PrivacyPolicy

This Privacy Policy explains what personaldata is collected when you use the pasiparo.com any pasiparo.com mobileapplication, or website (“Pasiparo”, "Website", or "App")and the services provided through it (together with the Website and the App,the “Service”), how such personal data will be used, shared.

BY USING THE SERVICE, YOU PROMISE US THAT (I)YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU AREOVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TOTHIS PRIVACY POLICY FOR YOU). If you do not agree or are unable to make thispromise, you must not use the Service. In such case, you must contact thesupport team via online chat or email to (a) request deletion of your accountand data.

Process”, inrespect of personal data, includes to collect, store, and disclose to others.

TABLE OF CONTENTS

·        1. PERSONAL DATA CONTROLLER

·        2. CATEGORIES OF PERSONAL DATA WE COLLECT

·        3. DATA PROTECTION PRINCIPLES

·        4. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA

·        5. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA

·        6. WITH WHOM WE SHARE YOUR PERSONAL DATA

·        7. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

·        8. AGE LIMITATION

·        9. CHANGES TO THIS PRIVACY POLICY

·        10. DATA RETENTION

·        11. CONTACT US

1. PERSONAL DATA CONTROLLER

Pasiparo.com Online Marketplace NigeriaLimited, a company registered in Nigeria (with registered office at 91/93 MMWay Jibowu Busstop Yaba Lagos) will be the controller of your personal data.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (forexample, an email address). We also collect data automatically (for example,your IP address).

1.       Data you giveus

Youmay be asked to provide us information about yourself when you register forand/or use the Service. This information includes: first name, phone number,email (together “Required Information”), last name, photo, address details,working hours.

Touse our Service and register an account, you will need to provide RequiredInformation. You will be able to use the Service even if you do not give thisdata to us, but some Service’s functionality may be limited to you (forexample, if you do no register an account, you will not be able to chat withother users, post ads, see contact details of other users).

Sometimesyou may also need to provide to us additional information in the communicationwith our Support Team in order to fulfill your request (for example, if youraccount was previously blocked, we may ask you to confirm your identity byproviding an ID document).

2.       Data providedto us by third parties

Whenyou decide to log in using Facebook or Google, we get personal data from yourFacebook or Google account. This includes your profile image, name, email, FacebookID, Google ID, friends list. For more information, please refer to the FacebookPermissions Reference (describes the categories of information, which Facebookmay share with third parties and the set of requirements) and to the FacebookData Policy. In addition, Facebook and Google let you control the choices youmade when connecting your Facebook profile to the Website. To know more abouthow Google processes your data, visit its privacy policy. The informationobtained from third parties will be processed for the purposes described in andin accordance with this Privacy Policy.

3.       Data we collectautomatically:

o    Data about howyou found us

We collect data about your referring URL (thatis, the place on the Web where you were when you tapped on our ad).

o    Device andLocation data.

We collect data from your device. Examples ofsuch data include language settings, IP address, time zone, type and model of adevice, device settings, operating system, Internet service provider, mobilecarrier, hardware ID, and Facebook ID.

o    Usage data

We record how you interact with our Service.For example, we log the features, and content you interact with, how often youuse the Service, how long you are on the Service, what sections you use, howmany ads you watch.

o    Advertising IDs

We collect your Apple Identifier forAdvertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on theoperating system of your device). You can typically reset these numbers throughthe settings of your device’s operating system (but we do not control this).

o    Transactiondata

When you make payments through the Service,you need to provide financial account data, such as your credit card number, toour third-party service providers. We do not collect or store full credit cardnumber data, though we may receive credit card-related data, data about thetransaction, including date, time and amount of the transaction, the type ofpayment method used.

o    Cookies

A cookie is a small text file that is storedon a user's computer for record-keeping purposes. Cookies can be either sessioncookies or persistent cookies. A session cookie expires when you close yourbrowser and is used to make it easier for you to navigate our Service. Apersistent cookie remains on your hard drive for an extended period of time. Wealso use tracking pixels that set cookies to assist with delivering onlineadvertising. Cookies are used, in particular, to automatically recognize youthe next time you visit our Website. As a result, the information, which youhave earlier entered in certain fields on the Website may automatically appearthe next time when you use our Service. Cookie data will be stored on yourdevice and most of the times only for a limited time period.

3. DATA PROTECTION PRINCIPLES

In our data protection practices we strive to,in particular, to provide that personal data is:

1.     processed in accordance with specific,legitimate and lawful purpose consented to by you;

2.     is adequate, accurate and without prejudice tothe dignity of a human person;

3.     stored only for the period within which it isreasonably needed; and

4.     secured against reasonably foreseeable hazardsand breaches such as theft, cyberattack, viral attack, dissemination,manipulations of any kind, damage by rain, fire or exposure to other naturalelements.

