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SwitchApp Tech Solution Limited is a Registered Company with registration no RC1927006 and located at No 16b Alhaji Hussein Sumnonu Street, Lekki Phase 1, Lagos.
We operate the SwitchApp mobile application ("App") and the website ("Website"), [together referred to as the "Sites"]. Except as set in this Privacy Notice, we do not share, or sell, or disclose to a third party, any personal information collected at the Sites.
This Privacy Policy ("Policy") explains how we collect, use, disclose and protect Personal Information (as it is defined below) of our customers and users. It applies to all Personal Information collected by us on https://www.switchappgo.com (the "Site"), the SwitchApp mobile applications, and any other websites or mobile applications that link to this Policy, as well as during any written, electronic, and oral communications (collectively, the "Services"). SwitchApp may collect Personal Information to help you make any request and to improve the SwitchApp service.
Our Policy has been developed to provide a framework for the appropriate level of privacy protection and represents our commitment to compliance with the Nigerian Data Protection legislation and any other applicable worldwide data protection laws, to try and achieve the highest standards in protecting your personal information.
Your access to and use of our Services are subject to our Terms and Conditions, which define some of the terms used throughout this Policy. Please read this Policy carefully to understand our privacy practices and let us know if you have any questions by contacting us through (email address). By using our Services, you accept the Terms and Conditions, and accept our privacy practices described in this Policy.
Our Services may change from time to time. As a result, we reserve the right to update or modify this Policy at any time and from time to time without prior notice. If we make any material changes to the way we process your Personal Information, we will notify you before such changes are effective. We recommend you review this Policy periodically. This Policy became effective on the date indicated at the top of this page. Your continued use of our Services after any changes or revisions to this Policy indicates your agreement to the terms of the revised Policy.
1. Collection of Personal Information
When you use our Services, we may collect or receive Personal Information about you to provide our services and operate our business. The types of Personal Information that we may collect about you are:
a. Information You Provide to Us Directly
You may provide your Personal Information to us when you use our Services, including when you register with SwitchApp, search our website, contact us with inquiries, respond to surveys, or otherwise access our Services. This information may include:
• User Profile – We collect profile information associated with your Customer SwitchApp account. This includes information such as name, age, email address, residential address, and phone number.
• Payment Information – Payment information collected such as bank name and payment method.
• Surveys – From time-to-time, we invite our customers and users to participate in surveys or contests. When a customer or a user participates, we may request certain Personal Information such as name and email address.
b. Information Received from You as Part of Your Communications
When you use our Services (for example on our Site), complete electronic forms or contact us, by online chat, email, phone or text, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; your order details; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request.
c. Information Collected Automatically
We also may receive and store certain information about you and your device(s) automatically when you access or use our Site and Services. This information may include:
d. Location Information
When you use the Services, we may collect and store general location information (such as IP address). If you permit the Services to access location services through the permission system used by your mobile operating system ("Platform") or browser, we may also collect and store the precise location of your device when the SwitchApp website is running in the foreground or background of your device. You can choose whether to enable the location tracking feature through the settings on your device or Platform or when prompted by the SwitchApp website.
e. Information Related to the Referral Program
SwitchApp allows users to invite friends and family to sign up for our Services. So You can then direct us to send referral emails to contacts you select in your address book. By sending a referral, you also consent to SwitchApp sending your public profile image to the contacts you select to receive a referral link. By choosing to invite a friend you represent that you have received the friend's consent to provide his or her name and email address with us. SwitchApp will use that information to send an email inviting him or her to visit the site and will store that information to track the success of the referral program and may send marketing emails. You can also send an SMS with a referral link to your contacts. If you use this option, you understand that SwitchApp does not control the timing, content, or recipients of these SMS messages.
Users may not send, publish, or share any false, misleading, or deceptive communications in connection with participation in the Referral Program. Such actions may violate various federal, state, and/or international laws. Users may not send any referral emails, SMS messages, or other communications to children under the age of 18 years.
If you are referred to SwitchApp through one of our referral programs, or if someone attempts to refer you, we may share your name, whether you have already signed up for SwitchApp, whether you are a new customer, and whether you have placed a qualifying order with SwitchApp with the person(s) who referred you.
f. Personal Information from Publicly Available Sources and Third Parties
We may collect or receive Personal Information about you from publicly available sources, social network providers, marketing partners, and/or third parties. This may include
1. Use of Your Personal Information
1.1.We may use the information we collect or receive about you for various purposes:
• To provide you with the Services which you request.
• To verify your identity for security purposes.
• To market our Sites and Services, and the Products of third-party Sellers.
• In other ways naturally associated with the circumstances in which you provided the information.
• To process your payments, if you purchase any our services, to provide you with status on services, deal with your enquiries and requests, and access and handle any complaints.
