Privacy Policy

Last modified: September 2, 2019

This policy describes the information we process to support Talk Of Naija, and
other products and features offered by Talk Of Naija (Talk Of Naija Products or
Products). You can find additional tools and information in the Talk Of Naija
Settings and Settings.

 

What kinds of information do we collect?

To provide the Talk Of Naija Products, we must process information about you.
The types of information we collect depend on how you use our Products. You
can learn how to access and delete information we collect by visiting the
Talk Of Naija Settings.

 

Things you and others do and provide.

Information and content you provide. We collect the content, communications
and other information you provide when you use our Products, including when
you sign up for an account, create or share content, and message or
communicate with others. This can include information in or about the
content you provide (like metadata), such as the location of a photo or the
date a file was created. It can also include what you see through features
we provide, such as our camera, so we can do things like suggest masks and
filters that you might like, or give you tips on using camera formats. Our
systems automatically process content and communications you and others
provide to analyze context and what’s in them for the purposes described
below. Learn more about how you can control who can see the things you
share.

Data with special protections: You can choose to provide information in
your Talk Of Naija profile fields or life Events about your religious views,
political views, who you are “interested in,” or your health, and basically
what you feel like. This and other information (such as racial or ethnic
origin, philosophical beliefs or trade union membership) could be subject
to special protections under the laws of your country.

Networks and connections. We collect information about the people, Pages,
accounts, hashtags and groups you are connected to and how you interact
with them across our Products, such as people you communicate with the most
or groups you are part of. We also collect contact information if you
choose to upload, sync or import it from a device (such as an address book
or call log or SMS log history), which we use for things like helping you
and others find people you may know and for the other purposes listed
below.

Your usage. We collect information about how you use our Products, such as
the types of content you view or engage with; the features you use; the
actions you take; the people or accounts you interact with; and the time,
frequency and duration of your activities. For example, we log when you’re
using and have last used our Products, and what posts, videos and other
content you view on our Products. We also collect information about how you
use features like our camera.

Information about transactions made on our Products. If you use our
Products for purchases or other financial transactions, we collect
information about the purchase or transaction. This includes payment
information, such as your credit or debit card number and other card
information; other account and authentication information.

Things others do and information they provide about you. We also receive
and analyze content, communications and information that other people
provide when they use our Products. This can include information about you,
such as when others share or comment on a photo of you, send a message to
you, or upload, sync or import your contact information.

 

Device Information

As described below, we collect information from and about the computers,
phones, connected TVs and other web-connected devices you use that
integrate with our Products, and we combine this information across
different devices you use. For example, we use information collected about
your use of our Products on your phone to better personalize the content
(including ads) or features you see when you use our Products on another
device, such as your laptop or tablet, or to measure whether you took an
action in response to an ad we showed you on your phone on a different
device.

 

Information we obtain from these devices includes:

Device attributes: information such as the operating system, hardware and
software versions, battery level, signal strength, available storage space,
browser type, app and file names and types, and plugins.

Device operations: information about operations and behaviors performed on
the device, such as whether a window is foregrounded or backgrounded, or
mouse movements (which can help distinguish humans from bots).

Identifiers: unique identifiers, device IDs, and other identifiers, such as
from games, apps or accounts you use, and Family Device IDs (or other
identifiers unique to Talk Of Naija Company Products associated with the same
device or account).

Device signals: Bluetooth signals, and information about nearby Wi-Fi
access points, beacons, and cell towers.

Data from device settings: information you allow us to receive through
device settings you turn on, such as access to your GPS location, camera or
photos.

Network and connections: information such as the name of your mobile
operator or ISP, language, time zone, mobile phone number, IP address,
connection speed and, in some cases, information about other devices that
are nearby or on your network, so we can do things like help you stream a
video from your phone to your TV.

Cookie data: data from cookies stored on your device, including cookie IDs
and settings. Learn more about how we use cookies in the Talk Of Naija Cookies
Policy.

 

Information from partners.

Advertisers, app developers, and publishers can send us information through
Talk Of Naija Business Tools they use, including our social plug-ins (such as
the Like button), Talk Of Naija Login, our APIs and SDKs, or the Talk Of Naija
pixel. These partners provide information about your activities off
Talk Of Naija—including information about your device, websites you visit,
purchases you make, the ads you see, and how you use their services—whether
or not you have a Talk Of Naija account or are logged into Talk Of Naija. For
example, a game developer could use our API to tell us what games you play,
or a business could tell us about a purchase you made in its store. We also
receive information about your online and offline actions and purchases
from third-party data providers who have the rights to provide us with your
information.

