Privacy Notice

JudeAyua.com Privacy Notice

Last Updated June 2024

Overview

This Privacy Notice describes your privacy rights particularly regarding why, how, and when we collect, use, store, share, and protect your information across our website, other platforms we manage, email notifications and tools regardless of how you use or access them. This Privacy Notice is applicable to all of the website and/or payment platforms (“Platforms”) offered by JudeAyua.com or its subsidiaries or affiliates collectively referred to as JudeAyua.com “Services.”

JudeAyua.com (“JudeAyua” “We,” “Us,” “Our”) is the official website and personal blog of Jude Terna Ayua; lawyer, artist, writer, and youth mentor. Jude Ayua is a published author, and writes broadly about law, religion, policy and regulation, technology, leadership, and education.

At JudeAyua.com, we highly regard the privacy of our users. We greatly value your trust in sharing your information with us. This Privacy Notice (“Notice”) outlines the Personal Information we collect about our users (“User,” “You,” “Your”), the reasons for collecting it, and how we utilize it. It provides information about our privacy practices and helps you understand how we manage your information in compliance with the provisions of the Nigerian Data Protection Act 2023, other applicable legislation and regulatory requirements, and international best practices.

Definitions

“Cookies”: A cookie is a small data file that is transferred to your computer or mobile device. It enables us to remember your account log-in information, IP addresses, web traffic number of times you visit, browser type and version, device details, date, and time of visits.

“JudeAyua.com,” “we”, “us”, or “our” in this privacy statement means the JudeAyua.com entity that is responsible for processing your personal information, and includes its subsidiaries or affiliates.

“Personal Information/Data” means any information that can be used to identify a living person including email address, company name, password, payment card, financial information (such as bank account number, etc.), government-issued identity card and it may also include anonymous information that is linked to you, for example, your internet protocol (IP), log-in information, address, location, device, or transaction data.

“Services” include the services listed in our Terms of Use and our website.

“Sites” means any platform including but not limited to mobile applications, websites, and social media platforms.

“User” means an individual who uses the Services or accesses the site, platforms, and has agreed to use the end services of JudeAyua.com.

Privacy Principles

JudeAyua.com operates with the following core principles:

• Empowering you to be in charge of your personal information and to make your own voluntary choices about your personal data, subject to applicable law and regulations;
• Keeping and securing your personal information: we honor and protect your trusting us with your information, and we take responsibility to ensuring that appropriate security measures are put in place and your personal information is protected;
• Ensuring transparency and educating you to know what personal information is, how we collect personal information, for what purpose and how we secure personal information;
• Abiding by local and international laws: JudeAyua.com is a platform with a global coverage and local privacy expertise. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy notices may apply to some of our products and services. Please visit the webpage of the specific product or service to learn more about our privacy and information practices in relation to that product or service;
• Collecting and storing personal information on a “need to collect” basis: JudeAyua.com collects personal information to perform its Services for you. We work to have measures in place to prevent collecting and storing personal data beyond what we need.

1. Your Personal Information We May Collect

We may collect, use, process, store, or transfer personal information such as:

• Identity Data such as, your full name(s), your government-issued identity number, and your date of birth. This data is to enable us to verify your identity in order to offer our services to you;
• Contact Data: This is data we need to reach out to you, such as your contact address, email address, telephone number, details of the device you use and billing details;
• Log/Technical information: When you access JudeAyua.com services, our servers automatically record information that your browser sends whenever you visit a website, links you have clicked on, length of visit on certain pages, unique device identifier, log-in information, location and other device details;
• Transactional Data: These are information relating to a payment when you as a merchant (using one or more of our payment processing services) or as a customer, are using our products or services;
• Marketing and Communications Data: This includes both a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.
• Records of your discussions with us, when we contact you and if you contact us.

1.1. We may also collect, store, use, and transfer non-personal information or anonymized data such as statistical or demographic data.

1.2. This Privacy Notice applies to JudeAyua.com services only. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies, plug-ins, or other files on your computer, collect data, or solicit personal information from you. JudeAyua.com does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements.

2. How We Collect Your Personal Information

2.1. The Personal Information we have about you is directly made available to us when you:

• Subscribe to our Newsletter;
• Use any of our services;
• Contact our customer support team;
• Fill in our online forms; or
• Contact us.