• To facilitate delivery.
• To process and answer your inquiries or to contact you to answer your questions and/or requests.
• To develop and improve the products, services, communication methods and the functionality of our Sites.
• For the purposes of competitions or promotions that you have entered.
• To communicate information to you and to manage your registration on our Sites and/or subscription to our newsletter or other communications.
• To manage our everyday business needs regarding your participation in our contests, or promotional activities.
• To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise.
• For internal training and quality assurance purposes.
• To understand and assess the interests, wants, and changing needs of consumers, to improve our Sites, our Services, and/or developing new products and services.
• To provide personalised Services, communications and targeted advertising as well as product recommendations to you.
2.2 If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy. We use this data to profile your likes and dislikes.
2.3 We may also use information you have provided to selected third parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.
2.4 Information we collect about your computer, which may at times be able to identify you, for any lawful business purpose, including without limitation to help diagnose problems with our servers, to gather broad demographic information and to otherwise administer our Sites.
2.5 Information which does not identify any individual may be used in a general way by us or third parties, to provide class information, for example relating to demographics or usage of a particular page or service.
2.6 Your domain name and e-mail address are recognised by our servers and the pages that you visit are recorded. We shall not under any circumstances, divulge your e-mail address to any person who is not identified in this Policy. This information is used:
• to correspond with you or deal with you as you would expect;
• in a collective way not referable to any particular individual, for the purpose of quality control and improvement of our Sites;
• to send you news about the Services to which you have signed up;
• to tell you about other of our Services or services of related web sites.
2.8. You may opt-out from receiving future promotional information from us or direct that we do not share your information with any affiliated companies.
2.9. We may use, transfer and share aggregated, anonymous data about our users as a group for any business purpose, such as analysing usage trends and seeking compatible advertisers and partners.
3. Who will your Personal Information be shared with?
You agree that We may disclose Your personal information to the following persons:
• to our employees and/or third party service providers, such as payment processors (including their employees and/or third party service providers), to process use of the Services by You properly and efficiently and in order for them to interact directly with You via email or any other method for purposes of sending You marketing material regarding services, new features, special offers or promotional items offered by them (unless you have opted out from receiving such marketing material);
• to law enforcement, government officials, fraud detection agencies or other third parties when We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report or support the investigation into suspected illegal activity, or to investigate violations of the Terms.
• to our service providers (under contract with us) who help with parts of our business operations (fraud prevention, marketing, technology services etc.). Our contracts dictate that these service providers may only use your Personal Information in connection with the services they perform for us and not for their own benefit;
• to third parties' sponsors of promotions (irrespective of whether such promotions are hosted by us), or otherwise in accordance with the rules applicable to such promotions. You should carefully review the rules, if any, of each promotion in which you choose to participate, as they may contain additional important information about our, a sponsor's and/or other third parties' use of your personal information;
• to third party business partners like manufacturers and Sellers (in which case we will have agreements in place to secure the confidentiality of your Personal Information);
• to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any insolvency and/or similar proceedings);
• to the general public when you provide a rating or review of service received, you consent to us using that rating/review as we deem fit, including without limitation on the Sites, in newsletters, or other marketing material. The name that will appear next to that review will be your first name, as you would have provided upon registration. We will not display your surname, nor any of your contact details, with a rating or a review;
• To any person other than as described herein if we notify you and you consent to the sharing;
• If you provide information to us with a view to it being read, copied, downloaded or used by other people, we accept no responsibility for what that third party may do with it. It is up to you to satisfy yourself about the privacy level of every person who might see your information. If it is available to all the World, you have no control whatever as to how it is used;
• to assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money;
• for re-marketing. This involves Facebook or some other supplier placing a tag or marker in order to be able to serve to you an advert for our Services when you visit some other website;
• When we receive a complaint, we record all the information you have given to us. we use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. It is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
• Your Personal Information will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment and other offers, as well as product information, product development and development and expansion of our Services.
• Your Personal Information will be used by us or shared within our group of companies for internal reasons, primarily for business and operational purposes.
• As we continue to develop our business, we may sell or purchase assets, subsidiaries or business units. In such transactions, your Personal Information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Policy.
• If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to our Sites and/ or Services, your Personal Information will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets.
• In the event of insolvency, business rescue or reorganization proceedings being brought by or against us, all such Personal Information will be considered an asset of ours and as such it is possible, they will be sold or transferred to third parties.
• We will ensure that all of our employees, third party service providers, divisions, affiliates and third-party business partners (including their employees and third party service providers) having access to your personal information are bound by appropriate and legally binding obligations in relation to the confidentiality and security of your Personal Information and are restricted in their processing thereof as per this Policy.
