“Process”, with regards to personal data, includes to collect, store, and disclose to others.
PERSONAL DATA CONTROLLER
SELLABLES.COM.NG Online Marketplace Nigeria Limited, will be the controller of your personal data.
CATEGORIES OF PERSONAL DATA WE COLLECT
We collate data you give to us willingly (take for instance, an email address). We also collate data automatically (for example, your IP address).
2.1 Data you offer us.
You may be asked to provide us with details about yourself when you register for and/or use the Service. This information includes: first name, last name, phone number, email, (together “Required Information”), etc., as well as access to your photos, albums and their metadata. You will need to provide us with your ID or similar proof of identity document if you want to post advertorials in Mobile Device category, unblock your account or make duplicate account main. If you want to participate in car auction as a dealer, you will need to provide us with your Bank ID and САС (certificate of incorporation of legal entity).
To register an account using our service, you will need to provide the required information. Even if you do not give us this data, you will be able to use the service, but some service’s functionality may be limited to you (take for instance, if you do not register an account, you will not be able to chat with other users, post advertorials, view contact details of other users).
In some cases, you may also be required to provide us with additional information to our Support Team in order to fulfill your request (for instance, if your account was previously blocked, we may ask you to verify your identity by providing an ID document).
While posting an advertorial on the Service, you can choose to provide additional personal information about yourself. For instance, you can choose to make available your Curriculum vitae (CV). You admit that by providing your personal data in the advertorial you are making such data publicly available. Further more, you admit and give assent that we will make public some personal data from your profile to provide the Service, – it will enable us to ease communication and transactions between the users.
You should cautiously consider risks linked with the fact that you make certain information – such as, your phone number, address or exact location – publicly available.
2.2. Data provided to us by third parties
When you opt to log in using Facebook, we collate personal data from your Facebook account. This comprises of your profile image, name, and Facebook ID. Unless you shun the Facebook Login screen, we will also gather other data, such as your email address, sex, date of birth, friends list, and location as listed in your Facebook profile.
For more information, please go to the Facebook Permissions Reference (shows the categories of information, which Facebook may reveal to third parties and the set of guidelines) and to the Facebook Data policy. Furthermore, Facebook allows you control the selections you made when connecting your Facebook profile to the App on their Apps and Websites page.
2.3. Data we collect automatically:
2.3.1 Data about how you found us
We collate data relating to your referring URL (that is, the place on the Web where you were when you got linked to our ad).
2.3.2. Device and Location data.
We also collate data from your device. Examples of data we obtain include the following: type and model of a device, operating system, language settings, IP address, time zone, device settings, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
2.3.3. Usage data
We monitor how you interact with our Service. That is, we memoir the features, and content you interact with, how frequently you use the Service, the duration you spend on the Service, what sections you use, the number of ads you watch.
2.3.4. Advertising IDs
We collate your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (based on the operating system of your device). You can ordinarily reset these numbers through the settings of your device’s operating system (note that we do not control this).
2.3.5. Transaction data
When making payments through the Service, you are required to provide financial account data, such as your debit card number, to our third-party service providers. We do not gather or store full debit card number data, though we may receive debit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.
DATA PROTECTION PRINCIPLES
In our data protection practice we endeavour to, notably, ensure that personal data is:
- processed in compliance with specific, approved and lawful purpose consented to by you;
- is genuine, accurate and without prejudice to the integrity of human person;
- stored only for the duration within which it is reasonably needed; and
- secured against reasonably conceivable threat and breaches such as theft, cyberattack, viral attack, propagation, exploitation of any kind, damage by rain, fire or exposure to other natural elements.
MOTIVES WHY WE PROCESS YOUR PERSONAL DATA
We process your personal data:
4.1. To provide our Service
This includes enabling you to use the Service in a harmonious manner and preventing or confronting Service errors or technical issues.
4.2. To customize your experience
We process your personal data to modify the content of the Service and make offers pitched to your personal preferences and interests.
4.3. To handle your account and provide you with customer support
4.4. To communicate with you with respect to your use of our Service
We communicate with you via push notifications or chat. You may also receive notifications on the Website or via email that you received a new message from Sellables. To disable this, you need to make some adjustment on the settings of your browser or mobile device. To opt out of certain type of emails, you need to click on the unsubscribe link located in the footer of the email, or contact our support team at firstname.lastname@example.org.
The services that we use for these purposes may collate data with respect to the date and time the message was viewed by our users, alongside when they interact with it, such as by clicking on the link embedded or included in the message.
4.5. To make further research and analyze your use of the Service
This helps us to better understand our business, evaluate our operations, maintain, enhance, innovate, plan, design, and develop Sellables and our recent products. We also utilise such data for statistical analytic purposes, to test and boost our offers. This further gives us a better understanding of what features and sections of Sellables our users like more, what categories of users use our Service. Based on this, we often brainstorm on how to improve Sellables based on the results obtained from this processing. Take for example, if we noticed that Jobs section is not as popular as others, we may focus on improving it.
4.6. To send you marketing campaigns
Your personal data is also processed by us for our marketing campaigns. We may input your email address to our marketing list. As such, you will receive notification about our products, such as, special offers, for our products and services or our partners. If you want opt out from receiving marketing email notifications from us, you can unsubscribe following instructions at the footer of the marketing emails and by contacting our support team at email@example.com.
We may also show you advertorials on the Website, and send you push notifications for marketing purposes. To opt-out just change the settings on your mobile device or/and browser.
4.7. To personalize our ads
We and our partners use your personal data to personalize advertorials and possibly even show them to you at the appropriate time. Take for instance, if you have visited our Website, you might have viewed advertorials of our products, in your social media feed.
