Privacy Notice
Revised: August 2023
Please consider the following Privacy Notice carefully as it affects your use of our Services and your rights.
This privacy notice, provided by Entity OS (“Company”, “us”, “we”, "our" or "ourselves"), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you visit our website. Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us by email at [email protected].
WHAT INFORMATION DO WE COLLECT?
We collect personal information that you provide to us when you register on the Services, when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or when you contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include sensitive information and payment data.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected: We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice.
HOW DO WE PROCESS YOUR INFORMATION?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We may process your information so you can create and log in to your account, as well as keep your account in working order. We may process your information to provide you with the requested service. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services. We may process your information when necessary to request feedback and to contact you about your use of our Services. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. We may process information about how you use our Services to better understand how they are being used so we can improve them. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including: (i) to deliver and facilitate delivery of services to the user; (ii) to respond to user inquiries/offer support to users; (iii) to send administrative information to you; (iv) to request feedback; (v) to send you marketing and promotional communications; (vi) to deliver targeted advertising to you; (vii) to protect our Services; (viii) to identify usage trends; (ix) to determine the effectiveness of our marketing and promotional campaigns; and, (x) to save or protect an individual's vital interest.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.Click here to learn more. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request before entering into a contract with you.
Legitimate Interests.: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: (i) send users information about special offers and discounts on our products and services; (ii) develop and display personalised and relevant advertising content for our users; (iii) analyse how our Services are used so we can improve them to engage and retain users; (iv) support our marketing activities; (v) diagnose problems and/or prevent fraudulent activities; and, (vi) understand how our users use our products and services so we can improve user experience. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. We may use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent.
The Nigeria Data Protection Regulation (NDPR), General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: (i) performance of a Contract; (ii) legal obligations; (iii) where you have given us specific permission; (iv) if collection is in the interests of an individual and consent cannot be obtained in a timely way; (v) for investigations and fraud detection and prevention; (vi) for business transactions provided certain conditions are met; (vii) if it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim; (viii) or identifying injured, ill, or deceased persons and communicating with next of kin; and, (ix) if we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may share information in specific situations with the following third parties:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We may use cookies and other tracking technologies to collect, access or store your information.
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
If you choose to register or log in to our Services using a social media account, we may have access to certain information about you. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Meta or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
We may transfer, store, and process your information in countries other than your own. Please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), in a location which may be outside your home country. We will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with Our third-party service providers and partners and further details can be provided upon request.
Our servers are located in the United States of America, and, Europe.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations.
HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We aim to protect your personal information through a system of organisational and technical security measures. We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records promptly. If you become aware of any data we may have collected from anyone under 18years of age, please contact us.
WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such as Nigeria, the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. You may have certain rights under applicable data protection laws. These may include the right to: (i) request access and obtain a copy of your personal information; (ii) request rectification or erasure; (iii) restrict the processing of your personal information; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. We will consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can request to terminate your account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice.
DO WE MAKE UPDATES TO THIS NOTICE?
Yes, we will update this notice as necessary, to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated revision date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at [email protected]. Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request, review, update, or delete your personal information, please email [email protected].