INTRODUCTION
This Privacy Policy sets out details of the Personal Information that SHARKEX
collects from you and how we use that personal Information. We also explain your
rights and how to contact us if you have any questions about your Personal
Information. SHARKEX is committed to protecting the privacy of the personal
information we collect. We understand that you take your privacy seriously. We do
too. Our Privacy Policy describes how we manage personal information, including
the kinds of personal information we collect, the purposes for which we collect
personal information, and how we hold, use and disclose personal information. By
using our products and services (including our website) or by providing your
personal information to us you agree to the terms of this Privacy Policy.
In this Privacy Policy, terms such as “we”, “us, “our” or similar expressions shall
mean SHARKEX
We take your privacy very seriously and are committed to protecting your personal
data (meaning any information about you from which you can be identified). This
Privacy Policy explains what personal data we collect when you: use our products
and/or services or access SHARKEX’ websites at https://www.Sharkex.com, use our
official app; or engage us on our social media platforms (including our Facebook,
Twitter and Instagram pages); and/or when you otherwise interact or communicate
with us. It also explains how we may use this data, and what rights you have in
relation to such data.
- BACKGROUND
We are a “Data Controller” under the Nigeria Data Protection Regulation, 2019
(the NDPR) and other applicable data protection legislation (Data Protection Law).
This means we are responsible for deciding how we use the personal data that we
collect about you and, in accordance with the NDPR, we will ensure that the
personal data we hold about you is, always: - used fairly, lawfully, and transparently;
- collected for limited, specific purposes only;
- adequate, relevant to and limited to what is necessary for those purposes;
- kept accurate and up-to-date;
- not kept for longer than is necessary; and
- held securely.
We shall be accountable for and able to demonstrate our compliance with our
obligations under the provisions of the National Information Technology
Development Agency Act, 2007 (“NITDA ACT’’) as well as the Nigeria Data
Protection Regulation 2019 (“NDPR”) Data Protection Law, and this Privacy
Policy is one of the ways in which we do that. - PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person
can be identified. We may collect and use various types of your personal data:
The types of personal information we collect will depend on the circumstances in
which the information is collected. However, the types of personal information we
collect and hold about you may include:
❖ Registration Data: To access and use some elements of the Services you
must create an account, by providing us with the information which is
identified on the relevant registration page: name, email, date of birth, and
country. We will also collect a username and password. Please note that
some elements of the Services will not be available if you do not provide the
required information. We may also ask or allow you to submit other optional
information, including your gender, phone number, post code.
❖ Identity Data: We also ask you to provide identification information when we
provide other elements of the Services: name, age, gender and social media
handles/ usernames.
❖ Contact Data: When we want to communicate with you, or you with us, we
use your email address, billing address, telephone numbers, social media
handles/ usernames and location (country/ place of residence).
❖ User Data: We collect your usage and preference details related to your use
of the Services such as language, statistics, scores, rankings, time spent on
our website, preferences, survey responses, feedback and other data that
you provide to us as part of your account. information and how your device
has interacted with our website, including the pages accessed and links
clicked
❖ Marketing and/ or Communications Data: We retain your preferences in
receiving marketing messages from us and commercial partners, and your
communication preferences.
❖ Technical Data: Certain data is automatically generated and collected by us
when you use the Services such as your IP address, MAC address and
other device identifiers; your clickstream to, through and from the Services
(including date and time); pages you viewed or searched for; length of visits
to certain pages; page interaction information (such as scrolling, clicks and
mouse-overs); methods used to browse away from the page.
❖ Financial Payment Data: – Due to the nature of the service we offer, we will
collect financial information, such as bank account or other payment details,
necessary to process your payment if you make purchases, such as your
payment instrument number (such as a credit card number), and the
security code associated with your payment instrument. All payment data is
stored by Google Play and Apple App Store. You may find their privacy
notice link(s) at https://policies.google.com/privacy and
https://www.apple.com/legal/privacy.
❖ Sensitive Data: – We may also collect sensitive information about you such
as information about your health, racial or ethnic origin, religious beliefs and
criminal record if you provide your explicit consent or if we are otherwise
allowed or required by law
Information collected through our App
We collect information regarding your mobile device, push notifications, when you
use our App. We collect the following information:
▪ Mobile Device Access: We may request access or permission to certain
features from your mobile device, including your mobile
device’s camera, and other features. If you wish to change our access or
permissions, you may do so in your device’s settings.