Partners receive your data when you visit or use their services or through
third parties they work with. We require each of these partners to have
lawful rights to collect, use and share your data before providing any data
to us. Learn more about the types of partners we receive data from.

To learn more about how we use cookies in connection with Talk Of Naija
Business Tools, review the Talk Of Naija Cookies Policy.

 

How do we use this information?

We use the information we have (subject to choices you make) as described
below and to provide and support the Talk Of Naija Products and related
services described in the Talk Of Naija terms.

 

Provide, personalize and improve our Products.

We use the information we have to deliver our Products, including to
personalize features and content (including your News Feed, Stories and
ads) and make suggestions for you (such as groups, threads or events you
may be interested in or topics you may want to follow) on and off our
Products. To create personalized Products that are unique and relevant to
you, we use your connections, preferences, interests and activities based
on the data we collect and learn from you and others (including any data
with special protections you choose to provide); how you use and interact
with our Products; and the people, places, or things you’re connected to
and interested in on and off our Products. Learn more about how we use
information about you to personalize your Talk Of Naija and experience,
including features, content and recommendations in Talk Of Naija Products; you
can also learn more about how we choose the ads that you see.

Information across Talk Of Naija Products and devices: We connect information
about your activities on different Talk Of Naija Products and devices to
provide a more tailored and consistent experience on all Talk Of Naija Products
you use, wherever you use them. For example, we can suggest that you join a
group on Talk Of Naija that includes people you follow on or communicate with
using Messenger. We can also make your experience more seamless, for
example, by automatically filling in your registration information (such as
your phone number) from one Talk Of Naija Product when you sign up for an
account on a different Product.

Location-related information: We use location-related information-such as
your current location, where you live, the places you like to go, and the
businesses and people you’re near-to provide, personalize and improve our
Products, including ads, for you and others. Location-related information
can be based on things like precise device location (if you’ve allowed us
to collect it), IP addresses, and information from your and others’ use of
Talk Of Naija Products (such as check-ins or events you attend).

Product research and development: We use the information we have to
develop, test and improve our Products, including by conducting surveys and
research, and testing and troubleshooting new products and features.

Face recognition: If you have it turned on, we use face recognition
technology to recognize you in photos, videos and camera experiences. The
face-recognition templates we create may constitute data with special
protections under the laws of your country. Learn more about how we use
face recognition technology, or control our use of this technology in
Talk Of Naija Settings. If we introduce face-recognition technology to your
Talk Of Naija experience, we will let you know first, and you will have control
over whether we use this technology for you.

Ads and other sponsored content: We use the information we have about
you-including information about your interests, actions and connections-to
select and personalize ads, offers and other sponsored content that we show
you. Learn more about how we select and personalize ads, and your choices
over the data we use to select ads and other sponsored content for you in
the Talk Of Naija Settings.

 

Provide measurement, analytics, and other business services.

We use the information we have (including your activity off our Products,
such as the websites you visit and ads you see) to help advertisers and
other partners measure the effectiveness and distribution of their ads and
services, and understand the types of people who use their services and how
people interact with their websites, apps, and services. Learn how we share
information with these partners.

 

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat
harmful conduct, detect and prevent spam and other bad experiences,
maintain the integrity of our Products, and promote safety and security on
and off of Talk Of Naija Products. For example, we use data we have to
investigate suspicious activity or violations of our terms or policies, or
to detect when someone needs help. To learn more, visit the Talk Of Naija
website.

 

Communicate with you.

We use the information we have to send you marketing communications,
communicate with you about our Products, and let you know about our
policies and terms. We also use your information to respond to you when you
contact us.

 

Research and innovate for social good.

We use the information we have (including from research partners we
collaborate with) to conduct and support research and innovation on topics
of general social welfare, technological advancement, public interest,
health and well-being. For example, we analyze information we have about
migration patterns during crises to aid relief efforts. Learn more about
our research programs.

 

How is this information shared?

Your information is shared with others in the following ways:



People and accounts you share and communicate with

When you share and communicate using our Products, you choose the audience
for what you share. For example, when you post on Talk Of Naija, you select the
audience for the post, such as a group, all of your friends, the public, or
a customized list of people. Those people and businesses can see the
content you send. Your network can also see actions you have taken on our
Products, including engagement with ads and sponsored content. We also let
other accounts see who has viewed their Talk Of Naija.

