2. Who We Are
Our corporate website address: www.21search.ng
3. What We May Collect
We will collect and process the following data about you:
3.1 Information and content you provide. We collect the content, communication, and other information you
provide when you use our services, including when you fill forms or surveys or sign up for an account, or by
corresponding with us via phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address, phone number, personal description and photograph.
3.2 Information we collect about you. With regard to each of your visits to our website or the use of our
products, we will automatically collect the following information:
3.2.1 technical information, including the Internet Protocol (IP) address used to connect your computer
to the internet, your login information, browser type, time zone setting, browser plug-in types and versions, operating system and platform;
3.2.2 information about your use of our website and mobile application (including date and time), details
of transactions you carry out, interaction information, record of any correspondence between us and any
phone number used to call our customer/client service number;
3.2.3 information about your visit(s) from your IP address, including the full Uniform Resource Locators
(URL) clickstream to, through and from our website (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
3.3 Information we receive from other sources. This is information we receive about you if you use any of the
other websites we operate or the other services we provide. In this case we will inform you at the point of data collection, if we intend to share your data internally and combine it with data collected on www.21search.ng. We will also tell you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
4. How We Use Your Personal Information
4.1 User data collected helps us to personalize our products according to each user’s wish and preference.
4.2 We use information held about you in the following ways, that is, to:
4.2.1 tailor the content we display to you;
4.2.2 carry out our obligations arising from any contracts entered into between you and us and to provide
you with the information, products and services that you request from us;
4.2.3 provide you with information about other goods and services we provide that are similar to those
that you have already purchased or enquired about;
4.2.4 notify you about changes to our service;
4.2.5 ensure that content from our product is presented in the most effective manner for you and for
4.2.6 administer our product and for internal operations, including troubleshooting, data analysis,
testing,research,statistical and survey purposes;
4.2.7 improve our product to ensure that content is presented in the most effective manner for you and
for your device;
4.2.8 allow you to participate in interactive features of our service, when you choose to do so;
4.2.9 measure or understand the effectiveness of advertising we serve to you and others, and to deliver
relevant advertising to you;
4.2.10 make suggestions and recommendations to you and other users of our product about goods or
services that may interest you or them.
4.3 We will use information provided by you to provide you, or permit selected third parties to provide you,
with information about goods or services we feel may interest you. If you are an existing customer/client, we
will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those, which were the subject of a previous sale or negotiation of a sale to you. If you are a new customer/client, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you may unsubscribe from promotional emails via a link provided in each email.
We adopt robust technologies and policies to ensure the personal information we hold about you is suitably
protected. We take steps to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
6. Disclosure of your Information
6.1 We will usually not share your personal information with other third parties without your consent. You
agree that we have the right to share your personal information with:
6.1.1 any member of our group, which means our subsidiaries, our ultimate holding company and its
subsidiaries, as defined under the Nigerian Companies and Allied Matters Act Cap C20 LFN 2004;
6.1.2 our authorized employees only for the purpose of resolving issues associated with the use of our
6.1.3 selected third parties including:
220.127.116.11 business partners, suppliers or sub-contractors for the performance of any contract we enter
into with them;
18.104.22.168 advertisers and advertising networks that require the data to select and serve relevant
adverts to you and others. Please note that:
- we do not disclose information about identifiable individuals to our
advertisers, but we will provide them with aggregate information about our users, for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day;
- we may also use such aggregate information to help advertisers reach the kind of audience they want to target;
22.214.171.124 analytics and search engine providers that assist us in the improvement and optimisation of
our corporate and products websites.
6.2 We may share your data without your consent in any of the following situations:
6.2.1 if we are under a duty to disclose or share your personal data in order to comply with any legal
6.2.2 where we are requested to provide information by authorized third parties or
regulatory/governmental agencies investigating illegal activities;
6.2.3 in the event that we sell or buy any business or assets, in which case we will disclose your
personal data to the prospective seller or buyer of such business or assets;
6.2.4 if we or substantially all of our assets are acquired by a third party, in which case personal data
we hold about our clients will be one of the transferred assets;
6.2.5 we may hold events including seminars and conferences which are sponsored by third parties or have
third party speakers. Where you register for one of these events, we may share your details with those third parties;
6.2.6 we use third party payment processing services when you make payment through our website. We do
not have access to any credit card or financial information processed by the third party.
7. Where we Store your Data
7.1 The data that we collect from you will be transferred to, and stored at, a destination outside Nigeria. By
submitting your personal data, you agree to this transfer, storing or processing. We will take all steps
reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
7.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using secure sockets layer (SSL) technology. Where we have given you (or where you have chosen) a password, which enables you to access the services on our website and mobile applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8. Retention of Information
8.1 Your personal information will not be retained for longer than is necessary for the purposes for which it was processed.
8.2 Your information will be stored as long as you have an active client account. If your account is closed,
information will be deleted after 3 years from the databases, unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes.
8.3 Please note that the deletion of any of our apps from your device does not cause the deletion of your
8.4 If any of our apps has not been used for 2 years, we will notify you and ask you to confirm whether your
account is still active. If no reply is received, the account will be closed and your information will be deleted unless such information is required to be stored for accounting, dispute resolution or fraud prevention purposes.
9. Your Rights
9.1 The law gives you certain rights in respect of the information we hold about you. Below is a highlight of
some of those rights. It is not a complete, exhaustive statement of your rights in respect of your personal data.
9.1.2 You have a right to a copy of the personal data we hold about you, as well as the information about
what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.
9.1.3 You have a right to freely transfer your data received from us to any other person.
9.1.4 You have the right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose.
9.1.5 In some circumstances, you have the right to the deletion of the information that we hold about you.
9.1.6 You have a right to lodge a complaint about the handling of your personal information with the
National Information Technology Development Agency (NITDA).
9.1.7 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you(before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
9.2 NITDA’s website has a wealth of useful information in respect of your rights over your personal data.
9.3 If you wish to exercise your rights, you may contact the office of our data protection and compliance
officer at firstname.lastname@example.org, or you may write to us at email@example.com or firstname.lastname@example.org.
10. Changes to this Policy
Any future changes we make to this Policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.
Please note that our products may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to such websites.
Okoya-Thomas Street, Victoria Island,