Dufuna Technologies Limited Privacy Policy

Last revised on: 21st, June 2020

1.Scope of this policy

This privacy policy (the “Policy” or the "Privacy Policy”) describes how Dufuna Technologies Limited collects, uses, consults or otherwise processes an individual's Personal Data. For the purposes of this policy, "Dufuna" refers to Dufuna Technologies Limited, a limited liability company incorporated under the laws of the Federal Republic of Nigeria, having its registered office at The Third Floor, 109 Awolowo Road, Ikoyi, Lagos, Nigeria info@dufuna.org. Unless otherwise stated, Dufuna will process your personal data as a Data Controller.

We are committed to protecting the privacy of our users and customers. This Privacy Policy is especially directed at:

  • visitors and subscribers of the Dufuna Mobile Application (‘App’);
  • natural persons contacting us through the contact or other forms available on the website;
  • users signing in to use our services;

This Privacy Policy is intended to inform you how we gather, define, and use information that could identify you, such as your name, email address, photograph address, other contact details, online identifiers or other information that you provide to us when using our websites or when relying on our services. Please take a moment to read this Privacy Policy carefully. This policy also includes a description of your data protection rights, including a right to object to some of the processing activities we carry out.

2.Contacting us

If you have general questions about your account please send us an email at info@dufuna.org . Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

3.Collection of Information

The purpose of this App is to train individuals in information and communications technology (ICT) and workplace productivity skills. As part of our effort to provide these trainings, we receive and store information about you such as:

a)Personal Information

Certain features and services may require registration. Users may register (“sign-up”) on-app or via a third party (for example “via Google”). Upon signing-up, an account is created for the user (“Account”). Users who sign-up on-app are required to confirm their registration by clicking on an activation link which is sent to them via email. Users who sign-up through a third party are automatically activated. Users are required to provide part or all of the following information below, depending on the features or services they wish to access (some of which may be automatically retrieved directly from the third party):

  • First and last name
  • Date of Birth
  • Job title, industry, and level
  • Phone Number
  • Photograph (including camera permission)
  • Social Media Permission

Once you complete activation, and you will be able to create your profile (“Profile”). You may be required to provide us with additional information and consent to our terms.

Photograph Capturing During Tests

This App requires access to the front-facing camera on your device and once you grant this App access to your Camera, it will be possible to capture and store photographs via the camera on your device. Picture-taking by the App is automatic and will only be restricted to periods when the User is taking a test on the App. The purpose of this feature is to verify and ascertain that the User registered to that Profile is the one taking the test. Pictures taken by the App during the tests are securely stored and are only accessed by authorized staff and administrators in the event of the need to verify the identity of the test taker. Pictures taken shall not be used for any purpose other than stated in this policy. You are advised to be dressed appropriately and be positioned properly during all tests as pictures will be taken intermittently and without warning. If you believe that an inappropriate picture has been taken of you, you may request erasure from us by sending an email to info@dufuna.org. Although we do not offer an guarantee, Dufuna will do its best to pair you up with a staff or administrator of the same sex to work with you on the erasure request.

b)Other Information

You may have the opportunity to interact with other Users on the App; either directly or in a Forum. We cannot and do not guarantee the veracity of information communicated by other Users, neither do we guarantee that the information contributed by you would not be viewed by persons not on the App.

Non-personal information

We automatically track and collect certain non-personal information such as App navigation data, Internet Protocol (“IP”) addresses, timestamps and URLs. We use this information to do internal research on our users’ demographics, interest, and behavior to better understand, protect and serve you and our Dufuna community.

Correspondence information

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on our Website, we may store such information on our servers.

Payment Information

All payments are processed by our third party payment processor and as such, are largely governed by their terms of service and policies. We allow our third party payment processors to collect information for the purpose of collecting fees from users on the Website. We do not have access to the payment information that you provide to our third party payment vendor. For more information regarding what payment information our third party payment vendor collects and how it uses this information, please see their privacy policy.
To protect you against fraud, unauthorized transactions (such as money laundering), claims and other liabilities, we only collect an identification number and order details which enable us to match each user to the payments he makes. We do not collect credit card information.

