1.2. Cheapmedia Nigeria is an advertising and marketing service which provides an advertising platform to advertising agents and advertising sellers (“Client”). Cheapmedia Nigeria's advertising platform enables its Clients purchase various promotional Products an unlimited number of times at different times; enjoy access to application for booking promotional products through a personal account on the Agency's website; have the choice of independently selecting suitable advertising Products from among the Products proposed, taking into account cost, launch, and placement terms, and other conditions. The Client has control over advertising contents as it is responsible for presenting necessary documents and files for displaying an advertising message using an advertising Product.
2. INFORMATION THAT WE COLLECT AND HOW THE INFORMATION IS COLLECTED
2.1. When you visit our Website: We collect your Personal Information if you use http://www.cheapmedia.net and open an account to use the platform or perform any transactions on the platform. We collect personal information such as email address, password, to enable you sign up for our services.
2.1.1. When you create an account with us, we collect your Personally Information for your user profile namely first name, last name, address, gender, marital status, and phone number. And when you have a Cheapmedia Nigeria Wallet, we collect the information that you provide to track the value of your digital assets through your Wallet. Please note that if you refuse to share your Personal Information for this purpose we will not be able to provide our services to you.
2.1.2. If you contact our support team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure high quality service.
2.1.3. If you participate in our surveys, we collect your insights into the Services and responses to our questions. You may choose whether to participate in any survey.
2.1.4. When you visit our Website, we may also collect information that does not necessarily reveal your identity directly but may include information about the specific device you are using or location, such as the hardware model, operating system version, web-browser software (such as Chrome, FireFox, Internet Explorer, Safari, etc) and your Internet Protocol (IP) address/MAC address/device identifier. In some countries, this information may be considered Personal Information under applicable data protection laws.
2.1.5. We also automatically collect and store certain information in server logs such as: statistics on your activities on our Website, and products; information about how you came to and used our Website, and products; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. In some countries, this information may be considered Personal Information under applicable data protection laws.
2.2. Information collected through Third Parties: Third parties that assist us with our business operations also collect information through the Services. We may engage service providers to collect information to help us secure the Services and detect and prevent fraud. We may receive information about you from our advertising partners such as when advertising campaigns are published through the Services. Some of this information is collected through the technology described below.
2.3.1. The Services use the following cookies: Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we may offer. Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function. Functionality cookies, which are used to recognize you when you return to the Services. We also use Google Analytics which is a Google service that collects information about use of the Services. Google Analytics does not identify individual users.
2.3.2. Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, mobile device, or tablet. You also may be able to reject mobile-device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
2.4. Our Policy on Do Not Track (DNT) Signals: Some web browsers including Chrome, Firefox, Internet Explorer, and Safari incorporate a DNT or similar feature that signals to websites that a user does not want to have his or her online activity and behaviour tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Cheapmedia Nigeria, do not respond to DNT signals.
2.5. Performance and Usage Data: In connection with using certain Cheapmedia Nigeria services, we may automatically collect certain data relating to the performance and configuration of the Cheapmedia Nigeria services, our customers’ and their end-users’ consumption of and interaction of such services (Usage Data). Usage Data is generally technical information obtained from product software or systems hosting the services, devices accessing these products and services, and/or log files generated during such use which typically does not directly identify an end-user.
3. HOW WE USE THE INFORMATION WE COLLECT
3.1. Cheapmedia Nigeria may use information collected when you visit our Website for the following business purposes:
● To provide and maintain our services;
● To allow you to open and operate an Account;
● To set up and maintain your Account and Wallets;
● To enable you to complete Transactions on the platform;
● To notify you about changes to Cheapmedia Nigeria;
● To correspond with you in relation to your Account and your Transactions;
● To analyse use of Our Site and the services we provide;
● To provide Customer care and support;
● To monitor the usage of Our website;
● To detect, prevent, and address technical issues;
● To allow you to participate in interactive features of Cheapmedia Nigeria when you choose to do so;
● As required for legal and regulatory purposes, including for dispute-resolution purposes;
● To provide you with information about services and promotions that may be of interest to you, from ourselves and third parties;
● For market research e.g. surveying our Users’ needs and opinions on issues, such as our performance.
● To ensure legal compliance;
● Comply with legal requirements; and
● Enforce or exercise our rights and for other legitimate purposes.
3.2. Legal Bases for Collecting Your Personal Information
Please note that you are not obliged to share your Personal Information with Us. But if you refuse to share the Personal Information we require from you for the purpose of providing our services, we will not be able to provide our services to you. To use your information as described above, we rely on the following legal bases:
3.2.1. Provide the Services to You: We process your information to perform the contract (Terms of Service) that you have with us.