You may at any time request:
• confirmation that we hold your personal information;
• access to your personal information to view and/or update personal details;
• the identities or categories of third parties to whom we have disclosed your personal information; or
• that we correct or delete any personal information that is incomplete, misleading, inaccurate, excessive or out of date
• Requests must be made in writing to (email address).
4. Automated Decision Making
6.1.We conduct fraud checks on all customers. Where we believe we may detect fraudulent activity we may block you from using our Sites.
6.2.We share your information with and undertake fraud checks on all customers because this is necessary for us to perform our contracted services to customers, by ensuring that the services we (and retailers) provide are duly paid for, and also so that individuals themselves are protected from fraudulent transactions on their cards.
6.3.You have certain rights in respect of this activity - please see 'Your Rights' section below for more information. Our fraud detection is in place to protect all our customers as well as SwitchApp. You have the right to contest any fraud decision made about you and to be given more information about why any such decision was made by contacting us.
7. What are your rights?
We provide our customers and their authorized agents with the ability to access and delete Personal Information. In order to exercise these rights, you must login to your account to confirm your identity, which helps us ensure that Personal Information is only made accessible to appropriate parties. Customers will not receive discriminatory treatment for exercising their rights and can return to the service after deleting their information.
a. Your Rights
This section lists the privacy-related rights ("Rights") we extend to all SwitchApp user. Your right to know and right to deletion are not absolute and are subject to certain exceptions.
• Right to Know – You have the right to know the Personal Information we collect, use, disclose, and sell about you.
• Right to Deletion – You have the right to request that we delete any Personal Information we have collected from you or maintain about you. We may save Personal Information when permitted by applicable law including, without limitation, when the information is needed for a legal purpose.
• Right to Rectification – If you are a registered SwitchApp web user you may modify certain of your Personal Information by logging into our Site using your username and password and visiting the "Account" page. Registered SwitchApp user may also access the "Account" page to manage their subscriptions.
• Right to Opt-Out of the Sale of Your Personal Information – You have the right to opt-out of having your Personal Information sold.
• Right to Non-Discrimination – SwitchApp will not discriminate against those who exercise their Rights. Specifically, if you exercise your Rights, we will not deny you goods or Services, charge you different prices or rates for our Services and products or provide you different level or quality of products or Services.
b. Asserting Your Rights
• If you have a SwitchApp app, you may exercise your right to know or your right to deletion by clicking here for SwitchApp. To verify your identity, you must log in to your account prior to accessing or deleting your information.
• If you do not have a SwitchApp, you may exercise your right to know or your right to deletion by emailing your request to us at (support@switchappgo.com), with the subject line "Non-user Data Request" or calling us at +234-909-246-9047 For safety and to otherwise prevent fraud, we may ask that you provide us with certain personal information that's reasonably necessary for us to confirm your identity.
• You may also designate an authorized agent to make a request to know or a request to delete. To be able to act, authorized agents must submit written proof that they are authorized to act on your behalf or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf.
8. How We hold personal information securely
8.1.We will treat Your personal information as strictly confidential, save where we are entitled to share it as set out in this Policy.
8.2.In all circumstances the information is held by us on our secure systems. We take all reasonable and appropriate organisational steps to ensure that your personal information is kept secure and is protected against unauthorised or unlawful processing, misuse, unauthorised disclosure, loss, interference, destruction or damage, alteration, disclosure or access.
8.3.Our security systems are in line with industry standards, and we monitor developments to ensure that our security systems evolve, as required. We also test our systems regularly.
8.4.Personal information is destroyed or anonymised when no longer needed or when we are no longer required by law to retain it (whichever is the latter).
8.5.We will promptly notify you if we become aware of any unauthorised use, disclosure or processing of your personal information.
8.6.We may store your personal information with the web hosting service provider appointed by us from time to time. The storage may be in Nigeria or in any other country.
8.7.Where storage is in another country, your personal information will be stored in a jurisdiction that has equivalent, or better, data protection legislation than Nigeria or with a service provider which is subject to an agreement requiring it to observe data protection requirements equivalent to or better than those applicable in Nigeria.
9.
