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Privacy Policy

Last updated on September 23, 2019

The Workwise brand is owned and developed by Techbarn Limited (“we”, “us”), a company registered under the laws of the Federal Republic of Nigeria.

We respect your privacy and are committed to protecting your personal data.

This privacy policy describes how we look after the personal data of subscribers to our services through our website or mobile applications (our “Applications”) (collectively, such services, including any new features and applications, and our website is referred to herein as the “Services”) rendered to subscribers and or users of our Applications (“you”, “your”)

This privacy policy is provided in a layered format. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. DATA SECURITY
  7. YOUR LEGAL RIGHTS
  8. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This privacy policy aims to give you information on how we collect and processe your personal data through your use of our Applications, including any data you may provide through our Applications, while signing up to our Services or contacting us for support.

Our Applications are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

The Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, you are the controller of Business Contact Data. In general, we are the processor of Business Contact Data and the controller of other information relating to you which you have provided for our Services.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 18th September 2019.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third Party Links

Our Applications may include links to third-party websites, plug-ins and other applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, applications and we are not responsible for their privacy policies. When you leave our Applications to other websotes, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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 may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes contact address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, 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 Applications.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Applications and services such as details of communications you sent out via your account with us.
  • Location Information - for example, we may use the Location Services on your mobile device to provide certain functionality of our Services, including facilitating Visitor registration for your business contacts. Your location information is not made available to other users without your express permission
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide us Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location our servers and the External Third Parties referred to herein in the Glossary.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature on our Applications. 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 Policy.

This Privacy Policy does not apply to any Personal Data collected by us other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to us through any means. This includes, but is not limited to, information posted to any public areas of the Applications or the Services, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

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 perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

a) Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. You may also provide materials such as photographs, videos to our Applications. This includes Personal Data you provide when you:

  • apply for or use our services.
  • create an account on our Applications.
  • subscribe to our service or publications.
  • request marketing to be sent to you.
  • enter a competition, promotion or survey.
  • give us feedback or contact us.

b) Automated technologies or interactions: As you interact with our Applications, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this Personal Data by using cookies and other similar technologies.

c) Information from other sources: We may collect information from other services such as third-party service providers, payment processors, or advertising services. These may include device and location information, limited information on your card used for payment, prior visits to our Applications, or whether you opened an email campaign.

4. 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 perform the contract, we are about to enter into or have entered into with you such as using the information you provided to enable us provide you with such access and to monitor your use of our Services.
  • We and our subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected to help us improve the content and functionality of the Applications and Services, to better understand our users and to improve the Application and Services.
  • We provide Visitor registration and other work-related services. In connection with those Services, we have access to data or information submitted by your visitors or other business contacts (“Business Contact Data”) for hosting and processing purposes in connection with the Services. We only use Business Contact Data per the terms of our relevant agreement with you, or as may be required by law.
  • Your visitors or business contacts should note that by using the Services, they grant access to and share their Personal Data with you in an automated manner. Your use and disclosure of the Personal Data which they have made available through the Services is governed by the terms of your privacy policy or other agreements which you may have with them. This Privacy Policy does not govern the use of Personal Data provided by a Visitor.
  • 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 such as sharing this information with third-party service providers in order to provide the services to you. When we need to share information, we take the steps to ensure that only the necessary information is shared, and the information is protected and being used in accordance with this policy.
  • Where we need to comply with a legal obligation.

See Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your Personal Data

We have set out below, a description of all the ways we plan to use your Personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a subscriber to our Services (a) Identity
(b) Contact
(c) Financial
(d) Usage
Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or Privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d)Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e)Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how you use our products/services, to develop them and grow our business
To administer and protect our business and Applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our Applications,products/services, marketing, client relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Applications updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about our services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional offers from 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 subscribed to our services, provided your Personal Data on our Applications and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

International Information Transfer

As part of providing our services to you, your Personal Data may be transferred, stored or processed in a country other than where you are located. We will ensure a similar degree of protection is afforded to your Personal Data in such location.

Change of Purpose

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.

Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your Personal Data with the parties as set out below:

  • Related Companies for providing our Services and any use by Related Companies will be consistent with this Privacy Policy.
  • External Third Parties as set out in the Glossary below.
  • 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 Policy.

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 third-party service providers 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.

6. 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.

7. DATA RETENTION

How long we will use your Personal Data for

We will only retain your Personal Data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

We may continue to store your information for a reasonable amount of time after you cancel your paid subscription or becomes inactive, in the case that you wish to reactivate your account.

In some circumstances we may 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 and same shall be retained to help us improve our Services.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data such as: Please see glossary below to find out more about these rights.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9. GLOSSARY

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to you or our Services or to take steps at your request before entering into such a contract or providing such Services.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

Service providers such as agents, consultants and related Third Parties. We, like many businesses, sometimes hires other companies and non-employee individuals to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting services.

Your Legal Rights

You have the right to:

  • Request access to your Personal Data (commonly known as a “data subject access request”). 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 particular 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 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.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. Your continued use of our Applications after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.