PRIVACY POLICY
Cookie Policy
CONTENT OUTLINE
This Privacy Policy was last updated on the 30th of June, 2023.
While we have not made any material changes to the way we process data about our users, we have updated this policy to make it shorter and easier to read, and to comply with the Nigerian Data Protection Law and the EU General Data Protection Regulation.
We at Advocacy for Policy and Innovation (API) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data.
Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Company’s website, mobile applications, APIs or related services (the “Services”).
By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.
Data we collect from you
Personal information is data that can be used to identify or contact an individual.
By using our Services, you consent to the storage, usage and disclosure of your personal information including your nonpublic personal information (collectively referred to as “Personal Information”). By accessing or using the Services or otherwise providing information to us, you consent to the control and processing of the information by Advocacy for Policy and Innovations (API).
We collect certain data from you directly, like information you enter yourself, and data from third-party platforms you connect with the Company. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
Any Personal Information we collect will be used strictly in accordance with current data protection legislation and this Privacy Statement.
Information you provide to us directly
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:
- Account Data: In order to use certain features, you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, gender, and assign you a unique identifying number (“Account Data”).
- Unique Identifiable Data: You will need to provide your personal identifiable data such as driver’s license number, national identification number, international passport number, residence permit number, social security number, proprietary global unique identifiers.
- Employment Data: You will need to provide information on your employment status, employer details, business contact information, business registration details, and proof of business activities.
- Profile Data: You can also choose to provide profile information like a photo, social media profiles, or other data. Your Profile Data will be publicly viewable by others.
- Payment Data: If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, card information, billing address, and zip code. For security, the Company does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
- Data About Your Accounts on Other Services: We may obtain certain information through your social media or other online accounts if they are connected to your Company account. If you login to the Company via another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location and physical location of your access devices.
Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
7. Communications and Support: If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.
Information we may collect from other sources
When you access the Services we collect certain data by automated means, including:
- System Data: Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).
- Usage Data: Usage statistics about your interactions with the Services, including features accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Services (“Usage Data”).
- Approximate Geographic Data: An approximate geographic location, including information like country, city, and geographic coordinates, is calculated based on your IP address.
Information we may collect when you visit our websites
For purposes of this Privacy Statement, “website” includes our mobile applications.
By using our websites and associated microsites, you agree to the processing of your Personal Information as explained in this Privacy Statement, including the placement of cookies on your device.
Personal information is collected to fulfill your requests for products and services and to improve your online experience. We take steps to limit the amount of Personal Information collected to what is required to support the intended purpose of the collection.
API may ask you for some or all of the following types of information when you register for events, promotions, request services, manage accounts, access various content and features or directly visit our websites. The information includes, but is not limited to:
- Contact Information: Name, Email Address, Postal Address, Phone Number, Mobile Number, Facsimile Number;
- Communication Preferences such as newsletters you would like to receive;
- Search Queries.
In some instances, API will automatically collect certain types of information when you visit our websites and through emails exchanged with API, or through our customer service chat. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. The collection of this information will allow us to improve the effectiveness of our websites and our marketing activities.
- Mobile Devices:
If you access our websites on your mobile device, API may collect your unique device identifier and mobile device IP address, as well as information about your device’s operating system, mobile carrier and your location information.
When you provide us your mobile phone number as your contact phone number, you consent to the use of your mobile phone number for the purposes identified in this Privacy Statement. If you choose to receive notifications from us on your mobile device (e.g. text notifications), you also consent to the use of your mobile phone number for that purpose. - Location Information:
We may obtain your location information from our Business Partners, or otherwise on our Services. We may also incorporate geo mapping into our Services, and you may consent to the collection of location information by the third party geo mapping service provider in connection with your use of the geo mapping service. Any information collected via your use of the geo mapping service should be transmitted directly through the geo mapping service provider and is not through API. Please refer to the geo mapping service provider’ privacy policy for details about their collection, use and sharing of this information. - Links to Other websites:
Our websites may contain links to other sites which are outside our control and are not covered by this Privacy Statement. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policies. API is not responsible for the content or privacy practices of linked sites or any use of those sites.
Please be aware that API websites may contain links to sites maintained by other organizations. We encourage you to review the privacy policy of each website you visit.
How we get data about you
- Cookies and Similar Technologies
API collects information during your visit to the website through the use of cookie technology. A cookie is a piece of programming information contained in a very small text file that is placed in your internet browser or elsewhere on your hard drive. You can control acceptance of cookies by modifying your internet browser preferences. You have the ability to accept all cookies, to be notified when a cookie is set or to reject all cookies. Please note that, if you choose to block all cookies (including essential cookies) you may not be able to access all or part of our site and may be unable to use those services or engage in activities that require the placement of cookies. API uses cookies to distinguish you from other users of our website and also provide us with aggregated website usage statistics.