We use cookies, web beacons, pixels, session replay/seen capture, and similar technologies to collect information and personalize your experience with our Services. When we use session replay technology, we may collect on real-time basis information on how you use and navigate the Services. This may include mouse movements and how you scroll through the Services, but we do not collect keystroke data. Additional information on other technologies we may use is set forth below.
a. Cookies
Cookies are small web files that a site or its provider transfers to your device's hard drive through your web browser that enables the site's or provider's system to recognize your browser and remember certain information.
i. How We Use Cookies – We use first-party and third-party cookies for the following purposes:
• to make our Services function properly;
• to improve our Services;
• to recognize you when you return to SwitchApp and to remember information you have already provided,
• to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and
• to provide a secure browsing experience during your use of our Services.
ii. How to Manage Cookies " You may disable the use of cookies by modifying your browser settings. If you choose to disable cookies you may not be able to fully experience the interactive features of our Services. For more information on cookies and how to disable cookies visit https://www.switchappgo.com/cookie-policy.
b. Web Beacons
Web beacons, also known as web bugs, pixel tags, or clear GIFs, are tiny graphics with a unique identifier that may be included on our Site to deliver or communicate with cookies, in order to track and measure the performance of our Site and Services, monitor how many web visitors we have, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user's hard drive, web beacons are typically embedded invisibly on webpages (or in an email).
c. Interest-Based Advertising
We (or our service providers) may use the information we collect, for instance, IP addresses and unique mobile device identifiers, to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content and features and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your device settings. We may also use cross-device targeting to help identify our users and serve advertising. This type of advertising is often called "interest-based" or "personalized" advertising–and it occurs on mobile apps, "cross-app" advertising.
Please note that even if you opt-out, you may still receive advertisements from us. However, in that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs.
d. Mobile Applications
Depending on your permissions, we may receive your Personal Information from your Internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Each operating system, (iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You should view your device or system "Settings" to determine how you can opt out of use of your device ID for "cross-app" personalized advertising.
10. Disclaimer and Indemnity
Whilst we will do all things reasonably necessary to protect your rights of privacy, we cannot guarantee or accept any liability whatsoever for unauthorised or unlawful disclosures of your personal information, whilst in our possession, made by third parties who are not subject to our control, unless such disclosure is as a result of our gross negligence or noncompliance with applicable laws.
If you disclose your personal information to a third party, such as an entity which operates a website or mobile application linked to the Sites or anyone other than SwitchApp, SWITCHAPP SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED BY YOU AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION TO THE THIRD PARTY. This is because we do not regulate or control how that third party uses your personal information. You should always ensure that you read the privacy notice of any third party.
11. Age Restriction
The Sites are not directed to and/or intended for use by individuals under the age of 18 years and We request that such individuals not use the Sites and not provide personal information through the Sites.
Persons under the age of 18 years are not allowed to register for the Service or use the Sites in anyway.
If a user attempts to register and inputs a birthdate validating them younger than 18 years of age, their personal information is not stored and they are directed off the platform.
12. Security
SwitchApp has implemented administrative, technical, and physical security controls that are designed to safeguard Personal Information. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Information is absolutely secure. Please keep this in mind when disclosing any information on the SwitchApp website.
Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the Contact Us section below.
13. Data Retention
We will not retain your information for any longer than we think is necessary. Information that we collect will be retained for as long as needed to fulfill the purposes outlined in the 'Use of personal information' section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.
When determining the relevant retention periods, we will take into account factors including:
a) our contractual obligations and rights in relation to the information involved;
b) legal obligation(s) under applicable law to retain data for a certain period of time;
c) statute of limitations under applicable law(s);
d) our legitimate interests where we have carried out balancing tests (see section on 'How we use your personal information' above);
e) potential disputes;
f) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
14. Third-Party Sites
Some of the functionality may be provided by third parties and the Services may link to other third-party websites that are not controlled by SwitchApp. These third parties are not under our control and SwitchApp is not responsible for their privacy policies or practices. If you provide any Personal Information to any third party or through any such third-party website, we recommend that you familiarize yourself with the privacy policies and practices of that third party.
15. Social Media Usage
15.1. You may choose to enable or log in to our Services via various online services, including social networking services like Facebook and Google. Our Services also may enable you to access social networking services such as Facebook, Twitter, or Instagram (collectively, "Social Network") directly or indirectly through our Services.
15.2. When you link a Social Network account to SwitchApp or log into our Services using your Social Network account, we may collect relevant Personal Information necessary to enable our Services to access that Social Network and your information contained within that Social Network. We also may share your information with the operator of that Social Network to facilitate or enhance delivery of that Social Network or other services to you. A Social Network may provide us with access to certain information that you have provided to them, and we will use, store, and disclose such information in accordance with this Policy. Additionally, a Social Network may collect Personal Information and information about your use of our Site and Services automatically.
15.3. The way a Social Network collects, uses, stores, and discloses your information is governed by the policies of such third parties and SwitchApp shall have no liability or responsibility for the privacy practices or other actions of any Social Network that may be enabled within our Services.
16. International Users
SwitchApp is based in Nigeria and, regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in Nigeria. Any information we obtain about you will be stored in accordance with Nigeria Data Protection laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in Nigeria.
17. Complaints
If you have any questions or complaints regarding this Policy/Privacy practices, please contact us by email at support@switchappgo.com.