We may target advertorials to you through our diversity of ad networks and dealings, using data from advertising technologies on and off of our Services such as unique cookie or matching tracking technology, pixel, device identifiers, geolocation, operation system information and email.
How to opt out or decline personalized advertising
iOS: On your iPhone or iPad, simply click on “Settings,” then tap “Privacy” and select “Advertising” and then enable “Limit Ad Track”. Secondly, you can reset your advertising detector (this also may help you reduce the number of personalized ads) in the same section.
Android: To opt-out of advertorials on your Android device, just tap settings on your mobile phone, tap on Google icon, select “Ads” and enable “Opt out of interest-based ads”. Additionally, you can reset your advertising detectors in the same section (this also may help you to reduce number of personalized ads).
For more information on how to affect advertising choices on different devices, please, take a look at the information given here.
Here are some useful opt out links of some interest-based advertising listed below:
- Network Advertising Initiative – http://optout.networkadvertising.org/
- Digital Advertising Alliance – http://optout.aboutads.info/
- Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
- Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
- DAA AppChoices page – http://www.aboutads.info/appchoices
Google permit its users to opt out of Google’s personalized ads and to hinder their data from being used by Google Analytics.
Facebook also permit its users to personalize the types of ads they see on Facebook. To find out how you can control the ads you see on Facebook, please tap here or adjust your ads settings on Facebook.
4.8. To implement our Terms and Conditions of Use and to prevent and combat fraudulent activities
4.9. To abide with legal obligations
We may process, use, or share your data when the law demands of it, basically, if a law enforcement agency demand for your data by available legal means.
4.10. To process your payments
Though we provide free products and/or services, we also offer paid ones as well. In view of this, we use third-party services for payment processors to carryout this process. To enjoy premium services you will have to make a payment to access the paid features of the Service.
UNDER WHAT LEGAL BASES WE USE IN PROCESSING YOUR PERSONAL DATA
We process your personal data, specifically, under the following legal bases:
5.1. your consent;
In this context, we use your cookies as described in our Cookies Policy .
5.2. to carry-out our contract with you;
5.3. for our (or others’) legitimate concerns; Under this legal basis we, especially:
- Interact with you in relation to your use of our Service
This sends push notifications to you notifying you that you have unread messages. The legitimate concern we lean on for this purpose is our focus is to encourage you to use our Service more often. We also take into note the potential benefits to you.
- We make research and scrutinize your use of the Service
Our legitimate concern for this purpose is our interest in enhance our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of our mobile application with seamless transition, easier and more enjoyable, or to unveil and test new features).
- send you marketing notifications
The legitimate concern we lean on for this processing is our focus to promote our Service in a measured, proper and befitting way.
- personalize our advertorials
The legitimate concern we lean on for this processing is our focus to promote our Service in an agreeably targeted way.
5.4. to obey legal obligations.
WITH WHOM DO WE DISCLOSE YOUR PERSONAL DATA
6.1. Service providers
We share personal data with third parties that we hire to render services or carry out business functions on our behalf, in accordance with our instructions. We may share your personal information with the enlisted types of service providers:
- cloud storage providers (Amazon, DigitalOcean, Hetzner)
- data analytics providers (Facebook, Google, Appsflyer)
- login service providers (Google, Apple, Facebook, Twitter)
- marketing partners (specifically, social media networks, marketing agencies, email delivery services; namely Facebook, Google)
- payment services providers (Solid)
- local banks, credit and debit organizations (Access Bank, Sterling Bank, First Bank, Kuda Microfinance Bank, etc.);
6.2. Law enforcement agencies and other public establishments
6.3. Third parties as part of a merger or procurement
As we promote the growth our business, we may acquire or sell assets or business offerings. Customers’ information is primarily one of the transferred business assets in these types of transactions. We may also share such information with any linked entity (e.g. parent company or its branch(es)) and may transfer such information in the course of a commercial transaction, such as the sale of our business, a dispossession, merger, consolidation, or asset sale, or in the unimaginable event of liquidation.
If there is a data infringement that may cause a threat for the rights and freedoms of individuals, we will alert competent supervisory authority, when such notification is necessary. If the risk is evaluated by us as “high”, we will also alert the affected data subjects without undue delay. The duration for such report will be developed by us in relation to the number of affected data subjects and time required to collect contact information for announcement.
If the measures taken or suggested to be taken with regards to the infringement did not deal with your concerns, you have the right to make a complaint with a competent supervisory authority, or institute legal proceedings in a court of competent jurisdiction.
NO RESTRICTION CLAUSE
No restriction of liability shall avail us in the event that we act in infringement of the principles set out in Section 3.
HOW YOU CAN EXERCISE YOUR RIGHTS
To manage your personal data, you have the following rights:
Accessing / evaluating / updating / rectifying / amending / your personal data. You may review, edit, or modify the personal data that you had provided earlier to Sellables in the settings section on the Website.
You may also demand for a copy of your personal data stored during your use of the Service at firstname.lastname@example.org.
Erasing your personal data. You can request deletion of your personal data by sending us an email at email@example.com.
When you request wiping-out of your personal data, we will use reasonable efforts to comply to your request. In certain situations, we may be legally authorised to keep some of the data for a certain period time; in such situation, we will honour your request after we have complied with our obligations.
Opposing to or restricting the use of your personal data (including for direct marketing purposes). You can make a request or demand to stop using all or some of your personal data or limit our use of your personal data thereof by sending a request at firstname.lastname@example.org.
The right to make a complaint with supervisory authority. We would love you to contact us first-hand, so we could handle your concerns before making a complaint with a competent data protection supervisory authority.
We do not deliberately process personal data from persons under 18 years of age. If you learn that anyone below the age of 18 has provided us with personal data, please contact us at email@example.com.
Last updated: 3 January 2023