4. FOR WHAT PURPOSES WE PROCESS YOUR PERSONALDATA

We process your personal data:

1.       To provide ourService

This includes enabling you to use the Servicein a seamless manner and preventing or addressing Service errors or technicalissues.

2.       To customizeyour experience

We process your personal data to adjust thecontent of the Service and make offers tailored to your personal preferencesand interests.

3.       To manage youraccount and provide you with customer support

We process your personal data to respond toyour requests for technical support, Service information or to any othercommunication you initiate. This includes accessing your account to addresstechnical support requests. For this purpose, we may send you, for example,notifications or emails about the performance of our Service, security, paymenttransactions, notices regarding our Terms and Conditions of Use or this PrivacyPolicy.

4.       To communicatewith you regarding your use of our Service

Wecommunicate with you, for example, by push notifications or in the chat. As aresult, you may, for example, receive a notification whether on the Website orvia email that you received a new message on Pasiparo. To opt out of receivingpush notifications, you need to change the settings on your browser or mobiledevice. To opt out of the certain type of emails, you need to follow anunsubscribe link located in the footer of the email by contacting our supportteam at support@pasiparo.com or in your profile setting.

Theservices that we use for these purposes may collect data concerning the dateand time when the message was viewed by our users, as well as when theyinteracted with it, such as by clicking on links included in the message.

5.       To research andanalyze your use of the Service

This helps us to better understand ourbusiness, analyze our operations, maintain, improve, innovate, plan, design,and develop Pasiparo and our new products. We also use such data forstatistical analysis purposes, to test and improve our offers. This enables usto better understand what features and sections of Pasiparo our users likemore, what categories of users use our Service. As a consequence, we oftendecide how to improve Pasiparo based on the results obtained from thisprocessing. For example, if we discover that Jobs section is not as popular asothers, we may focus on improving it.

6.       To send youmarketing communications

Weprocess your personal data for our marketing campaigns. We may add your emailaddress to our marketing list. As a result, you will receive information aboutour products, such as for example, special offers, and products of ourpartners. If you do not want to receive marketing emails from us, you canunsubscribe following instructions in the footer of the marketing emails, bycontacting our support team at support@pasiparo.com or in your profile setting.

Wemay also show you advertisements on the Website, and send you pushnotifications for marketing purposes. To opt out of receiving pushnotifications, you need to change the settings on your device or/and browser.

7.       To personalizeour ads

Weand our partners use your personal data to tailor ads and possibly even showthem to you at the relevant time. For example, if you have visited our Website,you might see ads of our products, for example, in your Facebook’s feed.

Wemay target advertising to you through a variety of ad networks and exchanges,using data from advertising technologies on and off of our Services like uniquecookie, or similar tracking technology, pixel, device identifiers, geolocation,operation system information, email.

How to opt out or influence personalizedadvertising

iOS:

On your iPhone or iPad, go to “Settings,” then“Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, youcan reset your advertising identifier (this also may help you to see less ofpersonalized ads) in the same section.

Android:

To opt-out of ads on an Android device, simplyopen the Google Settings app on your mobile phone, tap “Ads” and enable “Optout of interest-based ads”. In addition, you can reset your advertisingidentifier in the same section (this also may help you to see less ofpersonalized ads).

To learn even more about how to affectadvertising choices on various devices, please look at the informationavailable here.

Inaddition, you may get useful information and opt out of some interest-basedadvertising, by visiting the following links:

1.     Network Advertising Initiative – http://optout.networkadvertising.org/

2.     Digital Advertising Alliance – http://optout.aboutads.info/

3.     Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices

4.     Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/

5.     DAA AppChoices page – http://www.aboutads.info/appchoices

Browsers:

Itis also may be possible to stop your browser from accepting cookies altogetherby changing your browser’s cookie settings. You can usually find these settingsin the “options” or “preferences” menu of your browser. The following links maybe helpful, or you can use the “Help” option in your browser.

6.     Cookie settings in Internet Explorer

7.     Cookie settings in Firefox

8.     Cookie settings in Chrome

9.     Cookie settings in Safari web and iOS

Google allows its users to opt out of Google’spersonalized ads and to prevent their data from being used by Google Analytics.

Facebook also allows its users to influence the typesof ads they see on Facebook. To find how to control the ads you see on Facebook,please go here or adjustyour ads settings on Facebook

10.    To enforce ourTerms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreementsand contractual commitments, to detect, prevent, and combat fraud. As a resultof such processing, we may share your information with others, including lawenforcement agencies (in particular, if a dispute arises in connection with ourTerms and Conditions of Use).

11.    To comply withlegal obligations

We may process, use, or share your data whenthe law requires it, in particular, if a law enforcement agency requests yourdata by available legal means.

12.    To process yourpayments

We provide paid products and/or serviceswithin the Service. For this purpose, we use third-party services for paymentprocessing (for example, payment processors). As a result of this processing,you will be able to make a payment and use the paid features of the Service.

