1. General

This privacy policy describes the policy of Whales Innovations Ltd regarding the collection, use, storage, sharing and protection of your personal information ("Privacy Policy"). This Privacy Policy applies to the www.naijacona.com and naijacona.com website (together, "Naijacona" or "Website") and all related websites, applications, services and tools where reference is made to this policy ("Services"), regardless of how you access the Services, including access through mobile devices. Whales Innovations Ltd. is the data controller.

Scope and consent: By using Naijacona and related Services, you give explicit consent to Naijacona for the collection, use, disclosure and retention of your personal information by us, as described in this Privacy Policy, our Cookie Policy and our Terms of Use.

Naijacona may change this Privacy Policy from time to time. We advise you to read it regularly. Substantial changes to our Privacy Policy will be announced on our website. The amended Privacy Policy will be effective immediately after it is first posted on our website. This new Privacy Policy is effective from 28 of July 2024.

2. What personal information do we collect?

You can visit naijacona website without registering with us. When you decide to provide us with your personal information, you agree that such information is sent to and stored on our servers. We collect the following types of personal information:

Information we collect automatically: When you visit naijacona website, use our Services and or reply to ads or other content, we automatically collect the information sent to us by your computer, mobile device or other equipment that provides access. This information includes, but is not limited to:

• information from your interaction with our Website and Services, including, but not limited to, device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from www.naijacona.com, referring URL, ad data, IP address and standard web log information; and
• information we collect through cookies, web beacons and similar technologies.

Information you provide to us: We collect and store any information you enter on our website or that you provide to us when you use our Services. This information includes, but is not limited to:

• information that you provide to us when you register for an account or for the Services that you use, such as your full name and/or user name, email address, social media links, address and profile photo;
• additional information that you may provide to us through social media sites or third-party Services;
• information provided in the context of dispute resolution, correspondence through our website or correspondence that is sent to us;
• information about your location and the location of your device, including your device’s unique identifier information if you have enabled this service on your mobile device, and
• your resume if you choose to submit it to us for consideration through our careers page.

Information from other sources: We may receive or collect additional information about you from third parties and add this to our account information. This information includes, but is not limited to: demographic data, navigation data, additional contact data and additional data about you from other sources, such as public authorities, to the extent permitted by law.

3. How we use your personal information?

You agree that we may use your personal information for the following purposes:

• to provide you access to our Services and Customer Support by means of e-mail or telephone;
• to prevent, detect and investigate potentially prohibited or illegal activities, fraud and security breaches and to enforce our Terms of Use;
• to personalize, measure and improve on our Services, content and ads;
• to contact you, by e-mail, push notification, text message (SMS) or by telephone, to inquire about our Services and the services of companies that are part of the Whales innovations Ltd. "corporate family'
• to provide you with other services that you have requested, as described when we collected the information,
• to administer contests, and
• to consider you as a potential candidate if you choose to upload your resume through our careers page.

Sharing information with and registration on social media sites: We may offer sign-on Services that enable you to access the Website or related websites with your login credentials. We can also offer Services that enable you to share information with third-party social media websites, such as Facebook and X, Instagram and TikTok.

If you provide us access to personal information stored on third-party websites, the scope of access to this personal information shall vary per website and will be determined by both your own browser settings and your consent. If you wish to connect your third-party account to your naijacona account and you consent to us accessing the information in these third-party accounts, you agree that we can collect, use and store information from this third-party website in accordance with this Privacy Policy.

Transfer of your personal information to third parties: We may disclose your personal information to third parties in accordance with this Privacy Policy and applicable legislation and regulations. As further described under Section 5, we will not disclose your personal information to third parties for their marketing purposes without your explicit consent. We may share your personal information with;

• companies of the Classifieds Group to provide joint content and services (such as registration and customer support), to prevent, detect and investigate possible illegal activities, violations of our policy, fraud and/or data security breaches, and to support decision making on products, websites, applications, services, tools and communication. The Classifieds Group companies will only use this information to send you marketing messages when you yourself have requested their services, and they will use your personal information in accordance with their respective privacy policy.
• service providers with whom we have entered into an agreement to help us provide our Services on the website, such as financial service providers, marketing agencies and advertising-related service providers, and technical support. In such cases, the personal information shall remain under the control of Whales Innovations Ltd. If you are listing an ad, your listing or business address may be displayed on a map in your ads (including within the naijacona mobile application) via Google Maps and therefore transferred to Google (refer to the Google Privacy Notice for more info). Your information may also be provided to Microsoft in connection with our use of Microsoft Advertising (refer to Microsoft’s Privacy Statement for more info).
• certain third parties (such as intellectual property rights holders, supervisory authorities, tax authorities, police and other regulatory authorities) if we are required to do so by law, or in accordance with our Privacy Policy. We may share your personal information:
  • to comply with legal obligations or a court order; or
  • if this is necessary for the prevention, detection or prosecution of criminal offenses, such as fraud, deceit or prosecution, or
  • if it is necessary to maintain our policies or to protect the rights and freedoms of others.
• other third parties to whom you have given consent to share your information via naijacona,
• companies that we intend to merge with in the context of a re-organization or that acquire us;
• an intellectual property owner if the owner of an intellectual property right or an intermediary in good faith believes that an advertisement violates the rights of the owner. Before personal information is provided, the IP owner will enter into an agreement that, inter alia, stipulates that information is only provided on the strict condition that it may only be used in the context of legal proceedings and/or obtaining legal advice and/or to answer questions from the relevant advertiser.

Without limitation to the foregoing, we shall moreover - in our efforts to respect your privacy and to keep the website free of malicious persons or parties – not disclose your personal information to third parties without a court order or formal request from the government in accordance with applicable law, unless we believe in good faith that such disclosure is necessary to prevent impending injury or financial damages or to report alleged illegal activities.