2.2. The lawful basis we rely on for processing your Personal Information are:

• Consent: When you agree to us collecting your Personal Information by using our Services.
• Contractual obligation: Without your Personal Information, we cannot provide our Services to you.
• Legal obligation: To ensure we are fully compliant with all applicable legislation. We protect against fraud by checking your identity with your Personal Information.

3. How We Use Your Personal Information

3.1. We may use your Personal Information we collect to:

• Provide, administer and communicate with you about products, services, offers, programs and promotions of JudeAyua.com, affiliates and partners;
• Evaluate your interest in our services and contact you regarding potential relations with JudeAyua.com;
• Evaluate and improve our services, and developing new services that you may be interested in;
• As necessary to establish, exercise and defend legal rights;
• To use data analytics to improve our website, products or services, and user experiences;
• Process your payment transactions (including authorization, clearing, chargebacks and other related dispute resolution activities);
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities;
• For other purposes for which we provide specific notice at the time of collection.

4. Data Security and Retention

4.1. We are committed to protecting the information we collect about you. We maintain administrative, technical and physical controls designed to protect the Personal Information you provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.

4.2. Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfill their job responsibilities.

4.3. We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Information is protected and maintained. Transmitting information online is not entirely secure. Whilst we take all reasonable steps to ensure that your Personal Information is secured and well protected we do not guarantee that all information provided online is secure. 

4.4. We will only retain personal information on our servers for as long as is reasonably necessary and as long as we are providing Services to you. Your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection, and prevention. Where we retain your Personal Data, we do so in compliance with limitation periods under the applicable law.

5. When We May Disclose Information You Provide

We may disclose and/or share your information under the following circumstances:

5.1. Service Providers

We may disclose your information with third parties who perform services to you on our behalf, including without limitation, ride-hailing, event management, marketing, customer support, data storage, data analysis and processing, and legal services.

5.2. Legal Compliance and Protection

We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Notice or reasonably necessary or appropriate for any of the following reasons: 

1. to comply with legal process; 
2. to enforce or apply our Terms of Use and this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; 
3. enforce our Code of Conduct and policies contained and incorporated therein, 
4. to respond to your requests for customer service; and/or  
5. to protect the rights, property, or personal safety of JudeAyua.com, our agents and affiliates, our users, and the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes. 

5.3. Business Transfers

As we continue to develop our business, we may engage in certain business transactions, such as the transfer or sale of our assets. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.

5.4. Affiliated Companies

We may disclose your information with current or future affiliated companies.

5.5. Consent

We may disclose your information to any third parties based on your consent to do so.

5.6. Aggregate/De-identified Information

We may disclose de-identified and/or aggregated data for any purpose to third parties, including advertisers, promotional partners, and/or others.

6. Legal Basis for Collecting Your Personal Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose information that can be directly linked to or used to identify you. To the extent those laws apply, our legal grounds for processing such information are as follows: 

6.1. To Honor Our Contractual Commitments to You

Much of our processing of information is to meet our contractual obligations to provide services to our users. 

6.2. Legitimate Interests

6.2.1. In many cases, we handle information on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, these include: Customer service; Marketing, advertising, and fundraising; Protecting our users, personnel, and property; Managing user accounts; Organizing and running events and programs; Analyzing and improving our business; and Managing legal issues.

6.2.2. We may also process information for the same legitimate interests of our users and business partners.

6.3. Legal Compliance

We may need to use and disclose information in certain ways to comply with our legal obligations.

6.4. Consent

Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw your consent; in accordance with applicable law.

7. Online Analytics

We may use third-party web analytics services (such as Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive to our Site, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the official Google Analytics Opt-out Browser Add-on.

8. Your Choices and Data Subject Rights

8.1. We may transfer Personal Information that we maintain about you to recipients outside the country in which the Personal Information was originally collected. The data protection regulations of these countries may be different from those of your country. Where Personal Information is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Information. 

