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I. OVERVIEW AND LOCATIONS
At Mobile Ajua, Inc. (hereinafter “AJUA,” “We” or “Our”), We are committed to protecting the privacy rights of ajua participants, Our clients’ customers and visitors to Our website (hereinafter “You” or “Your”) as well as abiding by all applicable privacy laws and regulations.
AJUA operates internationally and has offices in the United States, Kenya, Nigeria, and the Caribbean. As AJUA has global operations, data is stored, processed and transferred between international and local data center providers.
A) Personal Data
In delivering survey services to Our clients, AJUA may collect Your personal data (hereinafter “Personal Data”) either from You, an AJUA client or a third party. Examples of the types of Personal Data AJUA collects include: phone number; email; gender; age; address or place of residence; spending habits; income level; education level; current employment; purchases; and ownership (e.g., smart phone or home); and photos.
The exact nature of the Personal Data AJUA collects will vary from client-to-client and from survey-to-survey.
b) Credit Card and Billing Data
AJUA will not collect, process or store Your credit card or billing data without Your prior authorization. AJUA uses third party software platforms to process online payments. Each such platform has its own privacy policy, which You will be asked to agree to prior to Your Personal Data being collected. Please make sure that You understand the online platform’s privacy policy prior to entering any information. If you have any questions, please contact the AJUA Privacy Officer as set forth in the Privacy Officer Contact section of this Privacy Policy.
c) AJUA Website Visitor Data
When You visit an AJUA Website, We use a third party service, Google Analytics, to collect standard internet log data and details of Your behavior patterns while on the site. AJUA does this to find out information such as the number of visitors to Our website and the pages of the site visited. The data is only processed in such a way that You remain anonymous. We do not make, and do not allow Google to make, any attempt to find out Your identity or the pages of the Website You visited.
d) Cookies
AJUA uses cookies to store visitor information that enhances website user experience, including user preference, look and feel, performance and app related data. All user related data is encrypted. No passwords or sensitive data is stored in cookies.
II. CHILDREN AND MINORS
If You are under the age of consent in the jurisdiction in which You reside, You will need the consent from a parent or guardian before you can create an account or provide any Personal Data to AJUA. For residents of the European Union: If You are under the age of 16 and reside in the European Union You will need the consent from a parent or guardian before you can create an account or provide any Personal Data to AJUA.
III. WHY PERSONAL DATA IS COLLECTED
AJUA collects Your Personal Data to deliver contractual services to Our clients. Examples of the services We provide include:
- targeted surveys (e.g., surveys that target certain demographics such as age or income level)
- surveys to collect certain demographics (e.g., age or income) for internal audience segmentation and analysis for improving targeted services
- surveys to improve the products and services offered to You as a consumer
- surveys to improve the products and services offered by our clients
The nature of the survey services that We provide Our clients varies from client-to-client and from survey-to-survey. You will be advised of the nature of the survey and the use to which survey response data will be put prior to your survey being launched.
IV. HOW PERSONAL DATA IS COLLECTED
Personal Data is collected via questions and answers using short message service (“SMS” aka “text messaging”) or other communication platforms.
VI. DATA USE
a) Third Parties
Personal Data is not shared with any third party other than to deliver the surveys and related response data and analysis that We have contracted with Our clients to perform and in which You have agreed to participate. AJUA does not sell any Personal Data that it collects.
b) Compliance with laws and public safety
AJUA may provide your Personal Data to comply with requests by law enforcement or other governmental authorities, or to protect the safety of public.
V. WHERE YOUR PERSONAL DATA IS STORED
AJUA utilizes Amazon Web Services (hereinafter “AWS”) Cloud Computing Services for storage of Personal Data. Personal Data is stored in AWS facilitates located in the United States, the European Union and Africa. Data is transferred securely using the services of local messaging providers and other secure communication platforms. Personal Data is stored in AJUA’s databases using Our proprietary software and processes
VI. ADDITIONAL USER RIGHTS PROVIDED UNDER EUROPEAN UNION DATA PRIVACY LAW,.
For users residing in the European Union, AJUA adheres to the European Union’s applicable data privacy and protection laws for Personal Data, including the General Data Protection Regulation (hereinafter the “GDPR”), in connection with any Personal Data collected in connection with the delivery of Our services as set forth below.
a) Personal data retention
Your Personal Data will be retained for or as long as required:
- to fulfill the purposes for which the Personal Data was collected;
- in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; or
- as required by other applicable laws or regulatory requirements.