3.2.2. Legitimate interests: We use your information for legitimate business interests when permitted by law. For example, we analyse users’ behaviour on the Services to improve them, for direct marketing and for administrative use, fraud detection, and other legal purposes.
4. HOW WE SHARE INFORMATION WE COLLECT
4.1. We may share personal information about you with third parties in the following circumstances:
4.1.2. Corporate Transaction: We may share and transfer information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control by Cheapmedia Nigeria or any affiliated company (in each case, whether in whole or in part).
4.1.4. Google Analytics
4.1.5. Vital interests: We may disclose information where we deem it necessary for the purpose of protecting the vital interests of any person.
4.1.6. Compliance with Laws: In compliance with laws or any competent law-enforcement body, court, government agency, regulatory body, or third party, we may disclose information where we believe disclosure is necessary or required (i) by law or regulation, in order to comply with legal process or government requests (including in response to public authorities to meet national security or law enforcement requirements); (ii) to exercise, establish, or defend our legal rights; (iii) to prevent or investigate possible wrongdoing in connection with our website; or (iv) to protect the personal safety of users of our website or the public.
4.1.7. With your consent: We may disclose your personal information for any purpose with your consent.
4.1.8. Other legitimate business purposes: We may share your personal information when it is necessary for other legitimate purposes such as protecting Cheapmedia Nigeria confidential and proprietary information or where necessary to support, respond to, and provide our products and services to our customers. As a general rule, Cheapmedia Nigeria will not share, rent, sell, or otherwise disclose any of your personal information, except with your permission. We use and disclose personal information for the purposes that we have disclosed to you, except as otherwise permitted by law. We will request your consent before we use or disclose your information for any materially different purpose. Unless specifically described below, consent may be obtained in any legally sufficient method. For example, depending on the circumstance and the laws of your jurisdiction, consent may be obtained by providing you with notice and the opportunity to opt-out. In addition, Cheapmedia Nigeria may aggregate information collected through the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (Aggregated Information). Cheapmedia Nigeria shares Aggregated Information with third parties and does not limit third parties’ use of the Aggregated Information.
5. GENERAL PROVISIONS ON CONSENT TO PROCESSING OF PERSONAL DATA
5.1 By registering on the website Cheapmedia Nigeria (hereinafter referred to as the Site), the User undertakes to accept this Consent to the processing of personal data (hereinafter referred to as the Consent). Acceptance (acceptance) of the Consent offer is registration on the site or provision of personal data in feedback forms posted on the site. The user consents to the legal entity that owns the website Cheapmedia.net and which is located at: 625003, Tyumen, ul. Volodarsky, 14, of. 505, to the processing of your personal data with the following conditions:
5.1.1 This Consent is given to the processing of personal data both without and with the use of automation equipment.
5.1.2. Consent to the processing of personal data of the User is given solely and exclusively for the purpose of using to inform the User about the status of goods and services ordered by him on the website, for use in drawing up an Offer Agreement, for replying to the User’s requests via the feedback form on websites, and also for sending messages and notifications.
5.1.3. The basis for the processing of personal data are: Section 37 of the Constitution of the Federal Republic of Nigeria 1999; and Nigeria’s Data Protection Regulation 2019.
5.1.4. The transfer of personal data to third parties is carried out on the basis of the legislation of the Russian Federation, the subject of personal data agrees that his data can be transferred to third parties - partners of the Site.
5.1.5. Personal data is processed until all necessary procedures are completed. Processing can also be terminated at the request of the subject of personal data. Storage of personal data recorded on paper is carried out in accordance with regulatory and legal provisions in the field of archiving and archival storage.
5.1.6. Consent is given including the possible cross-border transfer of personal data and information (advertising) alerts.
5.1.7. Consent may be revoked by the subject of personal data or his representative by sending a written statement to the Site administration or his representative at the address indicated at the beginning of this Consent.
5.1.8. In the case of the withdrawal of personal data by the subject or his representative of the
Consent to the processing of personal data, the Site Administration has the right to continue
processing without the permission of the personal data subject if there are grounds within the extant laws in Nigeria.
5.1.9. The processing of personal data of the Personal Data Subject can be carried out using automation equipment and/ or without the use of automation equipment in accordance with the current legislation of the Russian Federation and the internal provisions of the Site. The site administration has the right to involve for the processing of personal data of the Personal Data Subject of subcontractors, and also has the right to transfer personal data for processing to its affiliates, while ensuring that such subcontractors and affiliated persons accept the corresponding obligations regarding the confidentiality of personal data.
5.10. This Consent is valid from the moment the User (subject) sends the registration data through the Site until the processing of personal data is terminated for the reasons specified in clause 9 of this document.
