about our advertisers and analytics provider please refer to our Policy for Cookies and similar Technologies.

Law enforcement authorities, regulators and others:

We may disclose your personal data to law enforcement authorities, regulators, governmental or public bodies and other relevant third parties to comply with any legal or regulatory requirements.

We may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Publicly available information;

When you use our Services, you may choose to make certain personal information visible to other 234 Connect users. This may include your first name, last name, your email address, your location and your contact number and bank account details. Please note, any information you provide to other users can always be shared by them with others so please exercise discretion in this respect.