Privacy/Cookie Policy

Privacy/Cookie Policy

Privacy/Cookie Policy

 This is the privacy policy of Digital Jewels Africa Limited. In this document, “we”, “our”, or “us” refer to Digital Jewels Africa Limited.

We are a company registered in Nigeria, Ghana, Rwanda, and Kenya,

Introduction

This privacy notice aims to inform you about how we collect and process any information that we collect from you and covers information that could identify you as an individual (i.e., “personal identifiable information”).

In the context of the Nigeria Data Protection Regulation (NDPR), Ghana Data Protection Act (GDPA), Kenya Data Protection Act (KDPA), Rwanda Data Protection Regulation (RDPR), and this notice; “Process” refers to how we collect, store, transfer, use, or otherwise, act on your information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and preserving the confidentiality of your personal information that you provide to us.

The data protection laws in scope (NDPR, GDPA, KDPA, and RDPR) require us to inform you about your rights and our obligations to you concerning the processing and use of your personal data.

Except as set out below, we do not share or sell, or disclose any information collected through our website to any third party.

1. Data Protection Officer

Digital Jewels Africa Limited has appointed a Data Protection Officer (DPO) who is responsible for ensuring that this policy (our company-wide privacy standard) is followed adequately.

To pursue issues related to your personal data, and concerns or questions about this privacy notice, including any requests to exercise your legal rights to privacy, please contact our DPO, at dpo@digitaljewels.net

2. Data We Process

We may collect and process different kinds of personal data about you, which we have collated into the following groups:

• Your identity: includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.

• Your contact information: includes information such as email address, phone numbers, and any other information you have given to us for communications or meetings.

• Technical data: includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Marketing data: includes your preferences in receiving marketing from us; communication preferences; responses and actions about your use of our services.

• We may also aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual.

Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.

However, where we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information, and it will be handled in line with this privacy policy.

3. Sensitive Personal information

Sensitive personal information refers to data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetics, and biometric data. It also includes information about criminal convictions and offences.

Digital Jewels Africa does not collect any sensitive personal information about you.

4. If you do not provide personal information we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at that time.

5. The Basis on Which We Process Information About You

The law requires us to determine under which legal grounds we process different categories of your personal information and to notify you of the basis for each category. If the basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

• Information we process because we have a contractual obligation with you

When you agree to our terms and conditions, a contract is formed between you and us. To carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it to provide you with our services or provide you with suggestions and advice on services. We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

• Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our services, you provide your consent to us to process your personal information (Name, Email address & Telephone Number). Wherever possible, we will obtain your explicit consent to process this information.

If you have not given us your explicit permission, we will NOT pass your name and contact information to selected associates.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at info@digitaljewels.net, or dpo@digitaljewels.net.

• Information we process because we have a legal obligation

Sometimes, we must process your information to comply with a statutory obligation. This may include your personal information.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation, such as a search warrant or court order.

Information we process to protect your vital interest or that of another data subject

Sometimes, we may process your information to protect an interest that is essential for your life or that of another natural person. For example, in emergency medical care, when we need to process your personal data for medical purposes but you are incapable of giving consent to the processing.

• Information we process in the public interest or exercise of official public mandate vested in us

Sometimes we must process your information for the performance of a task carried out in the interest of the public or in exercising an official authority vested in us, such as when we are carrying out a specific task that is laid down by law.

6. Specific Uses of Information You Provide to Us

We will process (collect, use, and store) the information you provide in a manner that complies with the Nigeria Data Protection Regulation (NDPR), Ghana Data Protection Act (GDPA), Kenya Data Protection Act (KDPA), Rwanda Data Protection Regulation (RDPR), and global best practices. We will endeavour to keep your information accurate and up to date, and not for longer than is necessary. Digital Jewels Africa is required to retain information in line with the relevant law and our retention policy.

• Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

• Communicating with us

When you contact us, whether by telephone, through our website, or by e-mail, we collect the data you have given to us to reply with the information you need. We also record your request and our reply to increase the efficiency of Digital Jewels Africa’s Operations.

We keep personal identifiable information associated with your message, such as your name and email address to be able to track our communications with you to provide a highquality service.

• Complaints

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.

If your complaint requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter of our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

• Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate or a business partner or collected by us on your behalf towards providing a service for you.

The information is not used for any other purpose other than the purpose for which you have requested us to collect it, as expressly stated in the contractual agreement.

We undertake to preserve the confidentiality of the information and the terms of our relationship, and we expect any affiliate or partner to agree to reciprocate this policy.

7. Use of Information We Collect Through Automated Systems When You Visit Our Website

Use of Cookies

Cookies are a kind of short-term memory for the web. They are stored in your browser and enable a site to ‘remember’ little bits of information between pages or visits. Cookies are used by web servers to identify and track your activities as you navigate the different pages of our website, and to identify you whenever you return website, allowing the website to provide you with a personalised browsing experience and Digital Jewels with statistics about how you use the website so that it can be improved.

Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies on Our Website

We use both SESSION COOKIES (which expire once you close your web browser) and PERSISTENT COOKIES (which stay on your device until you delete them).

We have also grouped our cookies into the following categories, to make it easier for you to understand why we need them:

1. a) Functionality: These cookies enable the technical performance of our websites and allow us to ‘remember’ the choices you make and your preferences

1. b) Performance: These cookies allow us to collect certain information about how you navigate the sites. They help us to understand which parts of our websites are interesting to you and which are not as well as what we can do to improve them.

These cookies are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will still be able to use all the functionality of our website.

How We Use Cookies

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies. The cookies used on this website include those which are strictly necessary cookies for access and navigation, cookies that track usage (performance cookies) and remember your choices (functionality cookies). We may use the information we obtain from your use of our cookies for the following purposes:

• to recognise your computer when you visit our website
• to keep you signed in on our site
• to track how you use our website as you navigate our website
• in the administration of our website to improve the website’s usability
• to record whether you have seen specific messages we display on our website
• to record your answers to queries and questionnaires on our site while you complete Them

Third-Party Cookies

In some special cases, we also use cookies provided by trusted third parties to help us understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

We also use social media buttons and YouTube plugins on this site, which will set cookies through our site that may be used to enhance your profile on their platforms or contribute to the data they hold for various purposes outlined in their respective privacy policies.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies may affect the functionality of this and many other websites that you visit. Disabling cookies may also result in also disabling certain functionality of this site. Therefore, it is recommended that you do not disable cookies.

8. Disclosure and Sharing of Your Information

Information we obtain from third parties

Although we do not disclose your personal information to any third party (as set out in this notice), we sometimes receive data that is indirectly made up of your personal information from third parties whose services we use. However, no such information is personally identifiable to you.

Data May be Processed Outside Nigeria, Kenya, Ghana, and Rwanda

Our websites are hosted in the United States of America, and we may also use outsourced services in countries outside Nigeria, Ghana, Rwanda, and Kenya from time to time in other aspects of our business.

Accordingly, the appropriate legal ground will be established prior to the data being processed outside Nigeria, Kenya, Ghana, and Rwanda.

9. Your Rights

Right of Access

You have a right to request a copy of the information of yours that we hold. You have the right to request the following information:

• The purpose of the processing, as well as the legal basis for processing
• Information about interests if the processing is based on our legitimate interests
• The categories of personal data collected, stored, and processed
• How long the data will be stored
• Details about your rights to correct, erase, restrict, or object to certain processing
• Information about your right to withdraw consent at any time
• How to lodge a complaint with the supervisory authority
• The source of personal data if you did not provide it directly

In addition to your right to access, you also have the right to correct data that is inaccurate or incomplete, the right to request that we limit the way we use your personal data, the right to challenge certain types of processing, such as email marketing, and in certain situations, the right to ask us to erase any personal data of yours that we have stored, such as unsubscribing from our newsletters.

You are free to exercise your rights through any of the established channels of communication with us.

Verification of Your Information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

10. Other Matters

Encryption of Data Sent Between Us

We use Secure Sockets Layer (SSL) certificates to verify our identity on your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or any other trust mark on the URL bar or toolbar of your browser.

How You Can Complain and Report a Data Breach

If you are not happy with our privacy policy or you have concerns and complaints, please reach out to us via dpo@digitaljewels.net

If you perceive that there has been a violation of this policy and a breach of your personal data in our custody and feel the need to escalate your concerns to the appropriate supervisory authority, you can file a report with:

– the Nigeria Data Protection Bureau (NDPB) via info@ndpb.gov.ng

– Office of the Data Protection Commissioner (Kenya) via info@odpc.go.ke,

– Ghana Data Protection Commission via info@dataprotection.org.gh,

– Rwanda’s Data Protection Office via dpp@ncsa.gov.rw

Where a violation of this policy/or a personal data breach has occurred, we will make a formal report to the appropriate supervisory authority within 72 hours of being aware of the violation/breach as well as formally notify all parties as detailed in our Data Breach notification procedure.

If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

11. Retention Period for Personal Data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested
• to comply with other laws, including for the period demanded by our tax authorities
• to support a claim or defence in court

12. Compliance with the Law

Our privacy policy has been compiled to comply with the Nigerian Data Protection Regulation (NDPR), Ghana Data Protect Act 2012 (GDPA), Kenya Data Protection Act (KDPA), Rwanda Data Protection Regulation (RDPR), as well as the European General Data Protection Regulation (GDPR).

If you think it fails to satisfy the law of your jurisdiction, kindly contact us at dpo@digitaljewels.net

13. Review of this Privacy Policy

We may update this privacy policy from time to time, as necessary. The terms that apply to you are those posted here on our website on the day you use our website.

If you have any questions regarding our privacy policy, please contact us via the DPO at dpo@digitaljewels.net