Public information can be seen by anyone, on or off our Products, including
if they don’t have an account. This includes your Talk Of Naija username; any
information you share with a public audience; information in your public
profile on Talk Of Naija; and content you share on a Talk Of Naija Page or any
other public forum, such as Talk Of Naija Marketplace. You, other people using
Talk Of Naija, and we can provide access to or send public information to
anyone on or off our Products, including in other Talk Of Naija Company
Products, in search results, or through tools and APIs. Public information
can also be seen, accessed, reshared or downloaded through third-party
services such as search engines, APIs, and offline media such as TV, and by
apps, websites and other services that integrate with our Products.

Learn more about what information is public and how to control your
visibility on Talk Of Naija

Content others share or reshare about you

You should consider who you choose to share with, because people who can
see your activity on our Products can choose to share it with others on and
off our Products, including people and businesses outside the audience you
shared with. For example, when you share a post or send a message to
specific friends or accounts, they can download, screenshot, or reshare
that content to others across or off our Products, in person or in virtual
reality experiences such as Talk Of Naija Spaces. Also, when you comment on
someone else’s post or react to their content, your comment or reaction is
visible to anyone who can see the other person’s content, and that person
can change the audience later.

People can also use our Products to create and share content about you with
the audience they choose. For example, people can share a photo of you in a
Story, mention or tag you at a location in a post, or share information
about you in their posts or messages. If you are uncomfortable with what
others have shared about you on our Products, you can learn how to report
the content.

Information about your active status or presence on our Products.

People in your networks can see signals telling them whether you are active
on our Products, including whether you are currently active on Talk Of Naija,
or when you last used our Products.

Apps, websites, and third-party integrations on or using our Products.

When you choose to use third-party apps, websites, or other services that
use, or are integrated with, our Products, they can receive information
about what you post or share. For example, when you play a game with your
Talk Of Naija friends or use a Talk Of Naija Comment or Share button on a website,
the game developer or website can receive information about your activities
in the game or receive a comment or link that you share from the website on
Talk Of Naija. Also, when you download or use such third-party services, they
can access your public profile on Talk Of Naija, and any information that you
share with them. Apps and websites you use may receive your list of
Talk Of Naija friends if you choose to share it with them. But apps and
websites you use will not be able to receive any other information about
your Talk Of Naija friends from you, or information about any of your followers
(although your friends and followers may, of course, choose to share this
information themselves). Information collected by these third-party
services is subject to their own terms and policies, not this one.

Devices and operating systems providing native versions of Talk Of Naija (i.e.
where we have not developed our own first-party apps) will have access to
all information you choose to share with them, including information your
friends share with you, so they can provide our core functionality to you.

Note: We are in the process of restricting developers’ data access even
further to help prevent abuse. For example, we will remove developers’
access to your Talk Of Naija data if you haven’t used their app in 3 months,
and we are changing Login, so that in the next version, we will reduce the
data that an app can request without app review to include only name,
username and bio, profile photo and email address. Requesting any other
data will require our approval.

New owner.

If the ownership or control of all or part of our Products or their assets
changes, we may transfer your information to the new owner.

Sharing with Third-Party Partners

We work with third-party partners who help us provide and improve our
Products or who use Talk Of Naija Business Tools to grow their businesses,
which makes it possible to operate our companies and provide free services
to people around the world. We don’t sell any of your information to
anyone, and we never will. We also impose strict restrictions on how our
partners can use and disclose the data we provide. Here are the types of
third parties we share information with:

Partners who use our analytics services.

We provide aggregated statistics and insights that help people and
businesses understand how people are engaging with their posts, listings,
Pages, videos and other content on and off the Talk Of Naija Products. For
example, Page/thread admins and business profiles receive information about
the number of people or accounts who viewed, reacted to, or commented on
their posts, as well as aggregate demographic and other information that
helps them understand interactions with their Page or account.

Advertisers.

We provide advertisers with reports about the kinds of people seeing their
ads and how their ads are performing, but we don’t share information that
personally identifies you (information such as your name or email address
that by itself can be used to contact you or identifies who you are) unless
you give us permission. For example, we provide general demographic and
interest information to advertisers (for example, that an ad was seen by a
woman between the ages of 25 and 34 who lives in Madrid and likes software
engineering) to help them better understand their audience. We also confirm
which Talk Of Naija ads led you to make a purchase or take an action with an
advertiser.