5. UNDER WHAT LEGAL BASES WE PROCESS YOURPERSONAL DATA

We process your personal data, in particular,under the following legal bases:

1.     your consent;

2.     to perform our contract with you;

3.    for our (or others')legitimate interests; Under this legal basis we, in particular:

o    communicate with you regarding your use of ourService

Thisincludes, for example, sending you push notifications reminding you that you haveunread messages. The legitimate interest we rely on for this purpose is ourinterest to encourage you to use our Service more often. We also take intoaccount the potential benefits to you.

o    research and analyze your use of the Service

Ourlegitimate interest for this purpose is our interest in improving our Serviceso that we understand users’ preferences and are able to provide you with abetter experience (for example, to make the use of our mobile applicationeasier and more enjoyable, or to introduce and test new features).

o    send you marketing communications

Thelegitimate interest we rely on for this processing is our interest to promoteour Service in a measured and appropriate way.

o    personalize our ads

Thelegitimate interest we rely on for this processing is our interest to promoteour Service in a reasonably targeted way.

o    enforce our Terms and Conditions of Use and toprevent and combat fraud

Ourlegitimate interests for this purpose are enforcing our legal rights,preventing and addressing fraud and unauthorized use of the Service,non-compliance with our Terms and Conditions of Use.

o    to comply with legal obligations.

6. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties thathelp us operate, provide, improve, integrate, customize, support, and marketour Service. We may share some sets of personal data, in particular, forpurposes and with parties indicated in Section 2 of this Privacy Policy. Thetypes of third parties we share information with include, in particular:

1.       Serviceproviders

Weshare personal data with third parties that we hire to provide services orperform business functions on our behalf, based on our instructions. We mayshare your personal information with the following types of service providers:

o    cloud storage providers (Amazon, DigitalOcean,Hetzner)

o    data analytics providers (Facebook, Google,Appsflyer)

o    marketing partners (in particular, socialmedia networks, marketing agencies, email delivery services; such as Facebook,Google, Mailfire)

2.       Law enforcementagencies and other public authorities

Wemay use and disclose personal data to enforce our Terms and Conditions of Use,to protect our rights, privacy, safety, or property, and/or that of ouraffiliates, you or others, and to respond to requests from courts, lawenforcement agencies, regulatory agencies, and other public and governmentauthorities, or in other cases provided for by law.

3.       Third partiesas part of a merger or acquisition

Aswe develop our business, we may buy or sell assets or business offerings.Customers’ information is generally one of the transferred business assets inthese types of transactions. We may also share such information with anyaffiliated entity (e.g. parent company or subsidiary) and may transfer suchinformation in the course of a corporate transaction, such as the sale of ourbusiness, a divestiture, merger, consolidation, or asset sale, or in theunlikely event of bankruptcy.

7. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

To be in control of your personal data, you havethe following rights:

Accessing / reviewing/ updating / correcting your personal data. You may review, edit, or change the personaldata that you had previously provided to Pasiparo in the settings section onthe Website.

You may also request a copy of your personaldata collected during your use of the Service at support@pasiparo.com.

Deleting your personaldata. You can request theerasure of your personal data by sending us an email at support@pasiparo.com.

When you request deletion of your personaldata, we will use reasonable efforts to honor your request. In some cases wemay be legally required to keep some of the data for a certain time; in suchevent, we will fulfill your request after we have complied with ourobligations.

Objecting to orrestricting the use of your personal data (including for direct marketingpurposes). You can ask us to stopusing all or some of your personal data or limit our use thereof by sending arequest at support@pasiparo.com.

The right to lodge acomplaint with the supervisory authority. We would love you to contact us directly, sowe could address your concerns. Nevertheless, you have the right to lodge acomplaint with a competent data protection supervisory authority.

8. AGE LIMITATION

We do not knowingly process personal data frompersons under 16 years of age. If you learn that anyone younger than 16 hasprovided us with personal data, please contact us at support@pasiparo.com.

9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time totime. If we decide to make material changes to this Privacy Policy, you will benotified through our Service or by other available means and will have anopportunity to review the revised Privacy Policy. By continuing to access oruse the Service after those changes become effective, you agree to be bound bythe revised Privacy Policy.

10. DATA RETENTION

We will store your personal data for as longas it is reasonably necessary for achieving the purposes set forth in thisPrivacy Policy (including providing the Service to you), which includes (but isnot limited to) the period during which you have a Pasiparo account. We willalso retain and use your personal data as necessary to comply with our legalobligations, resolve disputes, and enforce our agreements.

11.CONTACT US

You may contact us at any time for detailsregarding this Privacy Policy and its previous versions. For any questionsconcerning your account or your personal data please contact us at support@pasiparo.com

Effective as of March 2020