Effective date: June 06, 2020
SOJION JENERA LIMITED
We use your personal data for many reasons, from understanding how our users engage with our journalism to informing our marketing and advertising. Ultimately, this allows us to publish the journalism that you read on our websites, apps, social media platforms and premises.
The reasons why we collect and use data about our users are:
i. To show you journalism that is relevant to you and to improve your experience on our platforms.
ii. To carry out marketing analysis and send you communications when we have your permission, or when permitted by law
iii. To enable us to show advertisement on our websites, apps, social media platforms and premises.
We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics:
– Information about your rights and our obligations
– Clarity about our dealings with you and transparency about how we collect and use your personal data
– Commitments on how we protect your personal data
– Commitments on how we will facilitate your rights and respond to your questions.
We will continue to examine how we can provide more clarity to our users about our use of data.
What Personal Data We Collect And How We Use It
Personal data is any information about you by which you can be identified. This can include information such as your name, date of birth, email address, postal address, phone number, mobile number; debit card details; information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and information relating to your personal circumstances and how you use our websites, apps, social media platforms and services.
Depending on the particular service that you want to access on our Platform, some of these personal data may or may not be required. For instance, When you register for Does2Leak Online Account we request for your name; your email address; some limited data from your social media profile if you have signed in to your Does2Leak Online Account using your social media details; and your photograph, if you add one to your profile page. You can choose to add a username to your profile page and you can use this when posting content or comments on our websites. We may assign you a unique ID number that we use to recognise you when you are signed in to our services.
Some of our services may give you the option of providing more information about your preferences, so that we can tailor your experience. Signing up for membership or a subscription may also mean you need to provide other details such as your address details.
We will not collect special categories of data – such as information about your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that information to us.
We collect personal data when you sign up for our services and when you browse our websites, apps and social media platforms. This information is used to provide our journalism and other services, display advertising and analyse how visitors use our websites, apps and social media platforms.
When you sign in to our websites, apps and social media platforms using your Facebook login details, you give permission to Facebook to share with us your email address and certain aspects of your Facebook profile if you have made these public on your Facebook profile. This only includes your first and last name, age range, link to your Facebook profile and profile picture. We do not have access to updates on your Facebook profile. If you use your Google login details, you give Google permission to share the information that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, your age range, a link to your Google profile and, if you have one, your profile picture.
We will then use this information to form a profile for your Does2Leak Online Account. If you remove our app from your Facebook settings, or if you remove the Does2Leak Online Newspaper App from your Google settings, we will no longer have access to this data. However, we will still have the information that we received when you first set up your Does2Leak Online account using your Facebook or Google login.
We collect information sent to us by your computer, mobile phone or other electronic access device. The automatically collected information includes but not limited to- data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, standard web log data, still and moving images.
We may also collect information you provide us including but not limited to- information on web form, survey responses, account update information, email, phone number, organization you represent, official position, correspondence with Does2Leak Online Newspaper support services and telecommunication with Sojion Jenera Limited. We may also collect information about your transactions, enquiries and your activities on our platform or premises.
This means that we are responsible for deciding how and why we hold and use your personal data.
We may also use information provided by other third parties like social media sites. Information about you provided by other sites are not controlled by Sojion Jenera Limited and we are therefore not liable for how it is used.
When you post information on a discussion board or comment publicly on an article on one of our websites, apps and social media platforms, the information you post and your username are publicly accessible. This information can be viewed online and collected by other people. We are not responsible for the way these other people use this information. When contributing to a discussion, we strongly recommend you avoid sharing any personal details, and especially information that can be used to identify you directly such as your name, age, address, bank or financial details and name of employer. We are not responsible for the privacy of any identifiable information that you post in our online community or other public pages of the websites, apps and social media platform.
Our apps use information on the content you have viewed. A list of the articles that you have recently viewed is cached in the local storage on your mobile device. You can delete this reading history in the settings of the app. Information on what you have viewed in the app and information on bugs and crashes is also sent to us. You can choose to receive notifications on your mobile device via the app. You can manage these notifications in the settings of the app.
How We Collect Personal Data
We collect personal data when you:
– become a supporter or registering for an account with Does2Leak Online Newspaper
– contribute to fund and support Sojion Jenera Limited
– pay for a subscription or purchase any other products/services;
– enter our competitions and surveys;
– sign up to our editorial emails;
– post in our online community;
– sign up for marketing communications;
– use mobile devices to access our content;
– access our websites, through cookies and other similar technology; and
– when you contact us via email, social media, our apps or similar technologies or when you mention us on social media.
Why We Use Your Personal Data
We use personal data collected through our websites, apps and social media platforms for a number of purposes, including the following:
– To provide the services you sign up for.
– Provide services and support;
– Process applications and send notices about your transactions to requisite parties;
– Verify your identity;
– Resolve disputes, collect fees, and troubleshoot problems;
– Manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
– Detect, prevent or remediate violation of Laws, Regulations, Standards, Guidelines and Frameworks;
– Improve Does2Leak Online Newspaper by implementing aggregate customer or user preferences;
– Measure the performance of Our Services and improve content, technology and layout;
– Track information breach and remediate such identified breaches;
– Manage and protect our information technology and physical infrastructure;
– Contact you at any time through your provided telephone number, email address or other contact details;
– To personalise our services (for example, so you can sign in), remembering your settings, displaying personalised advertising as well as measuring how effective our online adverts are, recognising you when you sign in on different devices and tailoring our marketing communications based on what you read on our websites, apps and social media platforms.
