Spynaija places particular importance on the protection of your Personal Information. That is why we are committed to ensuring the accuracy, security, and confidentiality of the Personal Information collected about you, in accordance with applicable laws.
This Policy does not apply to third-party websites and software (ex. Facebook, Youtube, Instagram, etc.) that may be accessed through our inspirational content website, transactional platform, or application, as the case may be (collectively, our “Sites”).
For the purposes of this Policy, “Personal Information” means any information about an identifiable individual, as defined in Canadian law.
1-THE PERSONAL INFORMATION WE COLLECT
In the course of our business and provision of services, the Personal Information collected may include, but is not limited to:
• Your first and last name;
• Your address;
• Your email address;
• Your IP address;
• Your use of our Sites and other technical information relating to your browsing behavior;
• Data necessary to process your payment; and
• Your order history.
We do not knowingly collect personal data about anyone under the age of 16.
Except when it is truly essential, we will not refuse to provide services or sell your goods if you refuse to give us your Personal Information.
Spynaija may not refuse to respond to a request for goods or services or to a request relating to employment by reason of the applicant’s refusal to disclose Personal Information except where:
- collection of that Personal Information is necessary for the conclusion or performance of a contract;
- collection of that Personal Information is authorized by law; or
- there are reasonable grounds to believe that the request is not lawful.
2-HOW WE COLLECT YOUR PERSONAL INFORMATION
Spynaija collects your Personal Information from you and through cookies.
2.1 From you (you know, when you actually give us information about you)
You provide us directly with Personal Information, such as when you create an account on our Sites, when you click on an advertisement that we have placed on a third-party website (e. g. Google, Facebook, etc.), when you contact us, when you complete an online request form or when you purchase one of our products or services.
Cookies are collected on our Sites to give you a better experience while browsing our inspirational content or while buying our motivational products. They are not mandatory, so you can turn them off at any time.
Cookies are small data files that are commonly stored on your device when using websites and online services. They are used for the efficient operation of websites and can provide information and help personalize services. Spynaija collects Personal Information provided by cookies.
Spynaija uses different types of cookies:
- Performance and functionality connection cookies: These cookies are not essential to the provision of our services. They facilitate the personalization and enhancement of the user experience. For example, they may remember your preferences and avoid having to re-enter information more than once or remember your credentials, so you don’t have to enter them each time you use them.
- Cookies for advertising purposes: These cookies are not essential to the provision of our services. They use information about your visit to the site, such as the pages visited or the response to advertisements, to help provide the best user experience for your situation.
3-HOW WE USE YOUR PERSONAL INFORMATION
Why we collect your Personal Information. Personal Information collected by Spynaija will be used for the following purposes:–
- Provide, maintain, customize and improve our services;
- Allow Spynaija to perform internal operations related to its services;
- Allow Spynaija to better understand its business and its customers, generally with the purpose to improve our products and services and developing new ones;
- Send or facilitate communications between Spynaija and you in connection with the services; and
- Communicating with you and serving you tailored advertising both on and off our Sites.
We will inform you if we intend to use your Personal Information for other purposes. Except as already provided by applicable privacy legislation, Spynaija will request your consent before using your Personal Information for purposes not previously identified.
4-YOUR CONSENT TO THE COLLECTION AND USE
Prior to using your Personal Information, we will require your consent. Your consent to the collection, use, and disclosure of your Personal Information is required, except when inappropriate. (For example, for legal or security reasons, it may be impossible or impractical to obtain consent).
If you browse our inspirational content or purchase our products, you are deemed to agree to this Policy. By agreeing to use Spynaija’s services, you expressly provide Spynaija with your consent to collect, process, and use your Personal Information in accordance with the provisions of this Policy.
You understand this Policy. You represent that you are aware of the purposes for which Spynaija collects, processes, and uses your Personal Information, how it will be collected, and how we protect the confidentiality of the Personal Information.
You may withdraw your consent at any time, subject to legal or contractual restrictions, and reasonable notice.
5-RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for an undefined period of time. Personal Information will be retained as long as necessary for the fulfillment of the identified purposes or for compliance with legal requirements regarding retention periods.