Information you share on www.naijacona.com: Our Website allows users to share advertisements and other information with other users, thereby making this shared information accessible to other users. Since our website also enables you to directly contact a buyer or seller, we recommend that you consider how you share your personal information with others. You are solely responsible for the personal information you share through our website and therefore we cannot guarantee the privacy or security of the information shared by you with other users.

In case you visit our Website from a shared computer or a computer in an internet café, we strongly recommend that you log off after each session. If you do not want the shared computer to remember you and/or your credentials, you will need to remove cookies and/or the history of your website visits. immediately you finish logging out.

4. Transfers of your personal information to other jurisdictions

We may never have need to transfer the personal information we collect about you to other countries than Nigeria in which the information was originally collected. As they may not have the same data protection laws as the jurisdiction in which you initially provided your personal information. In these circumstances, only the Nigerian governments, courts, law enforcement or regulatory agencies may be able to obtain access to your personal information through the laws of Nigeria.

5. Marketing Purposes

You agree that we may use the information collected by us to send you offers, whether personalized or not, or to contact you by telephone regarding products or Services offered by Whales innovations ltd on naijacona or companies of the Classifieds Group.

We will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our Services and functionalities.

When you no longer wish to receive marketing communications from us, you can, where applicable, change your preferences in your account, or follow the unsubscribe link in the marketing communication you received.

6. Advertising

Naijacona adheres to the Digital Advertising in Nigeria program and principles. If you do not wish to participate in our advertising personalization using your personal information or retargeting/tracking programs, you can opt-out by following the directions provided within the applicable advertisement, and use the opt-out mechanism. This does not necessarily mean that no advertisements will be shown to you. It simply means that these advertisements will not be personalized for you by means of cookies, web beacons or similar technologies.

7. Cookies

When you use our Services, we and our service providers may place cookies (data files on your phone or mobile device’s drive) or web beacons (electronic images that are placed in a web page’s code) or similar technologies. We use cookies to help us identify you as a user, to provide you a better experience on our website, to measure promotional effectiveness and to ensure trust and safety on our website. For more detailed information about our use of these technologies, we refer you to our Policy on Cookies, Web beacons and Similar Technologies, which forms part of this Privacy Policy.

8. Data subject rights – accessing, rectifying, changing and deleting your personal information, and withdrawing consent

Accessing or obtaining a copy of your information: You may access your personal information or account information by logging into your naijacona account. Alternatively, you can also contact Customer Support by selecting Privacy - Access Information to access or obtain a copy of your personal information stored by us (including information that is not directly accessible on naijacona), unless we are not required to provide access or a copy under applicable law. We may charge a fee to compensate costs; however, the fee shall not exceed the amount permitted by law.

Rectifying your information: If your information is factually incorrect or incomplete or irrelevant for the purposes for which we process your information, you may request that we rectify your information by contacting Customer Support and selecting Privacy - Rectify Information. Such requests will be handled by our data management department and in accordance with applicable law.

Changing your information: We cannot modify your personal information or account information. You can modify your own information by logging into your naijacona account. When you place a classified ad, you will be able to change, edit price and product value or rates and correct your listing or delete your message on naijacona.

Deleting your information: If you decide to close your account on naijacona, you can please send us account closure request by contacting Customer Support and selecting Privacy - Delete Information. You may also initiate a request via the naijacona app by selecting ‘account settings’ - ‘manage account’ - ‘request account deletion’. We will process your request within a reasonable period of time and in accordance with applicable law.

Withdrawing Consent: You have the right to object and opt-out of certain uses and disclosures of your personal information, and may withdraw your consent to our processing of your personal information at any time by contacting us. Please note that even if you opt-out, we may still collect and use non-personal information regarding your activities on our naijacona Website.

9. Protection and retention of your personal information

We protect your information by using technical and administrative security measures (such as firewalls, data encryption, and physical and administrative access controls to the data and servers) that limit the risk of loss, abuse, and unauthorised access, divulgence, and alteration. Nevertheless, contact us if you believe or suspects your account or information has been abused by anyone.

We use the reCAPTCHA Enterprise tool on our website to help detect and prevent fraud, spam and abuse. This tool collects information about your hardware and software (such as device or application data) and sends it to Google to run and improve the tool, as well as for general security purposes. Please note that your use of reCAPTCHA Enterprise is subject to Google’s Terms of Service and Privacy Policy.

We retain personal information no longer than is legally permissible and delete personal information when it is no longer necessary for the purposes as described above.

10. Other information

Abuse and unsolicited commercial communications ("spam"): We do not tolerate abuse on our naijacona website. users do not have permission to add other naijacona users to their mailing list for commercial purposes, even if a user has purchased something from you, unless the user has given his explicit consent. If you notice that someone is abusing our website (spam or spoof emails), please kindly quickly inform us so that we can do the needful in due time.

No one is allowed to use our member-to-member conveyance means to send spam or use content that violates our Terms of Use in any bad manner. For your security and privacy purpose, we may automatically scan messages and check for spam, viruses, phishing and other malicious activities or illegal or and prohibited content. As we do not permanently store messages sent through this measure.

Third Parties: Be rest assured that we do not in any way sell, trade nor share your information with any third party. All information, such as email, phone number, password, name and address and other details are mainly for naijacona private use for identification towards fraud prevention. If there is any need for us to use third-party tools (like, BVN, NIM, bank details) be sure still that all your information is 100% safe as they will never going to be downloaded on our website, but only the tool to verify you more as your safety and privacy is paramount to us.

Contact: get to us in case you wish to know more about us or if there are other things you may likely want to know about our Privacy Policy, feel free to contact us @ Whales Innovations Limited.