In addition, on some occasions, API may use tracking technologies such as web beacons, to collect information about your visits to our websites. These are small electronic images embedded in web content or e-mail messages and are ordinarily not visible to users. Like cookies, this tracking technology enables us to track pages and content accessed and viewed by users on API websites. The use of these technologies also helps us to provide you with a positive experience when you browse our websites, and it also helps refine our content and personalize your experience. - Information We Collect When You Engage With Us on Social Media
You can engage with API through social media websites or applications or through features such as plug-ins or applications on our websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your social media account, or engage with API on or through third party social media sites, plug-ins, or applications, you may allow API to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the ‘likes’ you make).
If you post information when you interact with our Services through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customise your privacy settings and how third party social media sites handle your personally identifiable information, please refer to their privacy help guides, privacy policies and terms of use. - Information We May Collect Through Third Party Advertising
We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the internet. These Third-Party Advertising Partners may use cookies, web beacons and other technologies to display advertisements of our products to you when you are on other, third-party websites that are affiliated in some way with the advertising partners. The information collected and shared via cookies may contain Personal Information.
The Third-Party Advertising Partners may collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by API and others, to among other things, analyse and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity.
How we use your data
We use information to operate the Services, including:
- To Process Your Requests to Administer Your Account and Provide the Services to You
Personal Information in our possession shall only be used in accordance with this Policy Statement, in performing statistical analysis of users’ behavior as a whole; and to help in the creation of anonymized statistical data which we may use at our discretion (including licensing to third parties).
API collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply: - Our data will be:
– Accurate and kept up-to-date;
– Collected fairly and for lawful purposes only;
– Processed by API within its legal and moral boundaries; and
– Protected against any unauthorized or illegal access by internal or external parties. - Our data will not be:
– Communicated informally;
– Transferred to organizations, states or countries that do not have adequate data protection policies; and
– Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities). - API’s Business Partners are encouraged to:
– Let people know which of their data is collected;
– Inform people about how API will process their data; and
– Inform people about who has access to their information. - To Share Your Information
We may disclose any information we collect as follows:
– The Reporting Entity with whom you are establishing a relationship and other similar organizations, or those that are nominated by you;
Government entities and other external data providers that hold information on you in order to verify that the information provided by you is consistent with the records held by such entities;
– To another user when you sign up for API’s services via a referral link. The user that referred you may receive information indicating that you have enrolled with API. You may avoid this sharing by not using a referral link to enroll;
To Business Partners, affiliated companies, and authorized service providers, we disclose Personal Information as is necessary to provide our Services. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. We do not rent, sell or otherwise disclose Personal Information about our online visitors with unaffiliated third parties for their own marketing use;
– With other non-affiliated companies for our everyday business purposes, such as to maintain accounts, respond to court orders and legal investigations. For example, in connection with our everyday business purposes, we may share information about you as follows:
– In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process; With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud; If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of API, or others; and
– We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes and merchant names with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions. - To Improve the Services and Develop New Ones
Administer focus groups and surveys;
– Conduct research and analysis of Users’ behavior to improve the Services;
– Develop new features and services. - To Prevent, Detect and Fight Fraud or Other Illegal or Unauthorized Activities
– Address ongoing or alleged fraud or other misbehavior on or through the Services;
– Analyze data to better understand and design countermeasures against fraud;
– Retain data related to fraudulent activities to prevent recurrences. - To Ensure Legal Compliance
– Comply with legal requirements;
– Assist law enforcement;
– Enforce or exercise our rights, for example, our Terms of Service;
– To process your information as described in this Privacy Policy, we rely on the following legal bases:
a. Legitimate Interests: We may use your information where we have legitimate interests to do so. For example, we analyze our Users’ behavior to improve the Services, to prevent and detect fraud and misuse, and to market the Email Notifications to you.
b. Consent: From time to time, we may ask for your consent to use your information. You may withdraw your consent at any time by contacting us using the contact information provided above.
How we share your information
API takes reasonable steps to protect your Personal Information from misuse, loss, unauthorized access, modification or disclosure.