You may delete your account. Any user may request that their account be deleted by sending a request to Spynaija by email.
6-OUR SECURITY MEASURES
We try our best to keep your Personal Information safe. Spynaija implements industry-standard security measures to protect its customers from unauthorized access or use, alteration, unlawful or accidental destruction, or loss of their Personal Information.
Sadly, not everybody is well-intentioned, and we cannot guarantee we will not get hacked. Unfortunately, it is impossible for us to guarantee the absolute security of the Personal Information collected or transmitted through our Sites. You therefore understand and agree that (i) there are limits to the security and confidentiality of the Personal Information we collect that are beyond the control of Spynaija; (ii) the security, integrity, and confidentiality of all Personal Information and data exchanged between you and Spynaija through our Sites cannot be guaranteed; and (iii) such Personal Information may be viewed or altered by a third party at the time of the transfer. For these reasons, Spynaija cannot be held responsible for any loss, capture, or alteration of Personal Information.
7-ACCESS AND MODIFICATION OF PERSONAL INFORMATION
You can change your account information yourself. You have access to your Personal Information through your user account on our Sites, if applicable. You can correct and update this Personal Information from this access.
You may obtain a copy of your Personal Information and have it corrected. You may obtain a copy of your Personal Information or have it corrected, if it is incorrect, by sending us a written request by e-mail.
Before we consider any request, we must make sure that you are who you say you are. No request for access, rectification, or deletion may be considered unless it is made in writing by you when you prove that you are the individual concerned (or the representative, heir or successor of that individual, or the liquidator of the succession, a beneficiary of life insurance or of a death benefit).
We will address your request fast. When we receive a request for access, rectification, or removal, we will attempt to respond within a reasonable timeframe after receipt of the request.
In some cases, we might not be able to provide you with everything you ask for. In certain situations, Spynaija may not be able to provide access to all the Personal Information it holds about you. Exceptions to the access requirement are meant to be limited and specific. The reasons for denying access will be provided to you upon request.
Some examples of why we could refuse your request. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or proprietary commercial reasons, and information that is subject to solicitor-client or litigation privilege.
A reasonable fee may be charged for the transcription, reproduction, or transmission of Personal Information.
8-PERSONAL INFORMATION DISCLOSURE
Spynaija will not disclose your Personal Information to a third party unless you consent, or unless such disclosure or use is required by law.
We may share aggregated data for research purposes. Personal Information may also be disclosed without your consent for research purposes if the documents containing the Personal Information are not structured so as to allow retrieval by reference to your name or identifying code or symbol and the Personal Information cannot be retrieved by means of such a reference.
9-POLICY CHANGE AND UPDATE
We may modify our Policy from time to time. Spynaija may, at its discretion, update, revise, modify or supplement this Policy from time to time. If a change is made to the Policy, you will be notified when you log in, and/or we will send you a link to the new version of the Policy. The Policy and any related agreements, if any, will be posted on our Sites. Spynaija asks its users to consult the amended Policy before continuing to use its services. If you refuse the updated version of the Policy, you will be able to terminate your account.
If you continue to use our Sites, you have agreed to the new Policy. The continued use of the services provided by Spynaija, after the amended Policy comes into effect, constitutes consent to such amended Policy.
10-POSSIBILITY TO FILE A COMPLAINT
We try to be the best at what we do, but you can make a complaint if something is wrong. Spynaija has established procedures to receive complaints and inquiries about its policies and practices for the management of Personal Information. The complaints procedure is easily accessible and simple to use.
We will accompany you in the process of a complaint and we promise to address it with care. Spynaija will inform persons making an inquiry or complaint about the existence of the relevant procedures. Spynaija will investigate all complaints. If a complaint is found to be justified, Spynaija will take appropriate measures, including, if necessary, amending its policies and practices.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in detail here;
•the right to be informed;
•the right of access;
•the right to rectification;
•the right to erasure;
•the right to restrict processing;
•the right to data portability;
•the right to object; and
•the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us.
• Follow the instructions at the bottom of each email, and we will promptly remove you from ALL correspondence.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
• Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
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