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1. INTRODUCTION
Hello, HAfar (“We” “Our” “Us”) is a dating application and the first of its kind in Nigeria. We offer you a range of services that enables you to profile potential dates even up to their local governments. Great right? Welcome to Our Privacy Notice. We understand that you care much about your privacy, and we are committed to protecting your personal data. This Privacy Notice describes how we processes personal data and the rights available to you. Please read the entire Privacy Notice to understand how we process your personal data and the rights available to you.
2. DATA PROTECTION OFFICER (DPO)
Hafar has, in compliance with the relevant laws, designated a data protection officer for you to contact if you have any questions concerning this Notice or our privacy practices. Our DPO can be reached via dpo@hafarprivacy.ng
3. INFORMATION WE COLLECT ABOUT YOU
For the services we render, we may collect personal data including names, contact address, telephone numbers, social media accounts, payment information, still and motion images, communication data such as email content and call logs, technical data such IP address, location data, log files and other relevant personal data
SENSITIVE INFORMATION
If When necessary, with your consent and or otherwise as permitted
by applicable law, we process the following category of sensitive
information:
> Information revealing race or ethnic group
> Biometric Data.
> NIN or other government identifiers
4. SOURCES WE COLLECT YOUR PERSONAL DATA FROM
We collect data directly from you when you correspond with us, fill physical or online form on our website, register or sign up to our application. We may also receive data from third party such as service providers like Google, social media or public registry.
5. HOW WE USE YOUR PERSONAL DATA
We process your personal data in order to achieve the following:
> To facilitate account creation and authentication and otherwise
manage user accounts.
> To respond to user inquiries/offer support to users.
> To send administrative information to you.
> To fulfil and manage your orders.
> To send you marketing and promotional communications
> To deliver targeted advertising to you.
> To post testimonials.
> To protect our Services.
> To evaluate and improve our Services, products, marketing, and
your experience.
> To identify usage trends.
> To tailor our services to better suit your need.
> To perform contractual obligations between you and us.
> To comply with legal obligations
> To investigate, defend and exercise our legal rights
FURTHER PURPOSE
We will only process your personal data for the particular purposes for which we collected it. We will notify you and obtain your consent before using it for any further purpose that is not compatible with the original purpose.
6. LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
We may process your personal data on one or more lawful grounds
depending on the specific purpose for which we are using your
personal data. Kindly contact us if you need further details or clarity
about the specific legal ground, we are relying on to process your
personal data where more than one ground has been stated. We will
rely on any of the legal bases listed below depending on the processing
activities:
> We will ask you for your consent in certain processing activities
especially where it involves collection of sensitive personal data.
Where we obtain your consent, kindly note that you can withdraw
the consent at any time and we will comply by not further
processing your personal data.
> We may process your personal data in order to perform contract
you have entered with us or take pre-contractual steps at your
instruction.
> We may rely on our legitimate interest to process your personal
data in order to tailor our services to suit your need.
> We may process your personal data where law mandates us to do
so
7. WHAT CONSTITUTE CONSENT
We may disclose your personal information to third parties such as online payment solutions, regulators, experts and consultants, third party service providers such data storage infrastructure provider, Google, amongst others.
9. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes they were collected and where we are required to assert or defend against legal claims, pending the final adjudication of the claim. 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 use this informational indefinitely without further notice to you. To learn more about our retention periods as established in our retention policy, please contact us.
10. PRINCIPLES OF DATA PROTECTION
We are obligated to comply with data protection principles whenever
we process your personal data and to inform you about these
principles. These principles are:
> We will inform you about the personal data we have about you, and
the lawful basis for processing it.
> We must use your personal data in a way you reasonably expect
and in a manner that ensures transparency, lawfulness, and
fairness.
> We will not use your personal data for any other reason that is not
compatible with the reason we collected it except we have informed
you and relied on an appropriate lawful basis.
> We will only collect personal data about you that is only necessary
to meet the required purpose and nothing more.
> We will only use your correct personal data in the course of our
processing activities.
> We will not store or keep your personal data in our custody beyond
the period necessary to fulfil the purpose for which it is collected.
> We will ensure that your personal data in our custody is protected
from unauthorized use, alteration or corruption.
11. YOUR LEGAL RIGHTS
You have certain rights under the law which we respect and adhere to
and which can be exercised by you at any time. However, note that
these rights are not absolute and may only apply in certain
circumstances. Your rights are as itemized:
> right to access your personal data
> right to request correction of your personal data
> right to request the erasure of your personal data
> right to object to the processing of your personal data especially
with regards to direct marketing
> right to request the restriction of processing of your personal data
pending the rectification of accuracy of your personal data
> right to request transfer of your personal data to another controller
or to you.
> right to withdraw consent
12. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE NIGERIA?
We may have the cause to transfer your personal data to our vendors or expert consultants in foreign countries. We will always ensure adequate protection of your data in these circumstances. Whenever we are transferring your personal data outside Nigeria to countries deemed not to have adequate data protection law, we will comply with the appropriate safeguards which the law has provided such as standard contractual clauses, binding corporate rule or consent. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Nigeria
13. DATA SECURITY
The security of your personal information is important to us. We have put appropriate security measures to protect your personal information, no method of transmission over the internet is 100% secure but we have implemented appropriate security measures such as encryption, firewall, and locks in place to prevent accidental loss of personal data, and/or to ensure that personal data is not used, accessed, altered, or disclosed in an unauthorized manner. In addition, we limit access to your personal data to only necessary employees, agents, contractors, and other third parties who we have business need with us. They will only process your personal data on our instructions and are strictly subject to a duty of confidentiality. We have put in place some procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach within 72 hours where we are obligated to do so.
14. RIGHT TO COMPLAINT
Kindly note that you have the right to make a complaint at any time to the Nigeria Data Protection Bureau (NDPB), the Regulator for data protection issues (https://ndpb.gov.ng/) or approach competent court of law to enforce your data protection rights. We would, however, appreciate the chance to deal with your concerns before you approach the NDPB, so please contact us in the first instance @ (email for complaint) or send a letter to our physical office @ (office address)
15. COOKIES
We use cookies and other tracking technologies on our website. Cookies are small pieces of text that are saved on your Internet browser when you use our website. The cookies are sent back to our computer each time you visit our website. Cookies make it easier for us to give you a better experience online. You can stop your browser from accepting cookies, but if you do, some parts of our website or online services may not function appropriately. Please read our comprehensive cookies policy for more information
16. CHANGES TO OUR PRIVACY NOTICE
This privacy notice will be updated from time to time to reflect our processing activities and we will aim to notify you when this happens.
17. CONTACT DETAILS
Please address questions, comments and requests regarding this Notice to our DPO @ (.)or send a letter to our physical office @ (.)