This Privacy Policy explains the collection, use, and sharing of personal data when you use the Naijamart.com website or any Naijamart.com mobile application and the services provided through it (collectively, the “Service”).
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 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 a case, please contact the support team via email to request the deletion of your account and data.
TABLE OF CONTENTS
- PERSONAL DATA CONTROLLER
- CATEGORIES OF PERSONAL DATA WE COLLECT
- DATA PROTECTION PRINCIPLES
- PURPOSES FOR PROCESSING PERSONAL DATA
- LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
- SHARING YOUR PERSONAL DATA
- AVAILABLE REMEDIES
- NO LIMITATION CLAUSE
- EXERCISING YOUR PRIVACY RIGHTS
- AGE LIMITATION
- CHANGES TO THIS PRIVACY POLICY
- DATA RETENTION
- CONTACT US
PERSONAL DATA CONTROLLER
NAIJAMART.COM Online Marketplace Nigeria Limited, a company registered in the Federal Republic of Nigeria (with a registered office at 350, Borno Way, Yaba, Lagos, Nigeria), will be the controller of your personal data.
Cars45 Limited, a company registered in the Federal Republic of Nigeria (with a registered office on the 4th Floor, CIPM House, CIPM Avenue, CBD, Alausa, Ikeja, Lagos), will be the joint controller of the following categories of personal data:
In relation to certain categories of personal data expressly specified below 2.3.5
• a) car dealers’ transaction data relating to sales at the car auction (paragraph 2.3.5.)
• b) personal ID, Bank ID, and САС of car dealers (clause 2.1.)
• c) the Required Information of car sellers and car dealers (clause 2.1.)
CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you voluntarily provide (e.g., email address) and data collected automatically (e.g., your IP address).
2.1 Data you provide us
You may be asked to provide information about yourself when you register for and/or use the Service. This information includes first name, last name, phone number, email, gender, date of birth (collectively, “Required Information”), address details, working hours, etc., as well as access to your photos, albums, and their metadata. If you want to post an advertisement in the Mobile Phones category, unblock your account, or create a duplicate account, you will need to provide us with your ID or similar identification document. To participate in the car auction as a dealer, you will need to provide us with your Bank ID and САС (certificate of incorporation of a legal entity).
To use our Service and register an account, you need to provide the Required Information. You can still use the Service without providing this data, but certain functionalities may be limited (e.g., inability to chat with other users, post ads, see contact details of other users). Sometimes, you may need to provide additional information to our Support Team to fulfill your request (e.g., confirming your identity by providing an ID document if your account was previously blocked).
When posting an announcement on the Service, you can choose to provide additional personal information about yourself, such as your CV or photos. By providing personal data in the announcement, you acknowledge that it will be publicly available. You also acknowledge and agree that certain personal data from your profile will be made public to facilitate communication and transactions between users. For example, your email will be shown as part of your advertisement in the Seeking Work CVs section to users with posted advertisements in the Jobs section.
You should carefully consider the risks associated with making certain information publicly available, such as your phone number, address, photos, passport, financial details, or exact location.
If you want to apply for a car loan, you need to provide us with your employment type (Salary Earner or Business Owner), monthly income/salary, and Bank Verification Number (BVN). We will use this information to calculate amounts for the first and subsequent monthly installments.
2.2 Data provided to us by third parties
When you log in using Facebook, we receive personal data from your Facebook account, including your profile image, name, and Facebook ID. We may also collect additional data such as email address, gender, date of birth, friends list, and location from your Facebook profile unless you opt out on the Facebook Login screen. You can control the choices you made when connecting your Facebook profile to the App on their Apps and Websites page.
When you log in with Google, we receive your name, email address, profile picture, and Google ID. We use your personal data from Google in accordance with this Privacy Policy. To learn more about how Google processes your data, visit its Privacy Policy. You can remove granted access by visiting Google Permissions.
When you log in using Apple, we receive your Apple ID, name, and email from your account. You can use the Hide My Email function during signing in with Apple, which will create and share a unique, random email address that will forward our messages to your personal email. You can revoke access on your Apple ID Manage Page.
When you log in or verify your phone number using Truecaller, we receive personal data from your Truecaller user profile upon your consent. This includes your phone number, name, address (country code, city, street, zip code), profile image, job title, company name, gender, and other information from your profile. For more information, please refer to the Truecaller Privacy Policy.
If you were invited to create an account in the Service, the person who invited you may provide personal information about you, such as your phone number, email address, social media account, or other contact information.
