TABLE OF CONTENTS
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 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.
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
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 email@example.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 firstname.lastname@example.org. 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
4.8 To enforce our Terms and Conditions of Use and prevent fraud
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.
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
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
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.
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 email@example.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.
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 firstname.lastname@example.org.