Privacy Policy

INTRODUCTION

This Privacy Policy sets out details of the Personal Information that INNIXX collects from you and how we use that personal Information. We also explain your rights and how to contact us if you have any questions about your Personal Information. INNIXX is committed to protecting the privacy of the personal information we collect. We understand that you take your privacy seriously. We do too. Our Privacy Policy describes how we manage personal information, including the kinds of personal information we collect, the purposes for which we collect personal information, and how we hold, use and disclose personal information. By using our products and services (including our website) or by providing your personal information to us you agree to the terms of this Privacy Policy.

In this Privacy Policy, terms such as “we”, “us, “our” or similar expressions shall mean INNIXX.

We take your privacy very seriously and are committed to protecting your personal data (meaning any information about you from which you can be identified). This Privacy Policy explains what personal data we collect when you: use our products and/or services or access INNIXX’ websites at https://www.innixx.org use our official app; or engage us on our social media platforms (including our Facebook, Twitter and Instagram pages); and/or when you otherwise interact or communicate with us. It also explains how we may use this data, and what rights you have in relation to such data.

1. BACKGROUND

We are a “Data Controller” under the Nigeria Data Protection Regulation, 2019 (the NDPR) and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the NDPR, we will ensure that the personal data we hold about you is, always:

used fairly, lawfully, and transparently;
collected for limited, specific purposes only;
adequate, relevant to and limited to what is necessary for those purposes;
kept accurate and up-to-date;
not kept for longer than is necessary; and
held securely.

We shall be accountable for and able to demonstrate our compliance with our obligations under the provisions of the National Information Technology Development Agency Act, 2007 (“NITDA ACT’’) as well as the Nigeria Data Protection Regulation 2019 (“NDPR”) Data Protection Law, and this Privacy Policy is one of the ways in which we do that.

2. PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. We may collect and use various types of your personal data:

The types of personal information we collect will depend on the circumstances in which the information is collected. However, the types of personal information we collect and hold about you may include:

Registration Data: To access and use some elements of the Services you must create an account, by providing us with the information which is identified on the relevant registration page: name, email, date of birth, and country. We will also collect a username and password. Please note that some elements of the Services will not be available if you do not provide the required information. We may also ask or allow you to submit other optional information, including your gender, phone number, post code.
Identity Data: We also ask you to provide identification information when we provide other elements of the Services: name, age, gender and social media handles/ usernames.
Contact Data: When we want to communicate with you, or you with us, we use your email address, billing address, telephone numbers, social media handles/ usernames and location (country/ place of residence).
User Data: We collect your usage and preference details related to your use of the Services such as language, statistics, scores, rankings, time spent on our website, preferences, survey responses, feedback and other data that you provide to us as part of your account. information and how your device has interacted with our website, including the pages accessed and links clicked
Marketing and/ or Communications Data: We retain your preferences in receiving marketing messages from us and commercial partners, and your communication preferences.
Technical Data: Certain data is automatically generated and collected by us when you use the Services such as your IP address, MAC address and other device identifiers; your clickstream to, through and from the Services (including date and time); pages you viewed or searched for; length of visits to certain pages; page interaction information (such as scrolling, clicks and mouse-overs); methods used to browse away from the page.
Financial Payment Data: – Due to the nature of the service we offer, we will collect financial information, such as bank account or other payment details, necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Google Play and Apple App Store. You may find their privacy notice link(s) at https://policies.google.com/privacy and https://www.apple.com/legal/privacy.
Sensitive Data: – We may also collect sensitive information about you such as information about your health, racial or ethnic origin, religious beliefs and criminal record if you provide your explicit consent or if we are otherwise allowed or required by law

Information collected through our App

We collect information regarding your mobile device, push notifications, when you use our App. We collect the following information:

Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device’s camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data: We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.
Push Notifications: We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt- out from receiving these types of communications, you may turn them off in your device’s settings. This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered personal information under applicable regulations as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website and/or app feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal information about you in the following ways

access or use our Products and Services.
create an account on our App
request information, marketing and other communications to be sent to you
enter a competition, promotion or survey
complete surveys or provide us with your feedback; and – otherwise interact or correspond with us (including via email, social media or telephone).
when you submit a query to us
by tracking your use of our products and services (including our website); from third parties who are entitled to disclose that information to us
from publicly available sources
from online sources (including social media platforms and providers (e.g. LinkedIn); In connection with some elements of the Services we also receive additional personal data about you from other organisations who have collected personal data from you and data collected on our behalf at any of our events. We may also receive personal data as part of the legal processes we undertake to protect our Services and our intellectual property, such as our brand or media rights, or those of our licensees/commercial partners. We may also collect personal data about you and your use of our website, products and services using cookies. We use cookies to monitor and observe your use of our website, products and services, compile aggregate data about that use, and provide you with a more effective service (which may include customising parts of our website based on your preferences and past activities on that website. Cookies are small, usually randomly encoded, text files that help your browser navigate through a particular website. The cookie file is generated by the website you are browsing and is accepted and processed by your computer’s browser software. The cookie file is stored in your browser’s folder or subfolder We also use third party tools to help us manage and analyse our social media presence, and report on comments, mentions and other content that is posted about us on social media sites and other public channels and forums. These third parties’ activities, and their information collection and sharing practices, are subject to the terms of the relevant social media site, channel or forum.

4. HOW DO WE USE PERSONAL INFORMATION?

Depending on how you use our products and services, your interactions with us, and the permissions you give us, the purposes for which we use your Personal Information include:

Verify your identity when you are dealing with us.
Determine your eligibility for any of our products or services.
Maintain our relationship with you
Enable us to provide you or your organisation with our products and services
Answer your queries and requests.
To manage and respond to any queries or complaints to our customer service team.
To improve and maintain our products and services and monitor their usage.
For market research, e.g. we may contact you for your opinions and comments.
To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so.
For security purposes, to investigate illegal activities such as fraud and where necessary to protect ourselves and third parties.
To investigate breaches of our contracts, policies or Terms and Conditions.
To comply with our legal and regulatory obligations.
Assess, operate, maintain, upgrade and improve our products and services (including our website)
Provide better products, services and information to our customers and to the community.
Carry out education and training programs for our employees.
Manage and resolve any legal or commercial complaints or issues (including debt recovery)
Meet our obligations and perform our functions under applicable laws and agreements
Maintain and update our records
Use in accordance with any request or instructions from you
Carry out planning and forecasting activities and other internal business processes
Keep you informed about our activities and notify you of changes to our products or services
Make special offers related to our products or services that we think may be of interest to you
Use as otherwise required or authorised by law or government agency.
We may use and disclose your personal information for marketing purposes (but we will not sell your personal information to any third party).

We may also use your personal information for any other purpose as authorised by you. We rely on the following legal bases, under data protection law, to process your Personal Information:

Because the processing is necessary to perform a contract with you, or take steps prior to entering into a contract with you (e.g. where you have made a purchase with us, we use your Personal Information to process the payment and fulfil your order).
Because we have obtained your consent (e.g. where you contact us with a query, where you add optional information to your account profile, or if you consent to receive marketing from us). You are free to withdraw your consent at any time.

Because it is in our legitimate interests in operating our business, for security purposes, to protect our staff, business and reputation, for fraud prevention and to operate and promote the business. For example, we are always seeking to engage more with our users and we use information about you to tailor your view of our Sites (and the messages we send to you) to make them more relevant to you. We also combine information we collect about you with aggregated information about our products and service offerings, to increase our understanding of our users.
Because the processing of information relating to actual or suspected criminal activity is necessary for the purposes of the prevention or detection of crime.

5. HOW DO WE USE YOUR PERSONAL INFORMATION FOR MARKETING & ADVERTISING?

Depending on your marketing preferences, we may use your Personal Information to send you marketing messages by email, phone, SMS or post. Some of these messages may be tailored to you, based on your online profile, your previous browsing or activities, and other information we hold about you.

If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us via any of the methods given at the in the ‘Contact us’ section at the end of this Policy, or by using the ‘unsubscribe’ mechanism in the promotional message or updating your contact preferences in your account. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (e.g. information about your legal rights). Once you unsubscribe, you may continue to receive marketing messages for a few days while we take action on your unsubscribe request.

Social Media

You may also see adverts for INNIXX on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Sites). Where you see an ad on social media, this may be because we have engaged the social network to show adverts to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third party websites.