– To carry out marketing analysis, for example we look at what you have viewed on our websites and apps and what products and services you have bought (including what you have looked at and what products or services you have bought on our other platforms.
– To send marketing communications when we have your permission, or when permitted by law.
– To improve our marketing communications, we use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email.
– To sell advertising space on our websites, apps and social media platforms.
– For statistical purposes such as analysing the performance of our websites, apps and social media platform and to understand how visitors use them.
– To respond to your queries and to resolve complaints.
– To comply with applicable laws, regulations and Court order.
Legal Grounds For Using Your Personal Data
We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. In every case, the legal ground will be one of the following:
For example, where you have provided your consent to receive marketing emails from us, your personal data may be used to provide this service to you. You can withdraw your consent at any time. In the case of marketing emails you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email or through your email preferences in the “emails and marketing” tab, when signed into your account.
Our Legitimate Interests:
Where it is necessary for us to understand our readers, promote our services and operate our websites, apps and social media platforms efficiently for the creation, publication and distribution of news, media and related journalistic content both online and in print form, globally.
Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a subscription from us and we need to use your contact details and payment information in order to process your order and deliver your subscription.
Compliance With Law:
Personal Data That We Receive About You From Other Organisations
When you sign up to any of our services we may add to the personal data you give us by combining it with information shared with us by other trusted organisations. This includes, for example, information about your location. We may also add information to improve the accuracy of your delivery address when we send out mail. We may also obtain information from partners whose offers we include in some of our marketing communications and we use this information to ensure that we do not send you irrelevant marketing.
We also use information on the content you have viewed on our websites, apps and social media platforms as well as your interaction with the content to add you to groups with similar interests and preferences, so that we can make our online advertising more relevant. Sometimes we use data about your interests or demographics that third parties have collected from you online to add to these groups. Please refer to our cookies policy for more information on how we use
Security Of Your Personal Data
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our websites, apps and social media platforms. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our websites, apps and social media platforms while still in transit and so you provide it at your own risk.
To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. These websites use Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission. Measures have also been taken to comply with global Information Security Management Systems (ISMS) we therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.
We do not share your personal data with other people or organisations that are not directly linked to us except under the following circumstances:
We may share your data with other organisations that provide services on our behalf such as dealing with online payments and other forms of payment processing, i.e credit or debit card transactions and preventing fraud.
We may also share your data with our advertising partners.
We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do so.
International Data Transfers
We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data as are available in Nigeria.
How Long We Keep Your Personal Data
How We May Contact You
From time to time we may send you service emails, Marketing communications and editorial newsletters. If we have your permission, we may send you materials we think may interest you, such as new offers and updates. Depending on your marketing preferences, this may be by email, phone, SMS or post.
We offer a range of editorial newsletters. You can manage your subscription to these emails through your profile page when you are signed in to your account. You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email or through your email preferences in the tab “Emails and marketing” when you are signed in to your account.
We may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by signing into your account.
Responding To Your Queries Or Complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Cookies And Similar Technology
Advertisement on our websites, apps and social media platforms that is based on cookies and similar technology
We use personalised online advertising on our websites, apps and social media platforms. This allows us to deliver more relevant advertisement to people who visit our websites, apps and social media platforms. It works by showing you adverts that are based on your browsing patterns and the way you have interacted with our websites, apps and social media platforms. It then shows you adverts which we believe may interest you.
When you browse our websites, apps and social media platforms or use our apps, some of the cookies and similar technology we place on your device are advertising cookies, so we can understand what sort of pages you are interested in. We can then display advertising on your browser based on these interests. For instance if you have been reading a lot of food and drink articles, we may show you more advertisements for food and drink.
We do not collect or use information such as your name, email address, postal address or phone number for personalised online advertising.
We may also share online data collected through cookies and similar technology with our advertising partners. This means that when you are on another website, you may be shown advertising based on your browsing patterns on our websites, apps and social media platform. We may also show you advertising on our websites, apps and social media platforms based on your browsing patterns on other sites that we have obtained from our advertising partners.
Online retargeting is another form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with a site away from our websites. For example, if you have visited the website of an online clothes shop, you may start seeing adverts from that same shopping site displaying special offers or showing you the products you were browsing. This allows companies to advertise to you if you leave their website without making a purchase.
Advertising That We Place On Our Websites, Apps And Social Media Platforms Or On Other Sites
We also use personalised online advertising to promote our own products and services. This means that you may see advertising for our products and services on our websites, apps and social media platforms and when you are on other third party websites, including social media platforms.
Your Rights With Regard To The Personal Data That We Hold About You
You can contact us with regard to the following rights in relation to your personal data:
If you would like to have a copy of the personal data we hold on you or if you think that we hold incorrect personal data about you, please contact us using the details provided in our “contact us” section. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Where you have provided us with consent to use your personal data, you can withdraw this at any time.
You also have the right to ask us to delete your personal data or restrict how it is used.
If you do not want us to use your personal data for marketing analysis, you can change your settings in your account.
We may need to request specific information from you to help us confirm your identity in relation to any of the foregoing.
Data Confidentiality Rights
By email: email@example.com
By phone number: +2348030544052