▪ Mobile Device Data: We automatically collect device information (such as
your mobile device ID, model and manufacturer), operating system, version
information and system configuration information, device and application
identification numbers, browser type and version, hardware model Internet
service provider and/or mobile carrier, and Internet Protocol (IP) address
(or proxy server). If you are using our App, we may also collect information
about the phone network associated with your mobile device, your mobile
device’s operating system or platform, the type of mobile device you use,
your mobile device’s unique device ID and information about the features
of our App you accessed.
▪ Push Notifications: We may request to send you push notifications
regarding your account or certain features of the App. If you wish to opt-
out from receiving these types of communications, you may turn them off
in your device’s settings.
This information is primarily needed to maintain the security and operation of our
App, for troubleshooting and for our internal analytics and reporting purposes.
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
information but is not considered personal information under applicable
regulations 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 and/or app feature. However, if we combine or
connect aggregated data with your personal information so that it can directly or
indirectly identify you, we treat the combined data as personal information which
will be used in accordance with this privacy policy - HOW WE COLLECT YOUR PERSONAL DATA
We may collect personal information about you in the following ways
- access or use our Products and Services.
- create an account on our App
- request information, marketing and other communications to be sent to you
- enter a competition, promotion or survey
- complete surveys or provide us with your feedback; and
- otherwise interact or correspond with us (including via email, social media
or telephone). - when you submit a query to us
- by tracking your use of our products and services (including our website);
from third parties who are entitled to disclose that information to us - from publicly available sources
- from online sources (including social media platforms and providers (e.g.
LinkedIn);
In connection with some elements of the Services we also receive additional
personal data about you from other organisations who have collected personal
data from you and data collected on our behalf at any of our events. We may also
receive personal data as part of the legal processes we undertake to protect our
Services and our intellectual property, such as our brand or media rights, or those
of our licensees/commercial partners.
We may also collect personal data about you and your use of our website, products
and services using cookies. We use cookies to monitor and observe your use of
our website, products and services, compile aggregate data about that use, and
provide you with a more effective service (which may include customising parts of
our website based on your preferences and past activities on that website. Cookies
are small, usually randomly encoded, text files that help your browser navigate
through a particular website. The cookie file is generated by the website you are
browsing and is accepted and processed by your computer’s browser software.
The cookie file is stored in your browser’s folder or subfolder
We also use third party tools to help us manage and analyse our social media
presence, and report on comments, mentions and other content that is posted
about us on social media sites and other public channels and forums. These third
parties’ activities, and their information collection and sharing practices, are
subject to the terms of the relevant social media site, channel or forum..
- HOW DO WE USE PERSONAL INFORMATION?
Depending on how you use our products and services, your interactions with us,
and the permissions you give us, the purposes for which we use your Personal
Information include:
- Verify your identity when you are dealing with us.
- Determine your eligibility for any of our products or services.
- Maintain our relationship with you
- Enable us to provide you or your organisation with our products and services
- Answer your queries and requests.
- To manage and respond to any queries or complaints to our customer
service team. - To improve and maintain our products and services and monitor their usage.
- For market research, e.g. we may contact you for your opinions and
comments. - To send you marketing messages and show you targeted advertising, where
we have your consent or are otherwise permitted to do so. - For security purposes, to investigate illegal activities such as fraud and
where necessary to protect ourselves and third parties. - To investigate breaches of our contracts, policies or Terms and Conditions.
- To comply with our legal and regulatory obligations.
- Assess, operate, maintain, upgrade and improve our products and services
(including our website) - Provide better products, services and information to our customers and to
the community. - Carry out education and training programs for our employees.
- Manage and resolve any legal or commercial complaints or issues (including
debt recovery) - Meet our obligations and perform our functions under applicable laws and
agreements - Maintain and update our records
- Use in accordance with any request or instructions from you
- Carry out planning and forecasting activities and other internal business
processes - Keep you informed about our activities and notify you of changes to our
products or services - Make special offers related to our products or services that we think may be
of interest to you - Use as otherwise required or authorised by law or government agency.
- We may use and disclose your personal information for marketing purposes
(but we will not sell your personal information to any third party). - We may also use your personal information for any other purpose as
authorised by you.