6. WHO DO WE SHARE THIS PERSONAL INFORMATION WITH?

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

We may share your Personal Information with the following third parties:

With our Commercial Sponsors and Partners, as described in ‘With our suppliers and service providers working for us, e.g. payment processors
With our professional and legal advisors.
With third parties engaged in fraud prevention and detection.
With law enforcement or other governmental authorities or regulatory bodies, e.g. to report a fraud or in response to a lawful request.
In the event that we sell any business assets, your Personal Information may be disclosed to a potential buyer. In this event, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Policy.
Social media sharing entities
Web and Mobile analytics platforms e. g Google Analytics
Your representatives, advisers and others you have authorised to interact with us on your behalf
Related entities within our corporate group
Our employees and third parties including consultants, contractors, suppliers, service providers, professional advisers and agents who need the information to assist us with conducting our business activities
Payment system operators and financial institutions
Parties identified at the time of collecting your personal information or as otherwise authorised by you

7. INNIXX’S COMMERCIAL SPONSORS AND PARTNERS

We team up with a selection of carefully chosen commercial sponsors and partners as part of our Commercial Partners programme. Our Commercial Sponsors and Partners include partners from a variety of sectors and is designed to support our business and also to bring customers and Site users a diverse range of our associated and branded offers. If you have given your consent, we may contact you (including by post, phone, SMS or email) in order to tell you more about the offers available to you and about a range of other initiatives from us and on behalf of our Commercial Sponsors and Partners.

8. HOW DO WE PROTECT YOUR INFORMATION?

We take the security of your Personal Information very seriously. We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your Personal Information. Your Personal Information is contained behind secured networks and is only accessed when necessary. A limited number of people have special access rights to such systems and they are required and bound to keep the information confidential. When you place orders or access your Personal Information, we offer the use of a secure server. We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers (which may be located offshore). Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time. These measures include: – restricting access to our physical and electronic databases, and physical security such as security procedures for access to our business premises; and – technological security procedures including password protection, network firewalls, encryption, intrusion detection and site monitoring where practicable to do so.

We also take steps to monitor access to and modification of your information by our employees and contractors, and ensure that our employees and contractors are aware of and properly trained in their obligations for managing your privacy

Whilst we have used our best efforts to ensure the security of your Personal Information, please be aware that we cannot guarantee the security of information transmitted over the internet. You also play an important role in keeping your information secure by maintaining the confidentiality of any usernames and passwords you use with our products and services (including our website)

9. MONITORING OF TELEPHONE CALLS

If you contact us by telephone, we may monitor or record the call for security purposes and to improve the quality of services that we provide to you.

10. THIRD PARTY LINKS

Our Sites may include links to websites operated by third parties. These linked sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content or activities of these linked sites. However, we do seek to protect the integrity of our site and welcome any feedback about these linked sites (including if a specific link does not work) by email or in writing via the contact details given below.

11. DURATION OF STORAGE OF DATA

Personal data is only retained for as long as it is needed for the purpose for which it was collected or as required by law. Within a reasonable time after the expiry of this period, we will take reasonable steps to de-identify or destroy the personal information which is in our possession or control.

12. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You have certain rights in respect of your Personal Information, including the right to access, correct, restrict, and request the erasure of your Personal Information, and obtain a copy of it in a machine-readable format.

You also have the right to object to your Personal Information being used for certain purposes, including sending you marketing.

We will comply with any requests to exercise your rights in accordance with applicable laws. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your Personal Information, or if you have any questions or concerns regarding your Personal Information, you should contact us using the details below.

13. ERASURE OF DATA

You have a right to request the erasure or destruction of your personal information when it is no longer necessary for the purpose for which it was originally collected, it is not being used for the purposes for which it was collected, or you wish to withdraw your consent for certain processing.

There may be cases where we are unable to comply with your request such as where we need to continue processing your personal information to comply with applicable laws. Such requests should be submitted in writing using the contact details below. We may ask you to verify your identity before complying with your request.

14. CONTACT US

If you have any queries on any aspect of our Privacy Policy or wish to exercise any of your rights referred to above, please contact us by email at support@innixx.org or by post to Road 5 Ikota, Shopping Complex, VGC, Lekki, Lagos.

15. CHANGES TO OUR POLICY

In order to comply with the law and to meet our changing business requirements, our policies and procedures are constantly under review. From time to time, we may modify, alter or update this Privacy Policy. We will post the revised Privacy Policy on the website, and so we encourage you to check back regularly.

This Privacy Policy was last updated in March 2022.