- With our Affiliates
We share your information with our affiliates to help us with technical processing operations, such as data hosting and maintenance, client care, marketing and targeted suggestions, better understanding how the Services are used and Users’ behavior to improve the Services, securing our data and systems, fighting against spam, abuse, fraud and intellectual property infringement. - When Required by Law
Applicable law may require us and our service providers to disclose your information if:
– reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirements; or
– necessary for the prevention or detection of crime (subject in each case to applicable law). - To Enforce Legal Rights
We may also share information:
– if disclosure would mitigate our liability in an actual or threatened lawsuit;
as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties;
– to enforce our agreements with you; and
– to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing. - With Your Consent or at Your Request
We may ask for your consent to share your information with third parties. When we do, we will make clear why we want to share the information.
We may collect and provide aggregate information about our Users (such as how many persons visited a particular page or activity or the likes and dislikes of our Users) to our advertisers, sponsors, promotional partners and affiliates but this aggregated information does not include personal information about any individual User.
Our use of cookies
Our Websites use cookies and other tools.
A cookie is a small data file that contains a unique identification number that a website places on your hard drive when you visit a site. The cookie stores information about your computer, the type of browser you use, and how many times your computer visits a certain site. Cookies enable us to track how often Users are visiting our Websites and the specific pages visited, the number of entries in specific events, the estimated audience size for sponsors and advertisers, and other User preferences. You can refuse to use cookies by turning them off in your browser. You do not need to have cookies turned on to use most of the Website. However, you may find that some areas on the Website will be slower, or may not function at all, and you may not be able to participate in certain activities such as contests or sweepstakes if the cookies are disabled.
How we protect and retain information
We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your personal information to those employees who need to know that information to service your account or perform their job functions.
All Relying Parties and agents are contractually bound to maintain the confidentiality of Personal Information and may not use the information for any unauthorized purpose.
API is committed to:
- Restricting and monitoring access to sensitive data;
- Developing transparent data collection procedures;
- Training employees in online privacy and security measures;
- Building secure networks to protect online data from cyber attacks; and
- Establishing data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.).
Only employees who need the information to perform a required process are granted access to personally identifiable information to the extent that is necessary. The computers and hardware in which API stores personally identifiable information are kept in a secure environment.
We follow best practice industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. When you enter sensitive information, you are advised to always use encrypted secure socket layer technology (SSL).
Your rights as a data subject
You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services and can also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.
Kindly visit our DATA PROTECTION POLICY to know more about your rights as a data subject.
Our choices about your information
- Information on API Database
If you would like to review, correct, update, suppress, restrict or delete personal information (including Personal Data as defined in the PRIVACY SHIELD section below) that you have previously provided to us, or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (if this right to data portability is provided to you by law), you can contact us at :
Email: hello@apiintelligence.org or;
Write to us at:
Advocacy for Policy and Innovation Ltd/Gte
Attn: Privacy/Legal Team,
Address : No 5 Kwaji Close Maitama, Abuja, Nigeria. - In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. For your protection, we only fulfil requests for the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for record-keeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases and other records may have residual data which will not be removed. In addition, we also may not allow you to review certain data for legal, security or other reasons. If at any time you believe that the Services have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem. - Children’s Privacy
API respects the privacy of your child and we want to share with you our policies regarding children under the age of sixteen (16). Although Users of all ages may navigate through the Services, we do not knowingly collect personal information from anyone under age sixteen (16). If we learn that a child under age sixteen (16) has improperly provided us with information, we will notify the child’s parent or legal guardian and thereafter delete the child’s personal information from our records. - Links to Other Websites And Services
The Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. API does not guarantee and is not responsible for the privacy or security of these third-party external websites, or for any information represented in these websites.
Cross-border data transfers
Advocacy for Policy and Innovation (API) is headquartered in Abuja, Nigeria. Our Data Privacy is governed by the Nigerian Data Protection Laws, European Union Data Protection Regulations and the Data Protection Regulations of the jurisdictions in which our services are used. Sharing of information sometimes involves cross-border data transfers to or from Africa and other jurisdictions. By visiting or using our Services, you consent to storage of your data on servers located in our host countries. We use the European Union Data Protection Privacy Shield and standard contractual clauses approved by our host countries to validate transfers of foreign residents’ personal information from and to various countries. For more information about our Privacy Shield certification, please visit our Privacy Shield policy.
Updates and modifications to this privacy policy
From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.
As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.
- Interpretation
Any capitalized terms not defined in this policy are defined as specified in API’s Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control. - Contact Us
If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our designated personal information protection manager) at:
Email: hello@apiintelligence.org or;
Write to us at:
Advocacy for Policy and Innovation
Attn: Privacy/Legal Team,
Address : No.5 Kwaji Close Maitama Abuja, Nigeria.
Last updated: This Privacy Policy was last updated on February 23, 2023
