This Privacy Policy explains what personal data is collected when you use the website located at: https://sparobanks.com (the “Website”), any SparoBanks mobile application (the “App”), and the services and products provided through it (together with the Website, the “Service”), how such personal data will be processed.
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 18 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; (b) leave the Website and not access or use it; and (c) cancel any active email subscriptions.
“NDPR“ means Nigeria Data Protection Regulation 2019.
“CCPA“ means the California Consumer Privacy Act of 2018.
“GDPR“ means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA“ includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.
“Process“, in respect of personal data, includes to collect, store, and disclose to others.
1. PERSONAL DATA CONTROLLER
Raw Nigeria Newspaper Limited, a company registered under the laws of the Federal Republic of Nigeria, having its registered office at Jmj junction, Federal Polytechnic Nekede, Owerri, Imo State, will be the controller of your personal data.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, an email address).
Data you give us
If you decide to subscribe for newsletter or to submit news to Legit, you will be asked to provide your email address.
Data we collect automatically:
- Cookies.
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising. Cookies set by us are called first-party cookies. We also use third party cookies, which are cookies from a domain different from the domain of our Website, for our advertising and marketing efforts.Cookies are used by us for the following purposes:
- To speed up loading of pages.
- To recognise and count the number of visitors, to know which pages are the most and least popular, and to see how visitors move around our Website when they are using it. As a result, we will be able to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- To make our Website and the advertising displayed on it more relevant to your interests.
- To measure advertising performance.
- To prevent fraudulent activity and improve security.
- To personalize the content of the Website.
- To analyze performance of the Website and fix bugs.
Cookie data will be stored on your device and most of the time only for a limited time period. You can manage your cookies as set out in Clause 4.7 below.
3. DATA PROTECTION PRINCIPLES
In our data protection practices we strive, in particular, to provide that personal data is:
- collected and processed in accordance with specific, legitimate and lawful purpose consented to by you, lawfully, fairly and in a transparent manner;
- is adequate, accurate and without prejudice to the dignity of human person;
- stored only for the period within which it is reasonably needed;
- secured against reasonably foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.
4. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.
To provide you with customer support
We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our
Terms and Conditions of Use or this Privacy Policy.
To communicate with you regarding your use of our Service
We communicate with you, for example, by emails. These may include for example, emails with information about the Service. To opt out of receiving emails, you need to follow unsubscribe link located in the footer of the email or by contacting our support team at [email protected].
To send you newsletter
We process your personal data for sending our newsletter. If you do not want to receive emails from us, you can unsubscribe following instructions in the footer of the marketing emails or by contacting our support team at [email protected].
We use Sendios, which is a marketing personalization and retention platform, to deliver tailored email messages to our users.
To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
5. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA
We process your personal data, in particular, under the following legal bases:
your consent;
Under this legal basis we:
- Send you communications. You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails.
- Store or access information on your devices via cookies and other tracking technologies.
to perform our contract with you;
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Provide you with customer support
- Communicate with you regarding your use of our Service
for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
- to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
to comply with legal obligations.
6. WITH WHOM WE SHARE YOUR PERSONAL DATA
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 4 of this Privacy Policy. The types of third parties we share information with include, in particular:
Service providers
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers (Amazon)
- communication service providers (Sendios)
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
7. AVAILABLE REMEDIES
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
Deleting your personal data.You can request erasure of your personal data as permitted by law.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data.You can ask us to stop using all or some of your personal data or limit our use thereof.
Withdrawing your consent.You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails or via the cookies banner.
To lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority.
To data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request to us as described below.
To exercise any of your privacy rights, please send a request to [email protected].
8. NO LIMITATION CLAUSE
If there is a data breach that may cause a risk for the rights and freedoms of individuals, we will notify competent supervisory authority, when such notification is mandatory. If the risk is assessed by us as “high”, we will also notify the affected data subjects without undue delay. The time frame for such notification will be developed by us on the basis of number of affected data subjects and time needed to collect contact information for notifications.
If the measures taken or proposed to be taken in response to the breach did not address your concerns, you have the right to lodge a complaint with a competent supervisory authority, or to seek redress in a court of competent jurisdiction.
9. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
No limitation of liability shall avail us in case we act in breach of the principles set out in Section 3.
10. AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
11. INTERNATIONAL DATA TRANSFERS
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available
here), or (ii) the European Commission adequacy decisions about certain countries (details available
here).
12. CHANGES TO THIS PRIVACY POLICY
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
13. FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires us to disclose what personal information we have collected, used, and shared over the last 12 months.
Section 2 describes the personal information we have collected about you, including the sources of that information. We collect this information for the purposes described in Section 4. We share this information as described in Section 6.
Under CCPA you as a California resident have the following rights, which you may exercise by yourself or you may designate an authorized agent to make these requests on your behalf:
Right to Delete. You have the right to request that we delete your personal information that we have collected from you.
Right to Opt-Out. CCPA requires that we maintain a separate webpage that allows you to opt out of the sale of your personal information, which can be accessed by clicking the
link.
Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights. We will not deny you our services, charge you different prices, or provide you a lower quality of services if you exercise your rights under the CCPA.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
To exercise any of your privacy rights, please send a request to [email protected].
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. Learn more about what is considered to be
personal information under the statute.
To obtain this information from us, please send an email message to [email protected] which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
14. FOR VIRGINIA RESIDENTS
This section supplements our Privacy Policy and only applies if you reside in the Commonwealth of Virginia. Where applicable, it describes how we use and process your personal data and explains your particular rights under Virginia Consumer Data Privacy Act (VCDPA).
Disclosures about the use of your personal data
We may collect and use certain information about you, some of which may be personal data (such as email address, IP address or other information which may be reasonably linked to you), in order to operate the Service and to maximize your experience.
If you would like more information about the categories of your personal data we collect or the purposes for which we collect them, please read Section 2 and Section 4. To learn more about sharing of your personal data with our business partners and other third parties, please read Section 6.
Data Rights
Section 9 of our Privacy Policy describes the data rights we offer to all users and how to execute these rights. This includes the right to access, review, correct, update your data, obtain a portable copy of your data, or delete data related to your stored preferences and your use of the Service. Before completing your request, we may require some information sufficient to authenticate your identity.
Additionally, VCDPA provides Virginia residents with these data rights:
- Opt out of the Processing of your Personal Data for Targeted Advertising. In order to exercise your choice as a Virginia resident, please click on “Do Not Sell/Share My Information”. While we may use different wording, this link will opt you out of targeted advertising.
Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. - Confirm whether your Personal Data is being Processed. You may confirm whether your personal data is being processed by emailing us at [email protected].
- Appeal a Case with regard to your request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us at [email protected] to initiate an appeal of this decision. Please use the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied, you may contact the Office of the Virginia Attorney General via the contact details available at www.virginia.gov/agencies/office-of-the-attorney-general/#vagov.
15. DATA RETENTION
We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
16. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user’s DNT preference. You can usually access your browser’s DNT option in your browser’s preferences.
We currently do not support “Do Not Track” requests because no DNT standard has been adopted.
Our third-party services may collect information about your and your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
17. CONTACT US
You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at [email protected]. You may also contact our Data Protection Officer at [email protected].
Effective as of: 11 September 2023