8.2. Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act 2023 (the “NDPA”) and other applicable regulations. JudeAyua.com will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

1. The transfer is necessary for the performance of a contract between JudeAyua.com and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request.
2. The transfer is necessary to conclude a contract between JudeAyua.com and a third party in the interest of the Data Subject.
3. The consent of the Data Subject has been obtained.
4. The transfer is necessary for reasons of public interest.
5. The transfer is for the establishment, exercise, or defense of legal claims.
6. The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
7. We will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

9. Legal Basis for Processing 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:

1. Provide the Services to You: We process your information to perform the contract (Terms and Conditions of Service) that you have with us.
2. Legitimate interests: We use your information for legitimate business interests when permitted by law. For example, we analyze users’ behavior on the Services to improve them, for direct marketing, and for administrative use, fraud detection, and other legal purposes.
3. Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us using the contact information provided at the end of this Privacy Notice.
4. Performance of a contract: The processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
5. Legal Compliance: Processing is necessary for compliance with a legal obligation to which JudeAyua.com is subject.
6. Vital Interest: Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.
7. Public Interest and Mandate: Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in JudeAyua.com.

For the purpose of this Privacy Notice, consent means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.

10. Your Rights as a Data Subject

10.1. Individuals who have their Personal Information held by us are entitled to exercise the rights below and may contact us accordingly:

1. Right to request for and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format;
2. Right to information on their personal information collected and stored;
3. Right to objection or request for restriction;
4. Right to object to automated decision-making;
5. Right to request rectification and modification of Personal Information which JudeAyua.com keeps;
6. Right to request for deletion of their data;
7. Right to request the movement of data from JudeAyua.com to a third party; this is the right to the portability of data;
8. Right to object to, and to request us to restrict the processing of their information.

Your request will be reviewed by our Data Protection Officer (DPO) and carried out except as restricted by law or JudeAyua.com’s statutory obligations. You may decline to provide your Personal Information when it is requested by JudeAyua.com, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.

You have various rights with respect to the collection and use of your information through the Services.  Those choices are as follows:

10.2. Email Unsubscribe

You may unsubscribe from our marketing emails at any time by clicking on the “unsubscribe” link at the bottom of each newsletter or by emailing reachus@judeayua.com with your request.

10.3. Account Preferences

If you have registered for an account with us through our Services, you can update your account information or adjust your email communications preferences by logging into your account and updating your settings.

10.4. Data Sharing

We may share your information with trusted service providers or business partners in countries other than your country of residence in accordance with applicable laws. By providing us with your information, you acknowledge any such transfer and the storage or use of your data.

We transfer your Personal Information in circumstances necessary for the performance of a contract; the implementation of pre-contractual measures undertaken on your behalf in connection with our services that we provide you; for important reasons of public interest; for the establishment, exercise, or defense of legal claims; and to protect your vital interests or of other persons where you are physically or legally incapable of giving consent.

11. Security Measures

We have implemented technical, physical, and organizational security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. But we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

12. Children

The Services are intended for users over the age of 18 and are not directed at children as contemplated under the NDPA. If we become aware that we have collected personal information from children or personal data (as defined by the NDPA), we will take reasonable steps to delete it as soon as practicable.

13. Data Retention

We retain the information we collect for as long as necessary to fulfill the purposes set forth in this Privacy Notice or as long as we are legally required or permitted to do so subject to the relevant requirements under the applicable law or regulations. Information may persist in copies made for backup and business continuity purposes for additional time.

14. Third-Party Links and Services

The Services may contain links to third-party websites (e.g., social media sites like LinkedIn and Facebook), third-party plug-ins (e.g., the YouTube “like” button and Twitter “follow” button), and other services. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or privacy practices of such third-party websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Notice. We encourage you to read the privacy statements of each and every site you visit.

15. Cookies

Like many other websites, we use cookies to distinguish you from other users and to customize and improve our services.

Some browsers may automatically accept cookies while some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable cookies, it may limit your ability to use our website.

16. Updates to our Privacy Notice

We may change, amend, or review this Privacy Notice from time to time to reflect new services or changes in our Privacy Notice and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Notice.

Contact Us

Our Data Protection Officer (DPO), responsible for overseeing data protection and privacy compliance shall ensure that all communications with us will be treated accordingly, based on our Privacy Notice as well as the applicable data protection laws and regulations. Should we require additional details, we may contact you. All access requests, questions, comments, complaints, and other requests regarding our privacy practices should be sent to: reachus@judeayua.com.