6. HOW WE SECURE YOUR INFORMATION
6.1. Except as described above, we do not reveal information about you to unaffiliated third parties. We restrict access to nonpublic personal information about you to those Cheapmedia Nigeria employees who need to know that information to provide products or services to you. Cheapmedia Nigeria maintains (and requires its service providers to maintain) appropriate organizational and technical measures designed to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including: Employing physical access controls, encryption, Internet firewalls, intrusion detection, and network monitoring depending on the nature of the information and the scope of processing; providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible; and requiring our employees to keep all personal information confidential.
6.2. All information you provide to us are stored on secure servers in a controlled environment with limited access. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
6.3. While no transmission of information via the internet is completely secure, we take reasonable measures to protect your personal data. We cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
6.4 You are responsible for maintaining the security of your account, including the device on which you store your wallet. Access to the services through your account is treated as authorized by you. Unauthorized access to password-protected or secure areas is highly prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services with or without notice if we suspect or detect any breach of security. If you believe that the information you provided to us is no more secure, please notify or contact us immediately using the contact information provided below.
6.5. We keep your personal information in identifiable form only as long as we need it for the lawful purpose for which we collected it, or if longer or shorter, to comply with Law, to resolve disputes, or to enforce agreement with you.
7. HOW LONG WE RETAIN YOUR INFORMATION?
7.2. When we have no justifiable business need to process your personal information, we will either delete or anonymized it, 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.
8. YOUR PRIVACY RIGHTS
8.1. Updating Your Information: If you would like to update personal information that you have provided to us, please logon to http://www.Cheapmedia.et/my-profile/
8.2. Additional Rights for the EEA and Certain Other Territories: If you reside in certain territories (such as the European Economic Area), you may have the right to exercise certain privacy rights available to you under applicable laws such as the General Data Protection Regulation (GDPR). We will process your request in accordingly. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.
8.3. Right not to provide consent or right to withdraw consent: We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent or right to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal or information for which consent is not required.
8.4. Right of access: You may have the right to access the personal information that we hold about you. For details on how to access your personal information collected and held by us, and how to update that information or correct factual errors in it, please contact us at email@example.com. We may retain original and updated information for reasons such as agreement enforcement, dispute resolution, record-retention requirements, technical constraints, troubleshooting. For security purposes, we may request information to help verify your identity before granting access or making changes to the information.
8.5. Right of erasure: In certain circumstances, you may have the right to the erasure of personal information that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected) except, where it is not consistent with our legal and regulatory obligations.
8.6. Right to object to processing: You may have the right to request that we stop processing your personal information or stop sending you marketing communications.
8.7. Right to correct: You may have the right to require us to correct any inaccurate or incomplete personal information.
8.8. Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held). If our client requests Cheapmedia Nigeria to remove the data, we will respond to it and delete, amend or block access to any Personal Information that we are storing only if we receive a written request to do so from our client who is responsible for such Personal Information, unless we have a legal right to retain such Personal Information. We reserve the right to retain a copy of such data for archiving purposes or to defend our rights in litigation.
9. LINKED WEBSITES AND OTHER THIRD PARTIES
10. INTERNATIONAL DATA TRANSFERS
10.1. Your information, including Personal Data, may be transferred to countries other than the one you live in. This means your Personal Data may be maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Personal information, including personal information collected in the European Economic Area (EEA) or Switzerland, may be transferred, stored, and processed by us and our services providers, partners, and affiliates in Nigeria, the United States, and potentially other countries whose data protection laws may be different to the laws of your country, for example to Canada. We will not transfer Personal Information originating in the EU or Switzerland to third parties unless such third parties have met the requirement of providing at least the same level of privacy protection to your Personal Information as required by the Principles of the EU-US Privacy Shield Framework, the Swiss-US Privacy Shield Framework, and the Data Protection Guidelines 2019 of the National Information Technology Development Agency (NITDA) in Nigeria.
11. BLOGS AND SOCIAL MEDIA
11.2 Our website or other online community may include publicly accessible blogs or community forums. Any information you provide in these areas may be read, collected and used by others who access them. This includes information posted on our public social media accounts. Be advised to guard your personal data responsibly.
12. CHILDREN'S PRIVACY
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and monitor and guide children’s online activity. Our Website, products, and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from such individuals. If you become aware that a child has provided us with Personal Information, please contact us at firstname.lastname@example.org. If we become aware that an individual under the age of 18 has provided us with personal information, we will take steps to delete such information.
If you have any questions about our privacy policies; want to exercise your right to see a copy of the information that we hold about you; think that information we hold about you may need to be corrected; want to delete all or any part of your information; or want to object to the processing on legitimate grounds; or you have a particular complaint, please email email@example.com with enquiry topic ‘Data privacy’ or alternatively send a signed letter addressed to:
Data Protection Officer