4.Use of Information
We use your information to provide, analyse, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments and to communicate with you on these and other topics. For example, we use information to :

  • We use your Information in order to resolve disputes; troubleshoot problems; help promote safe matching; collect fees owed; measure user interest in Services; inform you about offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms of service; and as otherwise described to you at the time of collection.
  • We use your e-mail to send you system e-mails about the functionality of our platform that you cannot opt out from and you will have to receive if you want to use our App. If you want to stop receiving our system e-mails, you will have to de-activate your Account by contacting info@dufuna.org
  • We may use the e-mail associated with your Account to send you newsletters and promotions in conjunction with your use of our Services. If you do not wish to receive newsletters you may unsubscribe by clicking the unsubscription link in the newsletter e-mail. We may also send you newsletters which include third party’s offers. If you do not wish to receive these third party offers, you may unsubscribe by clicking the unsubscription link in the newsletter e-mail.
  • We use navigation data to operate and improve the App. We may also use navigation data alone or in combination with your other Information to provide aggregated information about the Dufuna experience.
  • We collect the IP Addresses to track when you use our App. We use IP Addresses to monitor the regions from which you navigate our App and sign-up to use our Services. Your IP-address is also registered for statistical purposes and to better our advertising.
  • We do not share your full name, photograph captured, e-mail, phone number and job title with third parties for their marketing purposes as a matter of course. However, if we decide to share such information, you shall be notified and shall have the option to opt-out from providing us with your personal information above for this purpose.

Third Parties

  • We partner with third-parties to either display advertising, process payment or do any such thing as we may deem necessary on our App. Generally, these third-parties do not have access to any information collected by us. They may, however, anonymously track your internet usage by various means, for example, through the use of cookies.
  • We make reasonable efforts to make sure that other users who use our Services, will use the information available to them solely for learning purposes. However, we cannot control their use of that information outside this scope and we are not responsible for such unauthorized uses.
  • Dufuna reserves its right to share your Information with a third party in case of sale merger, control changes, reorganization or liquidation of the Company. All actions will naturally be completed in compliance with applicable laws of personal data and privacy.

Our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information to perform a contract with you (for example to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example our direct marketing activities in accordance with your preferences), or where we have your consent to do so (for example, for you to participate in specific surveys and focus groups).

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example to prevent payment fraud or confirm your identity).

For questions about our use of your personal information not adequately addressed here, please contact us at info@dufuna.org

5.Protection of Information

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorised access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Indicatively :

  • All our employees, independent contractors and agents have executed non-disclosure agreements, which provide explicit confidentiality protections. Any employee, independent contractor or agent who violates such privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution.
  • We do not make any of your information available to third parties for their marketing purposes. Dufuna’s software runs on individual servers and no data given or collected is shared with other social media platforms. If however, we share your Information with third parties, we will notify you. Please note that no transmission over the internet can guarantee confidentiality and non-disclosure, and as such, you transmit at your own risk.
  • We use robust security measures to protect data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of data. When the Services are accessed using the internet, Secure Socket Layer (SSL) technology protects your Information, using both server authentication and data encryption. These technologies help ensure that your Information is safe, secure, and only available to you and to whom you have granted access.
  • We do not tolerate spam. To report Dufuna-related spam, please contact us at info@dufuna.org. You may not use our communication tools to send spam or otherwise send content that would violate our terms of service. We may check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content of the Website, but we will not permanently store messages sent through these tools.
  • Dufuna does its utmost to secure communications and data storage in order to protect confidentiality of your information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your Information. You are responsible for maintaining the security and confidentiality of your Account’s username and password.

6.Storage of Information

We save your Information in our database in order to improve our platform and user experience. If you wish that your Information be permanently deleted from our database when you stop using our Services, please notify us at info@dufuna.org.

7.Information and Rights

Once you have provided your Personal Data, you have several rights, which you exercise subject to statutory exceptions. Some of them are:

  • Right to access and rectify your data

    You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging into your account on our platform or by contacting us at info@dufuna.org

  • Right to erasure

    You have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please send us a request at info@dufuna.org

  • Right to restriction of processing

    Under certain circumstances, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.Should you wish to have your Personal Data restricted, please send us a request at info@dufuna.org

8.Other Platforms

This App may contain links to other platforms operated by third parties whose privacy policies and terms of service may differ from ours. We recommend that you read those documents carefully.

9.Changes to this Privacy Policy

We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention if they are major or fundamental changes and impact your data protection rights.

10.Data Retention

We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law.

11.Applicable Law

The validity and interpretation of this Privacy Policy shall be governed by the laws of the Federation of Nigeria.