We rely on the following legal bases, under data protection law, to process your
Personal Information: - Because the processing is necessary to perform a contract with you, or take
steps prior to entering into a contract with you (e.g. where you have made
a purchase with us, we use your Personal Information to process the
payment and fulfil your order). - Because we have obtained your consent (e.g. where you contact us with a
query, where you add optional information to your account profile, or if you
consent to receive marketing from us). You are free to withdraw your
consent at any time. - Because it is in our legitimate interests in operating our business, for
security purposes, to protect our staff, business and reputation, for fraud
prevention and to operate and promote the business. For example, we are
always seeking to engage more with our users and we use information about
you to tailor your view of our Sites (and the messages we send to you) to
make them more relevant to you. We also combine information we collect
about you with aggregated information about our products and service
offerings, to increase our understanding of our users. - Because the processing of information relating to actual or suspected
criminal activity is necessary for the purposes of the prevention or detection
of crime.
- HOW DO WE USE YOUR PERSONAL INFORMATION FOR MARKETING &
ADVERTISING?
Depending on your marketing preferences, we may use your Personal Information
to send you marketing messages by email, phone, SMS or post. Some of these
messages may be tailored to you, based on your online profile, your previous
browsing or activities, and other information we hold about you.
If you no longer want to receive marketing communications from us (or would like
to opt back in!), you can change your preferences at any time by contacting us via
any of the methods given at the in the ‘Contact us’ section at the end of this Policy,
or by using the ‘unsubscribe’ mechanism in the promotional message or updating
your contact preferences in your account. If you unsubscribe from marketing,
please note we may still contact you with service messages from time to time (e.g.
information about your legal rights). Once you unsubscribe, you may continue to
receive marketing messages for a few days while we take action on your
unsubscribe request.
❖ Social Media
You may also see adverts for SHARKEX on third party websites, including on social
media. These ads may be tailored to you using cookies (which track your web
activity, so enable us to serve ads to customers who have visited our Sites). Where
you see an ad on social media, this may be because we have engaged the social
network to show adverts to our customers, or users who match the demographic
profile of our customers. In some cases, this may involve sharing your email
address with the social network. If you no longer want to see tailored ads you can
change your cookie and privacy settings on your browser and these third party
websites. - WHO DO WE SHARE THIS PERSONAL INFORMATION WITH?
We may process or share your data that we hold based on the following legal
basis:
- Consent: We may process your data if you have given us specific consent
to use your personal information for a specific purpose. - Legitimate Interests: We may process your data when it is reasonably
necessary to achieve our legitimate business interests. - Performance of a Contract: Where we have entered into a contract with
you, we may process your personal information to fulfill the terms of our
contract. - Legal Obligations: We may disclose your information where we are legally
required to do so in order to comply with applicable law, governmental
requests, a judicial proceeding, court order, or legal process, such as in
response to a court order or a subpoena (including in response to public
authorities to meet national security or law enforcement requirements). - Vital Interests: We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential
violations of our policies, suspected fraud, situations involving potential
threats to the safety of any person and illegal activities, or as evidence in
litigation in which we are involved.
We may share your Personal Information with the following third parties: - With our Commercial Sponsors and Partners, as described in ‘With our
suppliers and service providers working for us, e.g. payment processors - With our professional and legal advisors.
- With third parties engaged in fraud prevention and detection.
- With law enforcement or other governmental authorities or regulatory
bodies, e.g. to report a fraud or in response to a lawful request. - In the event that we sell any business assets, your Personal Information
may be disclosed to a potential buyer. In this event, we will make reasonable
attempts to ensure the buyer will be bound by the terms of this Privacy
Policy. - Social media sharing entities
- Web and Mobile analytics platforms e. g Google Analytics
- Your representatives, advisers and others you have authorised to interact
with us on your behalf - Related entities within our corporate group
- Our employees and third parties including consultants, contractors,
suppliers, service providers, professional advisers and agents who need the
information to assist us with conducting our business activities - Payment system operators and financial institutions
- Parties identified at the time of collecting your personal information or as
otherwise authorised by you
- Sharkex COMMERCIAL SPONSORS AND PARTNERS
We team up with a selection of carefully chosen commercial sponsors and partners
as part of our Commercial Partners programme. Our Commercial Sponsors and
Partners include partners from a variety of sectors and is designed to support our
business and also to bring customers and Site users a diverse range of our
associated and branded offers.
If you have given your consent, we may contact you (including by post, phone,
SMS or email) in order to tell you more about the offers available to you and about
a range of other initiatives from us and on behalf of our Commercial Sponsors and
Partners. - HOW DO WE PROTECT YOUR INFORMATION?
