Last updated: December 12, 2021
Please note that this Policy applies to all CD CARE LIMITED customers subscribing to the use of its digital products either via the CDCare mobile app, cdcare-ng.com or cdcare.ng websites including customers that subscribes to its feature devices, computer applications, websites and other digital products or services that display or refer to this Policy.
This Policy describes how CD CARE LIMITED handles your personal and private data and affirms its commitment to protecting your privacy. This Policy does not address all possible data-processing scenarios and information about product or service-specific data collection, and policies on some other data-processing scenarios and information about the product or service-specific data collection done by CD CARE LIMITED may be issued by CD CARE LIMITED in supplementary policies. It is recommended that you read both this Policy and any supplements to fully understand CD CARE LIMITED privacy policies for a specific product or service.
What is personal data?
Personal data is information that can be used on its own or in combination with other information to identify an individual. Such data is collected when you use CD CARE LIMITED products or services and can include your name, date of birth, address, identity number, telephone number, account number, photo and the location and date when products or services were accessed. CD CARE LIMITED collects and uses your personal data solely for the purposes indicated in this Policy. The following are examples of personal data we may collect and how we use it:
Personal data collected by CD CARE LIMITED
We may collect some personal data, including your name, phone number, email address, age and location. Below are some examples of the types of personal data we may collect.
Data you submit directly: A number of CD CARE LIMITED services will require you to register account(s). You may be requested to provide account information, such as your email address, phone number, product information, time of purchase delivery address, and so on. All such information is secured.
Service-used data: We may collect system and application data from your devices, including the device name, system and application versions, regional and language settings, device version, device identification number (IMEI, ESN, MEID and SN), geographic location (such as the ID of the area where your device is located), service provider network ID (PLMN), usage habits and IP address. We may also log your service access times, search query terms and the data stored in cookies on your devices.
Third-party data: We may receive data about you from publicly and commercially available sources as permitted by law. We may also receive data about you from third party social networking services, such as when you log in to our mobile App or websites using your Facebook or Twitter account.
How does CD CARE LIMITED use your personal data?
We may use your personal data to:
Fulfil purchase orders – deliver, activate, or verify products or services; make changes upon your request, and offer technical support and repair services.
Contact you – send you information about products and services that may be of interest; invite you to participate in CD CARE LIMITED promotions and market surveys; or send you marketing information with your explicit consent. If you don't want to receive such information, you can opt-out at any time.
Inform you about application or site updates and install them.
Offer you a personalized user experience and personalized content and activate your after-sale services such as the CDCare Extended Warranty, CDCare repairs and so on.
. Carry out internal audits, data analysis and research to improve our products and services.
Analyze the efficiency of our business operations and measure our market share.
Improve customer communications and ensure we provide a secure, quality service to customers.
Troubleshoot errors should you choose to send us error details.
Synchronize, share and store data you upload or download and data required to implement uploads and downloads.
Improve our loss prevention and anti-fraud programs.
How do we handle location-based services?
When you access certain location-based services, for example, when you request the delivery of a device you purchased or when you request pick for a device you want to be repaired, CD CARE LIMITED may collect, use and process your device's precise or indistinct location. This is necessary for CD CARE LIMITED to provide the aforementioned services. CD CARE LIMITED may collect your device identification numbers (IMEI, ESN, MEID, and SN), device type, model and real-time location data (obtained through GPS, Wi-Fi and your service provider's network ID). CD CARE LIMITED collects location data to provide and improve its location-based products and services.
We may ask you to indicate which of CD CARE LIMITED digital products you want location-based services to be enabled for. You can choose not to share your location data by turning off location-based services on your devices. For detailed information on how to disable location-based services, please contact your network operator.
How do we collect and use non-identifiable data?
Non-identifiable data refers to data that cannot be used to identify an individual. For example, CD CARE LIMITED may collect aggregated statistics, such as the number of users that installed its mobile app or visitors to its website or other applications and digital products and services.
How does CD CARE LIMITED use your personal data?
CD CARE LIMITED collects this data to understand how people use its mobile app, website or other applications and digital products and services. This allows CD CARE LIMITED to improve its services to better satisfy customer needs. CD CARE LIMITED may, at its own discretion, collect, use, process, transfer or disclose non-identifiable data for other purposes.
We endeavour to keep your personal data and non-identifiable data separate and use each independently. If personal data is combined with non-identifiable data, it will be treated as personal data.
To ensure that our mobile app and website function properly, we sometimes store small data files known as cookies on computers or mobile devices. A cookie is a simple text file that is stored on your computer or mobile device by a web server. Only the server that creates the cookie can retrieve or read the cookie's contents. Each cookie is unique to your web browser or mobile application.
