Introduction
Welcome to JapaConnect! The protection of your privacy and your personal data is taken very seriously and of utmost concern to us.
We ensures highest standards for the protection of your personal data and your privacy. This Privacy Policy is designed to help you better understand how we collect and deal with your personal data and information.
Earning and keeping your trust is important to us and we use personal data solely to provide you with JapaConnect Services. We will never rent, sell, or otherwise provide personal data to any third party for advertising or for marketing purposes without your consent.
Responsible Body
We are responsible for the handling of your data, which we process according to your wishes and the requirements of the Nigerian Data Protection Regulation (NDPR). The responsible body for the collection and processing of personal data is:
Japa Nigeria
Lekki Phase 1, Lagos
Tel: +234 (0)901 533 3104
Email: move@japa.com.ng
If you have any questions about data protection or data security, please contact our data protection officer.
Email: Ernest@japa.com.ng
Our service providers include, for example, data centers, analysis service providers, and payment service providers. Our service providers are prohibited from processing your data for other purposes or for themselves.
Under the Nigerian Data Protection Regulation (NDPR), you have the right to lodge a complaint with the National Information Technology Development Agency (NITDA), the Nigerian supervisory authority for data protection issues (www.nitda.gov.ng). However, we encourage you to contact us first with any concerns you may have about your data privacy. We value your feedback and will strive to address any issues promptly
Your rights in data protection
You have the following rights regarding the processing of personal data:
• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold 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.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to 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 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 override your rights and freedoms.
• 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 the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request 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.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Processing of personal data on our website.
The data we collect
• Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Identity data: name, email address, date of birth, address, phone number, IP address
Technical data: includes internet protocol (IP) address, unique device identifier, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our services.
Profile data: includes your username, purchases or orders made by you, your interests and preferences.
Usage data: includes information about how you use our website, mobile apps, products, and services.
Marketing and Communications data includes your preferences in receiving marketing from us and our third parties, your Google Advertising ID (if you have one) and your communication preferences.
Aggregated data: we also collect, use and share Aggregated data, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you the services or to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How We Collect Your Personal Data
In accordance with the Nigerian Data Protection Regulation (NDPR), we use various methods to collect data, including:
Direct Interactions:
You may provide us with your Identity and Financial Data by filling in forms on our website or JapaConnect Apps, or by corresponding with us by email or other means. This includes personal data you give us when you:
i. Apply for our products or services.
ii. Create an account on our website or JapaConnect Apps.
iii. Subscribe to our service or publications.
iv. Request marketing materials.
v. Provide feedback.
Automated Technologies:
As you interact with our website or JapaConnect Apps, we may automatically collect Technical Data about your device, browsing actions, and patterns. We collect this data using cookies, server logs, and other similar technologies. We may also receive Technical Data about you from other websites that use our cookies. Please see our cookie policy for further details.
Third Parties or Publicly Available Sources:
We may receive personal data about you from various third parties and public sources, including:
i. We may share your personal data with data processors to allow us to provide you with our services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our processors 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.
ii. We also use cookies in our website which allow third parties, to use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the Internet and use that information to provide measurement services and target ads.
iii. Service providers, based in the Nigeria and outside Nigeria, acting as processors, to provide us with the following services:
Hosting, provided by, OVH;
Security, provided, namely, by Cloudfare;
Analytics, provided by, Google;
Log-in to our services using third-party credentials, provided by, Meta and Google.
iv. Regulators and other authorities who require reporting of processing activities in certain circumstances.
v. Third parties to whom 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 notice.
vi. Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services, both within and outside Nigeria.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to provide you the services or to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where you have given to us your consent to use your personal data. Whenever we need your consent to proceed with any usage of data, we will collect it. You have the right to withdraw consent to marketing at any time by Contacting us.
• We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
• You will receive marketing communications from us if you have requested information from us or purchased goods from our Partners Apps, and, in each case, you have not opted out of receiving that marketing.
• We may not share your personal data with any company outside the JapaConnect group of companies for marketing purposes without your express opt-in consent. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
• You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use.
• We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
• If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data security
• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
• In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
• We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
• 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 unauthorised 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 requirements.
• In some circumstances you can ask us to delete your data. We may also anonymise 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 information indefinitely without further notice to you.
• If you want further information about details of retention periods for different aspects of your personal data, you can contact us.
Links
JapaConnect may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage you to be aware when you leave the Japa Media websites to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by JapaConnect and its website.
Changes
This Privacy Policy must be adapted from time to time to the actual circumstances and the legal situation. Please check the Privacy Policy before using our platform to keep up to date with any changes or updates.
