At SENRI LIMITED (“SENRI”, “we”, “our”, or “us”), your privacy and the security of your personal data are of utmost importance to us. We are committed to handling your personal data responsibly and in accordance with the Nigeria Data Protection Act 2023 (“NDPA 2023”) and other data protection regulations. This Privacy Notice explains how we collect, use, disclose, and protect your personal data, as well as your rights under the law. It applies to our products, services, websites, applications and developer tools (collectively, our “Services”).
This Privacy Notice does not apply to Services not owned or controlled by SENRI, including third-party websites you might interact with on or through the Services.
By accessing our website or using any of our other Services, you acknowledge and consent to the practices described in this Privacy Notice.
1.INTRODUCTION
This Privacy Notice informs you about:
- The types of personal data we collect and process;
- The legal basis for processing your data;
- How we use and protect your data;
- Your rights as a data subject;
- How to contact our Data Protection Officer (DPO) for concerns regarding privacy rights;
- The procedure for escalating unresolved complaints to the Nigeria Data Protection Commission (NDPC).
If you do not agree with any part of this Privacy Notice, kindly discontinue the use of our website and other Services.
Please be aware that using our Services may come with additional terms and conditions. It is important to read this entire Privacy Notice thoroughly. Additionally, make sure to review any other agreements that pertain to the Services you intend to use, and ensure that you understand and agree to those terms before accessing the Services.
2. DATA WE COLLECT
The personal data we collect varies based on how you interact with us, the Services you use, and the choices you make. We may gather information from different sources and in several ways, including data you provide directly, information collected automatically, third-party data sources, and data we infer or generate from existing information.
2.1. Personal Data You Provide.
- Contact Information: Name, email address, phone number, date of birth, government issued ID, residential address, media files, contact list, etc to provide you with certain Services.
- Communications: This includes any information you provide when signing up for email alerts, using our developer tools, completing surveys, or interacting with customer support. It also encompasses call logs, such as calls made to clients from mobile devices with the SENRI Application installed.
- Financial details: Financial details you provide in the course of using our Services (e.g, entitlements or purchase history)
2.2. Data We Collect Automatically
- Device Information: (e.g., device and software used, IP address, web browser type, operating system version, and device identifiers.)
- Website usage statistics: (e.g., pages visited, time spent on our site)
- Location Information: General location of your device (e.g. your IP address may indicate your general geographic region, which will be matched against our IP whitelist.
- Cookies and tracking technologies (where consented)
2.3. Data We Collect Receive from Others
- Third Parties: We may retrieve additional personal data about you from third parties. E.g., some other developers allow you to use your SENRI account to log in to their service. We may combine that data with other information we have about you.
- Publicly available sources: We may also gather additional data about you from public sources of information, such as open government databases.
- Inferences: We may infer additional Personal Data based on the Personal Data described above. e.g., we may infer your interests as a website visitor based on the web pages you view.
3. HOW WE USE PERSONAL INFORMATION
We use the Personal Data we collect to:
- Provide you with the required Services,
- Respond to your questions or requests
- Developing, delivering, and improving our Services and other offerings, some of which may be offered in partnership with other parties;
- Personalizing your experience, including by presenting content or features better tailored to you or your interests, or our inferences about your interests
- Promoting our Services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events;
- Managing alpha, beta, or early access tests (and collecting feedback);
- Conducting data analytics (like analysing how our Services are used so we can better understand, improve, and personalize them);
- Complying with our legal or contractual obligations and enforcing our terms; and
- Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools
- Any other purpose that we disclose to you in the course of providing our Services to you
4. APPLICABLE LEGAL BASES FOR PROCESSING DATA
We process personal data under the following lawful bases:
4.1. Contractual Necessity
- Where processing is necessary for fulfilling a contract you are part of, or to take steps at your request before entering into a contract.
4.2. Consent
- Where you have consented to the processing of your Personal Information for specific purposes. You can revoke this consent by closing your SENRI account (if applicable) or by emailing us.
4.3. Legitimate Interests
- Processing is necessary for the legitimate interests pursued by SENRI or a third party, unless those interests are overridden by your own interests or fundamental rights and freedoms that require the protection of personal data.
4.4. Legal Obligations
- To comply with applicable regulatory requirements and reporting obligations
5. DATA SHARING AND DISCLOSURE
We do not sell or trade your personal data. However, we may disclose your data in the following circumstances:
- With partners: To facilitate the Services you access but only with your explicit consent and with the option to opt out.
- With other developers: To enable features for the software and application you use
- With service providers: Who assist in delivering our Services (under strict data processing and confidentiality agreements)
- With other users: If similar contacts have been saved on the SENRI Application
- With regulatory authorities: Where legally required;
- Publicly: As regards photos taken of products and locations for marketing purposes to others (With your express consent)
- In legal proceedings to protect our rights and interests.