Certain Personal Data may be retained in perpetuity by AJUA.
b) Right to access, copy and correct Personal Data
You have the right to see all of Your Personal Data that AJUA maintains and to have a copy of such data. You also have the right to make corrections to Your Personal Data as maintained by AJUA. Any request to access, copy or correct Personal Data should be made to the AJUA Data Protection Officer as set forth in Section XII of this Privacy Policy.
c) Right to delete Personal Data
Unless prohibited by law, you may request to have Your Personal Data deleted from AJUA’s systems and files. By requesting such deletion You are agreeing that We will no longer maintain any archival data on Your behalf and as such We will not be able to verify or reconstruct missing or lost data. In addition, We may not be able to provide or complete the survey(s) in which You have agreed to participate. Any request to delete Personal Data should be made to the AJUA Privacy Officer as set forth in the Privacy Officer Contact section of this Privacy Policy.
d) Right to opt-out
You have to the right to opt-out of the collection or use of Personal Data at any time. In doing so, however, We may not be able to provide or complete the survey(s) in which You have agreed to participate. Any request to opt-out of the collection of Personal Data should be made to the AJUA Privacy Officer as set forth in the Privacy Officer Contact section of this Privacy Policy.
e) Right to restrict the use of Personal Data
You have the right to restrict the use of Your Personal Data at any time. In doing so, however, We may not be able to provide or complete the survey(s) in which You have agreed to participate. Any request to restrict the use of Personal Data should be made to the AJUA Privacy Officer as set forth in the Privacy Officer Contact section of this Privacy Policy.
f) Right to object to the further processing of Personal Data
You have the right to object to the further processing of Your Personal Data at any time. In doing so, however, We may not be able to provide or complete the survey(s) in which You have agreed to participate. Any request to restrict the further processing of Personal Data should be made to the AJUA Privacy Officer as set forth in the Privacy Officer Contact section of this Privacy Policy.
g) Sharing of data with third parties
In the delivery of services, AJUA may share your Personal Data with third parties. Where such entities act as Data Processors, We will ensure that there is an appropriate agreement in place. Where such entities act as Data Controllers, they will be under an obligation to process your Personal Data in accordance with applicable privacy laws such as the GDPR.
h) Notice of security breach
If a security breach causes unauthorized intrusion, which results in unauthorized access to your Personal Data We will notify You as soon as possible and advise You of all corrective actions, taken in response.
1. ADDITIONAL USER RIGHTS UNDER THE KENYA DATA PROTECTION ACT, THE NIGERIA DATA PROTECTION REGULATION AND OTHER LOCAL LAWS
For users residing in Kenya, Nigeria and the rest of the world, AJUA adheres to their respective and applicable data privacy and protection laws for Personal Data,
VII. SECURITY
AJUA uses reasonable precautions to protect Personal Data from unauthorized use, access, disclosure, alteration or destruction. These precautions include appropriate physical, electronic and managerial procedures. AJUA is dedicated to providing a high level of privacy protection for all of the Personal Data that it collects. AJUA has security measures in place to prevent data loss and alteration of Personal Data during the transmission from You to Our servers.
Unfortunately, data transmission via SMS is not completely secure, the security of data exchanged via SMS is not guaranteed and AJUA does not warrant, guarantee or make any representations regarding the security of any Personal Data transmitted.
We do appreciate that all security mechanisms can be breached and we have therefore put in place systems to detect, contain and restore integrity of your data expeditiously if and when this happens.
VIII. CONSENT
By submitting Your Personal Data to AJUA You consent to the use of Your Personal Data by AJUA as set forth in this Privacy Policy.
VIIII. UPDATES
AJUA reserves the right to modify this Privacy Policy any time without notice.
X. DATA PROTECTION OFFICER CONTACT
Anyone with questions about AJUA Privacy Policy should contact the AJUA Data Protection Officer by email at: [email protected]
The AJUA Data Protection Officer can also be contacted by mail at:
AJUA KENYA.
Attention: The Data Protection Officer
Woodlands Trail, Woodlands Rd, Off Dennis Pritt Rd
Nairobi, Kenya
Telephone: +254 719 113 770
Woodlands Trail, Woodlands Rd, Off Dennis Pritt Rd
Nairobi, Kenya
Telephone: +254 719 113 770
AJUA NIGERA
Attention: The Data Protection Officer
Plot 8 The Providence St, Lekki Phase I 106104, Lekki, Nigeria
Residents of the European Union may also contact a Supervisory Authority in the member state of their usual residence or place of work or in the member state in which an alleged breach occurred.
Residents of jurisdictions other than the European Union should consult their local law for guidance on reporting a privacy concern.
AJUA Privacy Policy Last Update: 20 AUG 2022