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PRIVACY POLICY

Last updated - September 2023

1. INTRODUCTION

This Privacy Policy sets out how Adela Technologies Nigeria Limited uses and protects your personal data that you provide to us, or that is otherwise obtained or generated by us through our bulk messaging platform, Parrotica (the "Platform") or in connection with your use of our services (the “Services”). For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ refers to Adela Technologies Nigeria Limited, and ‘you’ refers to you, the user of the Services.

Parrotica is a product of Adela Technologies Nigeria Limited, and this Privacy Policy applies to all our services under the Platform unless otherwise stated. This Privacy Policy governs your use of the Platform and explains how we collect, safeguard, and disclose information that results from your use. We also use your feedback to provide and improve our Services. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use. Our Terms of Use together with the Privacy Policy constitutes your agreement with us.

We are committed to protecting the privacy of the personal information that is provided to or collected by us while using our Services. We acknowledge and comply with our legal obligations in relation to applicable data protection laws. We respect your privacy and are committed to protecting your Personal Data. Our privacy policy may be updated from time to time so you may wish to check it each time you submit personal information to us. The date of the most recent revision will appear at the top of this document.

2. PURPOSE OF THIS PRIVACY POLICY

The purpose of this privacy policy is to give you information about how we collect and process your personal data. It explains:

3. THE INFORMATION THAT WE MAY COLLECT

The scope of information we may collect from persons using our Services include:

Our Services may also be improved upon with additional features which if opted for by you, require us to collect additional information to provide such services.

4. THE TYPE OF INFORMATION WE MAY COLLECT

Personal data, or personal information, means any information about an individual from which they can be identified. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM, Personal Identifiable Information (PII) and others (‘Personal Data’). It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

5. WHY WE COLLECT INFORMATION

We collect your data for the following reasons:

6. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

7. HOW WE USE COOKIES

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. This way it makes your visit to the site easier and makes the site more useful to you. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We do not impose cookies on you, and you make the decision to accept or decline cookies. If you turn cookies off, some features will be disabled. However, it won’t affect your experience on our site.

8. RETENTION OF DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Where information is kept for a longer period, such as in backup storage, or archives, such information would be safeguarded in accordance with this Privacy Policy.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, reporting, or other requirements.

Where any information retained is stored in an encrypted format, considerations must be taken for secure storage of the encryption keys. Encryption keys must be retained if the data that the keys decrypt is retained.

In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may retain and use this information indefinitely without further notice to you.

9. LAWFUL BASIS FOR OUR USE OF YOUR PERSONAL DATA

We will use your personal data only to the extent permitted by law. Under the Data Protection Act 2023 (DPA) as well as the National Data Protection Regulation (NDPR) personal data may be processed under any of the following lawful basis:

Additionally, the Nigerian Communications Commission, regulates the sub-sector of the Nigerian telecommunications sector called Value Added Service under which Adela Technologies Limited is regulated. The Commission allows personal data to be processed in line with the DPA and applicable law. We also comply with the Do-Not-Disturb (DND) directive given by the NCC and would only transmit advertisement, messages and other e-marketing content to subscribers who have opted for it.

While we mostly collect and process your data with your consent, we may collect and process your data under any of the identified lawful bases depending on the circumstance. We do not always need your consent to process your data. However, we do need your consent before we can process your data for purposes such as direct marketing communications. You are at liberty to withdraw your consent to such kinds of processing at any time. Where such withdrawal makes us unable to proceed with providing you with certain Services, we will inform you accordingly.

By using our Services, you agree to the terms of this Privacy Policy, as to allow us to utilize your data to service you more accurately.

10. OUR ROLE AS DATA CONTROLLER

A “controller” is a person or organization who alone or jointly determines the purposes for which, and the way any personal data is, or is likely to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

11. DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect, or you provide to any of our affiliates on the following basis:

12. DATA SECURITY

We will take reasonable steps to protect personal information disclosed to us from loss, modification, misuse, unauthorized access and/or disclosure. While we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us over the internet as transmission over the internet is not completely secure; therefore, we note that any such transmission is at your own risk. However, we will use strict procedures and security features to try to prevent unauthorized access once we have collected your information. We are bound by international standards and best practices on information and cyber security as may be issued from time to time.

13. DATA RETENTION

We retain your data for such a period as is necessary for the purpose for which it was collected. Storage of your data is also determined by legal, regulatory, administrative, or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise. When data is no longer required for the purposes for which it was collected, we securely destroy it.

14. THIRD PARTY SITES

Our website, and Services may contain links to third-party websites, products, and services. Our products and Services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details are governed by their privacy practices and we will not be liable for any breach of confidentiality or privacy of your information on such third-party websites.

15. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time without prior notice by publishing a new version of the Privacy Policy on our website. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the Privacy Policy are material, we will do our best to notify you via email or through a notification on our website.

16. CHILDREN'S PRIVACY

Our Services are not intended for use by persons under the age of 18 (“Children''). If you are under the age of 18, you are required to use our Service under the guidance and supervision of an Adult. We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children, we would take steps to remove that information from our servers immediately.

17. ACCESS, CONSENT AND CORRECTION

We will take reasonable steps to ensure that the personal information we collect remains accurate, up to date and complete. We will also provide you with access to your personal information held by us on your request unless we are otherwise permitted by applicable laws. If you wish to access or correct personal information that we hold about you, please contact us through the contact details provided below. You have the right to withdraw consent previously given for processing your data or restrict the processing of your personal data. We might however continue to process your data if there are valid legal or operational reasons. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Furthermore, if you discover any inaccuracies in your personal information, please promptly notify us by contacting us through the contact details provided below.

18. YOUR LEGAL RIGHTS

In addition to being able to control the data you directly provide to us, you may exercise any of the below rights with respect to your data:

19. TERMINATION

If Adela Technologies Nigeria Limited merges with, or is acquired by, any other business, you acknowledge that your personal information may fall under the control of another person.

If you terminate your relationship with us, portions of your personal information may be retained in back-ups and archives for as long as is reasonably necessary to assist us in meeting our legal compliance obligations.

20. CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us using the details provided below:

Email address: info@adelatechnologies.com

Telephone number: +234 0704 719 1000

Address: 24 Hon Ajayi Alaba street, Ilasan, Lekki, Lagos State, Nigeria