WEB BEACONS AND PIXEL TAGS
In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our mobile app and website. A web beacon is typically a transparent image that is embedded on a website or in an email. For example, when you receive an email from CD CARE LIMITED , it may contain a click-through URL which links to content on our CDCare app, website or other digital products. If you click the link, the click-through is tracked by CD CARE LIMITED to help us learn about your device and service preferences and improve our customer service. The inclusion of pixel tags in emails allows us to know if our emails have been opened. If you do not want your activities to be tracked in such a way, you may unsubscribe from CD CARE LIMITED mailing lists at any time.
DO NOT TRACK
Many web browsers have a Do Not Track feature, which issues Do Not Track requests to websites. Currently, the main Internet standards organization has no policy governing how websites should behave when they receive such requests. However, all CD CARE LIMITED websites do respect the Do Not Track option if it is enabled in your browser.
How does CDCARE LIMITED discloses your personal data?
CD CARE LIMITED does not sell your personal data to third parties. However, CD CARE LIMITED may disclose your personal data under the following circumstances:
. Disclosures with explicit consent: After obtaining your explicit approval, CD CARE LIMITEDE may share your personal data with other parties.
Disclosures to CD CARE LIMITED affiliates: Your personal data may be shared with CD CARE LIMITED affiliates. As a matter of policy, we will only disclose data that is necessary.
Disclosures on legal or reasonable grounds: CD CARE LIMITED may disclose your personal data if required by the law, legal proceedings, litigation or public and governmental authorities. In some jurisdictions, your personal data may also be disclosed to transaction parties if CD CARE LIMITED is involved in a reorganization, merger or insolvency and liquidation proceedings.CD CARE LIMITED may also disclose your data where reasonable need can be demonstrated, such as to enforce its terms and conditions and to protect its customers.
How to access or modify your personal data?
You have a right to access your personal data, subject to some legal exceptions. Where privacy and information laws differ in some jurisdictions, we will comply with them. For security reasons, you may be required to put your request to access your personal data in writing.
You also have the right to delete or amend any personal information about you that we hold. CD CARE LIMITED will delete or amend such information upon your request in writing. We may decline to process requests if we have a reasonable basis to believe that they are made in bad faith, are impractical or if access is not otherwise required by local law.
How does CDCARE LIMITED protect your personal data?
CD CARE LIMITED takes personal data security seriously. We follow industry-standard practices to safeguard your personal data against unauthorized access, disclosure, use, modification, damage or loss. We take all reasonably practicable steps to protect your personal data. For example, we use encryption to ensure data confidentiality; we use trusted protection mechanisms to protect data from malicious attacks; we deploy visit control mechanisms to ensure only authorized personnel can access personal data; and we raise awareness among employees about the importance of protecting personal data through security and privacy protection training sessions.
We take all reasonably practicable steps to only collect relevant personal data. We only retain your personal data for the period necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. While we take the utmost care to protect your personal data, please note that no security measures are completely infallible.
How does CDCARE LIMITED handle the personal data of children?
Our mobile app, websites and digital products and services are primarily intended for adults. Children are not allowed to create their own user account without the consent of parents or guardians. Where a child's personal data is collected with parental consent, we will only use or disclose this data if the law permits it, if explicit permission is given by parents or guardians or if it is necessary to protect the child. Although the definition of a child may vary according to local laws and customs, we consider any person under the age of 18 years to be a child.
If CD CARE LIMITED learns that it has collected a child's personal data without first obtaining verifiable parental consent, it will take steps to delete the data within the shortest possible delay.
Third-party providers and their services
To ensure smooth use of our mobile app or smooth browsing experience of our website, you may be served content or web links from third parties external to CD CARE LIMITED and our Partners ("Third Parties"). CD CARE LIMITED does not have control over such Third Parties. You can choose whether or not to access links, content, products and services offered by Third Parties.
CD CARE LIMITED has no control over the privacy and data protection policies of Third Parties, which are not governed by this Policy. Before submitting your personal information to Third Parties, please refer to their respective privacy protection policies.
How your personal data is transferred internationally
CD CARE LIMITED products and services are delivered through resources and servers located around the world. This means your personal data may be transferred to or accessed from other jurisdictions which are outside the country where you use our products or services. These jurisdictions may have different data protection laws, or such laws may not even exist. In such cases, CD CARE LIMITED will ensure that a similar and adequate level of protection is afforded to your data as required by all applicable laws and regulations. For example, CD CARE LIMITED may request your consent to transfer personal data across borders or implement security measures like data anonymization prior to cross border data transfers.
How this Policy is updated