We take the security of your Personal Information very seriously. We have put in
place technical and organisational security measures to prevent the loss or
unauthorised access of your Personal Information. Your Personal Information is
contained behind secured networks and is only accessed when necessary. A
limited number of people have special access rights to such systems and they are
required and bound to keep the information confidential. When you place orders
or access your Personal Information, we offer the use of a secure server. We
generally store the personal information that we collect in electronic databases,
some of which may be held on our behalf by third party data storage providers
(which may be located offshore). Sometimes we also keep hard copy records of
this personal information in physical storage facilities. We use a range of physical
and technical security processes and procedures to protect the confidentiality and
security of the information that we hold, and we update these from time to time.
These measures include: – restricting access to our physical and electronic
databases, and physical security such as security procedures for access to our
business premises; and – technological security procedures including password
protection, network firewalls, encryption, intrusion detection and site monitoring
where practicable to do so.
We also take steps to monitor access to and modification of your information by
our employees and contractors, and ensure that our employees and contractors
are aware of and properly trained in their obligations for managing your privacy
Whilst we have used our best efforts to ensure the security of your Personal
Information, please be aware that we cannot guarantee the security of information
transmitted over the internet. You also play an important role in keeping your
information secure by maintaining the confidentiality of any usernames and
passwords you use with our products and services (including our website) - MONITORING OF TELEPHONE CALLS
If you contact us by telephone, we may monitor or record the call for security
purposes and to improve the quality of services that we provide to you. - THIRD PARTY LINKS
Our Sites may include links to websites operated by third parties. These linked
sites have separate and independent privacy policies. We therefore have no
responsibility or liability for the content or activities of these linked sites. However,
we do seek to protect the integrity of our site and welcome any feedback about
these linked sites (including if a specific link does not work) by email or in writing
via the contact details given below.
11.DURATION OF STORAGE OF DATA
Personal data is only retained for as long as it is needed for the purpose for which
it was collected or as required by law. Within a reasonable time after the expiry of
this period, we will take reasonable steps to de-identify or destroy the personal
information which is in our possession or control. - YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
You have certain rights in respect of your Personal Information, including the right
to access, correct, restrict, and request the erasure of your Personal Information,
and obtain a copy of it in a machine-readable format.
You also have the right to object to your Personal Information being used for
certain purposes, including sending you marketing.
We will comply with any requests to exercise your rights in accordance with
applicable laws. Please be aware, however, that there are a number of limitations
to these rights, and there may be circumstances where we are not able to comply
with your request. To make any requests regarding your Personal Information, or
if you have any questions or concerns regarding your Personal Information, you
should contact us using the details below. - ERASURE OF DATA
You have a right to request the erasure or destruction of your personal information
when it is no longer necessary for the purpose for which it was originally collected,
it is not being used for the purposes for which it was collected, or you wish to
withdraw your consent for certain processing.
There may be cases where we are unable to comply with your request such as
where we need to continue processing your personal information to comply with
applicable laws. Such requests should be submitted in writing using the contact
details below. We may ask you to verify your identity before complying with your
request.
14.CONTACT US
If you have any queries on any aspect of our Privacy Policy or wish to exercise
any of your rights referred to above, please contact us by email
at Support@Sharkex.com or by post to Plot 800 Emannuel Aguna, Jabi, Abuja. - CHANGES TO OUR POLICY
In order to comply with the law and to meet our changing business requirements,
our policies and procedures are constantly under review. From time to time, we
may modify, alter or update this Privacy Policy. We will post the revised Privacy
Policy on the website, and so we encourage you to check back regularly.
This Privacy Policy was last updated in March 2022.
Right to Know and Opt-Out of Data Sharing or Sale
We are committed to maintaining transparency in how we collect, use, and disclose your personal information. In accordance with applicable data protection laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), you have the following rights:
Right to Know: You have the right to request information regarding whether we share your personal information with third parties, and if so, the categories of such information, the categories of third parties involved, and the purposes for such sharing. Under California law, “sharing” specifically refers to the disclosure of personal information to third parties for cross-context behavioural advertising, whether or not for monetary or other valuable consideration.
Right to Opt-Out: You also have the right to opt-out of the sale or sharing of your personal information with third parties. If you do not wish for your personal information to be sold or shared, you may submit a request at any time via [Insert link to “Do Not Sell or Share My Personal Information” form or page], or by contacting us at __.
Once we receive your request, we will act promptly in accordance with applicable laws to process your opt-out and limit any future sharing or sale of your data.
Please note that even after opting out, we may continue to use certain personal data internally or as otherwise permitted or required by law, including for security, legal compliance, and service provision purposes.