Measurement partners.

We share information about you with companies that aggregate it to provide
analytics and measurement reports to our partners.

Partners offering goods and services in our Products.

When you subscribe to receive premium content, or buy something from a
seller in our Products, the content creator or seller can receive your
public information and other information you share with them, as well as
the information needed to complete the transaction, including shipping and
contact details.

Vendors and service providers.

We provide information and content to vendors and service providers who
support our business, such as by providing technical infrastructure
services, analyzing how our Products are used, providing customer service,
facilitating payments or conducting surveys.

Researchers and academics.

We also provide information and content to research partners and academics
to conduct research that advances scholarship and innovation that support
our business or mission, and enhances discovery and innovation on topics of
general social welfare, technological advancement, public interest, health
and well-being.

Law enforcement or legal requests.

We share information with law enforcement or in response to legal requests
in the circumstances outlined below.

Learn more about how you can control the information about you that you or
others share with third-party partners in the Talk Of Naija Settings.

 

How do the Talk Of Naija Companies work together?

Talk Of Naija infrastructure provide an innovative, relevant, consistent and
safe experience across all Talk Of Naija Company Products you may use. We also
process information about you across the Talk Of Naija Companies for these
purposes, as permitted by applicable law and in accordance with their terms
and policies.

 

How can I manage or delete information about me?

We provide you with the ability to access, rectify, port and erase your
data. Learn more in your Talk Of Naija Settings.

We store data until it is no longer necessary to provide our services and
Talk Of Naija Products, or until your account is deleted – whichever comes
first. This is a case-by-case determination that depends on things like the
nature of the data, why it is collected and processed, and relevant legal
or operational retention needs. For example, when you search for something
on Talk Of Naija, you can access and delete that query from within your search
history at any time, but the log of that search is deleted after 6 months.
If you submit a copy of your government-issued ID for account verification
purposes, we delete that copy 30 days after submission. Learn more about
deletion of content you have shared and cookie data obtained through social
plugins.

When you delete your account, we delete things you have posted, such as
your photos and status updates, and you won’t be able to recover that
information later. Information that others have shared about you isn’t part
of your account and won’t be deleted. If you don’t want to delete your
account but want to temporarily stop using the Products, you can deactivate
your account instead. To delete your account at any time, please visit the
Talk Of Naija Settings.

How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law
enforcement or others:

In response to a legal request (like a search warrant, court order or
subpoena) if we have a good faith belief that the law requires us to do so.
This may include responding to legal requests from jurisdictions outside of
the United States when we have a good-faith belief that the response is
required by law in that jurisdiction, affects users in that jurisdiction,
and is consistent with internationally recognized standards.

When we have a good-faith belief it is necessary to: detect, prevent and
address fraud, unauthorized use of the Products, violations of our terms or
policies, or other harmful or illegal activity; to protect ourselves
(including our rights, property or Products), you or others, including as
part of investigations or regulatory inquiries; or to prevent death or
imminent bodily harm. For example, if relevant, we provide information to
and receive information from third-party partners about the reliability of
your account to prevent fraud, abuse and other harmful activity on and off
our Products.

Information we receive about you (including financial transaction data
related to purchases made with Talk Of Naija) can be accessed and preserved for
an extended period when it is the subject of a legal request or obligation,
governmental investigation, or investigations of possible violations of our
terms or policies, or otherwise to prevent harm. We also retain information
from accounts disabled for terms violations for at least a year to prevent
repeat abuse or other term violations.

 

How do we operate and transfer data as part of our global services?

We share information globally, both internally within the Talk Of Naija
Companies, and externally with our partners and with those you connect and
share with around the world in accordance with this policy. Your
information may, for example, be transferred or transmitted to, or stored
and processed in Nigeria or other countries outside of where you live for
the purposes as described in this policy. These data transfers are
necessary to provide the services set forth in the Talk Of Naija Terms and to
globally operate and provide our Products to you. We utilize standard
contract clauses, rely on the European, American, African Commission’s
adequacy decisions about certain countries, as applicable, and obtain your
consent for these data transfers to Nigeria and other countries.

How will we notify you of changes to this policy?

We’ll notify you before we make changes to this policy and give you the
opportunity to review the revised policy before you choose to continue
using our Products.

How to contact Talk Of Naija with questions

You can learn more about how privacy works on Talk Of Naija. If you have
questions about this policy, you can contact us from the Talk Of Naija website.