- With other SENRI entities: To help provide support for the Services internationally
- With your permission: e.g., if you link external accounts with your SENRI account, or use your SENRI account to sign in to third-party websites and Services or participate in cross-promotional events
- With your permission: e.g., if you link external accounts with your SENRI account, or use your SENRI account to sign in to third-party websites and Services or participate in cross-promotional events
We may also process information that does not identify you individually, such as aggregated or de-identified data that we create or gather from other sources. This type of information helps us better understand broader groups of users. If we combine this non-identifiable information with data that does identify you, we will handle it according to the terms outlined in this Privacy Notice. However, please note that this Privacy Notice does not limit our ability to process information that does not identify you individually. We may use and disclose aggregated or de-identified information for any reason permitted by law.
6. DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected unless a long retention period is required or permitted by law.
Typically
- Contact information is retained for marketing and communication purposes until you opt out.
7. FRAUD PREVENTION & ANTI-CHEAT
Ensuring that users have a fair, balanced, and competitive experience while using our Services is extremely important to us. We strictly enforce rules against cheating, hacking, and any other unauthorized or fraudulent activities within our Services. To help identify and prevent malicious activity, we utilize a variety of anti-cheat and fraud prevention technologies. Please be aware that our Services may collect and analyze data about your application and the software it contains to detect cheating.
8. SECURITY MEASURES
We implement robust security measures to protect your data, including:
- Encryption of sensitive data
- Secure data storage and restricted access
- Regular security audits and compliance checks
However, no system is completely secure, and we encourage you to take precautions, such as safeguarding login credentials.
9. CHILDREN’S PRIVACY
Our Services are intended to be used by adults and are not directed to children (usually considered to be under 18,). SENRI does not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations.
10. TRANSFER OF DATA
SENRI is based in the Japan, but we operate globally to help provide users all around the world with a better experience on Services offered by us. We have subsidiaries, offices, service providers, and partners worldwide to support our operations in a number of different ways. This means that SENRI may process the information we collect in connection with your use of our Services in places outside the region where you reside.
When you use our Services, your information may be transferred to or stored in Germany or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. If permissible under local law, you’re authorizing SENRI to process your information in any of the locations where we operate (including the Federal Republic of Germany) by using our Services.
To learn more about the SENRI entity responsible for operating the Services you use, kindly reach us via the “Contact Us” tab below.
11. YOUR RIGHTS UNDER THE NIGERIA DATA PROTECTION ACT 2023
As a data subject, you have the following rights:
- Right to Access: Request details of personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to be Informed: Right to be informed regarding the use of your Personal Information.
- Right to Erasure (Right to be Forgotten): Request deletion of your personal data under certain conditions.
- Right to Restriction of Processing: Limit the way we process your data.
- Right to Data Portability: Request transfer of your data to another organization.
- Right to Object: Object to data processing based on legitimate interests.
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
- Right to be informed about appropriate safeguards in place whenever your personal information is transferred abroad;
- Right to submit a complaint to the Nigeria Data Protection Commission (NDPC).
You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies and GPS. In some cases, blocking or disabling cookies and GPS may cause our Services not to work as intended and some features may not be available.
If you’re under the age of 18 and your details have been captured by us, you can ask that we remove or anonymise such content. Please direct requests to help delete or edit content on the Services to our Data Protection Officer (DPO) via the “Contact Us” tab below.
You can exercise your rights without any cost. However, by law, we are allowed to refuse your request or charge a reasonable fee if your request is excessive, clearly unreasonable, or would impose an undue burden on us. If we decide to charge a fee, we will notify you before processing your request.
If you wish to exercise any of your rights set out above, please contact our DPO via the “Contact Us” tab below.
12. HOW TO REPORT PRIVACY CONCERNS
If you believe your data privacy rights have been violated or have any concerns about how we handle your data, you may contact our DPO via the “Contact Us” tab below.
If you are not satisfied with our response, you have the right to escalate the matter to the Nigeria Data Protection Commission (NDPC)
13. COOKIES AND TRACKING TECHNOLOGIES
Most web browsers are configured to accept cookies by default. If you prefer, you can typically adjust your browser settings to remove or block cookies. Keep in mind that doing so may impact the availability and functionality of our Services. For more detailed information about the cookies we use and how we utilize them, please refer to our Cookie Notice.
14. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice periodically. The latest version will always be available on our website. Continued use of our website or Services after changes means you accept the revised Privacy Notice.
For any further inquiries regarding this Privacy Notice, please contact us at privacy@senriltd.com.