We may collect your name, official government ID number, and photo image to confirm your identity. For this, we will share this information with a third-party service provider, Smile Identity Inc., to validate it with governmental sources. Smile Identity Inc. may collect additional data on you from governmental sources based on your ID number. Smile ID may process or store your data outside the borders of your country.
2.3 Data we collect automatically
Data about how you found us
We collect data about your referring URL, which is the place on the web where you were when you tapped on our ad.
2.3.2 Device and Location Data
We collect data from your device, such as language settings, IP address, time zone, device type and model, device settings, operating system, internet service provider, mobile carrier, hardware ID, and Facebook ID.
2.3.3 Usage data
We record how you interact with our Service, including the features and content you interact with, how often you use the Service, how long you are on the Service, which sections you use, and how many ads you watch.
2.3.4 Advertising IDs
We collect your Apple Identifier for Advertising (IDFA) or Google Advertising ID (AAID), depending on your device’s operating system. You can typically reset these numbers through your device’s operating system settings.
2.3.5 Transaction data
When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. While we do not collect or store full credit card number data, we may receive credit card-related data and transaction information, including the date, time, and amount of the transaction, as well as the type of payment method used.
DATA PROTECTION PRINCIPLES
In our data protection practices, we strive to ensure that personal data is:
• Processed in accordance with specific, legitimate, and lawful purposes that you have consented to.
• Adequate, accurate, and respectful of the dignity of individuals.
• Stored only for the period necessary to achieve the intended purposes.
• Secured against reasonably foreseeable hazards and breaches, such as theft, cyberattack, viral attack, dissemination, manipulation, damage by natural elements like rain or fire.
PURPOSES FOR PROCESSING PERSONAL DATA
We process your personal data for the following purposes:
4.1 To provide our Service
This includes enabling you to use the Service seamlessly and addressing any errors or technical issues that may arise.
4.2 To customize your experience
We process your personal data to tailor the content of the Service and provide offers that are personalized to your preferences and interests.
4.3 To manage your account and provide customer support
We process your personal data to respond to your requests for technical support, provide Service information, or address any other communication initiated by you. This may involve accessing your account to handle technical support requests. We may also send you notifications or emails about the performance of our Service, security, payment transactions, or updates regarding our Privacy Policy.
4.4 To communicate with you regarding your use of our Service
We communicate with you through push notifications or in-app chat. For example, you may receive notifications about new messages on Naijamart. You can opt-out of receiving push notifications by adjusting the settings on your browser or mobile device. To opt-out of specific types of emails, you can follow the unsubscribe link in the email or contact our support team at support@naijamart.com. The services we use for these purposes may collect data on when users view or interact with messages, such as clicking on included links.
4.5 To research and analyze your use of the Service
We analyze how you use our Service to better understand our business, improve our operations, innovate, plan, design, and develop Naijamart and new products. We also use this data for statistical analysis and to test and enhance our offerings. By doing so, we gain insights into user preferences and make informed decisions on improving Naijamart. For example, if we discover that the Jobs section is less popular, we may focus on improving it.
4.6 To send you marketing communications
We process your personal data for our marketing campaigns, which may involve adding your email address to our marketing list. Consequently, you will receive information about our products, such as special offers and products from our partners. If you do not wish to receive marketing emails, you can unsubscribe using the instructions provided in the email or by contacting our support team at support@naijamart.com. We may also display advertisements on the website and send you push notifications for marketing purposes. To opt-out of push notifications, you can adjust the settings on your device and browser.
4.7 To personalize our ads
We and our partners use your personal data to tailor ads and display them to you at the relevant time. For example, if you have visited our website, you may see ads for our products in your Facebook feed. We may use various advertising technologies on and off our Services, such as unique cookies or similar tracking technology, pixel, device identifiers, geolocation, operating system information, and email. If you wish to opt-out or affect personalized advertising, you can follow the instructions provided by your device’s operating system or visit the relevant links provided in our Privacy Policy.
4.8 To enforce our Terms and Conditions of Use and prevent fraud
We use personal data to enforce our agreements, detect, prevent, and combat fraud. As part of this process, we may share your information with law enforcement agencies if a dispute arises in connection with our Terms of Use.
4.9 To comply with legal obligations
We may process, use, or share your data when required by law, particularly in response to requests from law enforcement agencies through legal means.
4.10 To process your payments
If you use paid products or services within the Service, we will process your personal data for payment processing purposes, using third-party payment service providers. This allows you to make payments and access the paid features of the Service.
LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
We process your personal data based on the following legal bases:
5.1 Your consent
We rely on your consent to process your personal data, particularly when using cookies.
5.2 Performance of a contract
We process your personal data to fulfill our contract with you, which includes providing the Service and its features.
5.3 Legitimate interests
We rely on legitimate interests to process your personal data for the following purposes:
• Communication regarding your use of the Service: We have an interest in encouraging you to use our Service and addressing your needs and inquiries effectively.
• Research and analysis of your use of the Service: We have an interest in improving our Service, understanding user preferences, and enhancing the user experience.
• Marketing communications: We have an interest in promoting our Service in a measured and appropriate manner.
• Personalization of ads: We have an interest in promoting our Service in a reasonably targeted way.
• Enforcement of Terms and Conditions and prevention of fraud: We have an interest in protecting our rights, preventing fraud, and ensuring compliance with our Terms of Use.
5.4 Compliance with legal obligations
We may process your personal data to comply with legal obligations imposed by applicable laws.
SHARING YOUR PERSONAL DATA
We share information with third parties who assist us in operating, providing, improving, integrating, customizing, supporting, and marketing our Service. We may share sets of personal data for the purposes and with the parties indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include:
6.1 Service providers
We share personal data with third-party service providers that we engage to provide services or perform business functions on our behalf. These providers include cloud storage providers (e.g., Amazon, DigitalOcean, Hetzner), data analytics providers (e.g., Facebook, Google, Appsflyer), login service providers (e.g., Google, Apple, Facebook, Truecaller), marketing partners (e.g., social media networks, marketing agencies, email delivery services), payment services providers (e.g., Solid), and local banks and credit organizations (e.g., Access Bank, Sterling Bank, Union Bank, Sovereign Finance, Purple Money, etc.).
6.2 Law enforcement agencies and public authorities
We may use and disclose personal data to enforce our Terms of Use, protect our rights, privacy, safety, or property, respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or as required by law.
6.3 Third parties in a merger or acquisition
As we continue to develop our business, we may buy or sell assets or business offerings. In such transactions, customer information, including personal data, may be one of the transferred assets. We may also share personal data with affiliated entities such as parent companies or subsidiaries during corporate transactions like the sale of our business, merger, consolidation, or asset sale. In the unlikely event of bankruptcy, personal data may also be transferred.
AVAILABLE REMEDIES
In the event of a data breach that poses a risk to individuals’ rights and freedoms, we will notify the relevant supervisory authority if required. If the breach is assessed as high-risk, we will also notify the affected data subjects promptly. The timeframe for such notification will be determined based on the number of affected individuals and the time required to collect contact information for notifications. If you believe that the measures taken or proposed to address a breach are insufficient, you have the right to lodge a complaint with the competent supervisory authority or seek legal redress.
NO LIMITATION CLAUSE
No limitation of liability will absolve us of our responsibility if we act in breach of the principles outlined in Section 3.
EXERCISING YOUR PRIVACY RIGHTS
To exercise your privacy rights, including accessing, reviewing, updating, correcting, or deleting your personal data, you can make changes in the settings section on the Naijamart website. If you wish to delete your personal data or limit its use, you can send a request to support@naijamart.com or delete your account using the provided link. We will make reasonable efforts to fulfill your request, keeping in mind any legal obligations that may require the retention of certain data. You also have the right to object to or restrict the use of your personal data, as well as the right to lodge a complaint with a supervisory authority.
AGE LIMITATION
We do not knowingly process personal data from individuals under 16 years of age. If you become aware that someone under 16 has provided us with personal data, please contact us at support@naijamart.com.
CHANGES TO THIS PRIVACY POLICY
We may update or modify this Privacy Policy from time to time. If there are significant changes, we will notify you through our Service or other available means and provide an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after the changes take effect, you agree to be bound by the updated Privacy Policy.
DATA RETENTION
We will store your personal data for as long as reasonably necessary to achieve the purposes outlined in this Privacy Policy, including providing the Service to you. This includes the duration of your Naijamart account. We may also retain and use your personal data to comply with legal obligations, resolve disputes, and enforce our agreements. Hashed email addresses, phone numbers, identification documents, and information regarding blocked accounts may be retained even after fulfilling deletion requests. Data retention is subject to our legal obligations, the resolution of disputes, and the enforcement of agreements.
CONTACT US
If you have any questions about this Privacy Policy or previous versions, or if you need assistance regarding your account or personal data, you can contact us at support@naijamart.com.