Last Updated: October 11, 2019
- On or through this Website.
- In email, text, and other electronic messages between you and this Website.
- Any information we collect offline;
- Any information collected by a website operated by a third party which FELFO DIGITAL may link to or be accessible from the Website or;
- Any activities FELFO DIGITAL takes on behalf of its clients – in which it acts as a data processor. If you wish to inquire about the data processing, we undertake for any of our clients, or wish to assert your data protection rights regarding that processing, please contract the relevant client directly. If you do not know who our client is, you can contact us directly with your request. Please click on the following link if you want to understand how FELFO DIGITAL works with our clients and processes information on behalf of our clients.
Information We Collect
We collect information to provide better experiences to the Users of this Website – from figuring out basic stuff like which language you speak, to more complex things like which ads you’ll find most useful, the products and services that matter most to you, or which digital experiences you may not yet be aware of but might enjoy.
FELFO DIGITAL collects and processes two basic types of information from and about Users:
- Personal information: This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses and other contact information). This information is voluntarily provided to us by Users and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services.
- Aggregate user and tracking information: This information gives us insights on how Users use our Website. This data is anonymous and does not contain any personal information. We use this information to ensure that our Website, e-mails and marketing efforts continue to appeal to Website visitors and clients.
This information is collected in the following ways:
For visitors to FELFO DIGITAL’s website who are interested in working for us, FELFO DIGITAL collects the personal information that you provide when applying for open positions through our online career center. You may receive additional information from FELFO DIGITAL regarding your application at the address you provide.
We do not use any of the personal information you provide to FELFO DIGITAL to request information about FELFO DIGITAL’s or its client’s products and services as part of your application for employment or for any other purpose. We do not sell or rent such information.
Any personal information collected by FELFO DIGITAL is controlled by FELFO DIGITAL at its Fort Worth, Texas headquarters.
How We Use Information We Collect
We use information that we collect about you or that you provide to us, including any personally identifiable information:
- To present our Website and its contents to you.
- To provide, maintain, protect and improve our services, to develop new ones, and to protect our Users.
- To offer you tailored content – like giving you a more relevant ad experience and improving our businesses to better anticipate and meet your needs and desires.
- To fulfill any other purpose for which you provide it.
- To notify you about changes to our Website or any services we offer or provide through it.
- In any other way we may describe when you provide the information.
We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with FELFO DIGITAL employees and service providers to the extent necessary to administrate our systems and/or accommodate your request.
As discussed above, we use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
Information We Share
We may disclose aggregated information about our Users, and information that does not identify any individual (non-personally identifiable information), without restriction, including with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.
FELFO DIGITAL does not share, sell or distribute personal information collected from Users with companies, organizations and individuals outside of FELFO DIGITAL unless one of the following circumstances applies:
- For legal reasons. We will share personal information with companies, organizations or individuals outside of FELFO DIGITAL if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- comply with any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable terms of service, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of FELFO DIGITAL, our Users, our customers or the public as required or permitted by law. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA, the UK or Switzerland. With respect to transfers of personal information to the U.S., FELFO DIGITAL will comply with the level of privacy protection as is required by the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the U.S. Department of Commerce, regarding the transfer of personal information from the EEA, UK or Switzerland to the U.S. Click http://www.felfodigital.com.ng/privacy-policy/#privacy-shield-policy/ to view our Privacy Shield Policy.
Transparency and Choice
People have different privacy concerns. Our goal is to be clear about what information we collect and how we use it, so that you can make meaningful choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:
- Google Ads. View and edit your preferences about the Google ads shown to you on Google and across the web, such as which categories might interest you, using Ads Settings. You can also visit that page to opt out of certain Google advertising services.
- Profile Information. Take out any of your personal information associated with any FELFO DIGITAL profile.
Notwithstanding anything contained herein, you may ask us to delete any information about you and cease further contact at any time by sending us a request http://www.felfodigital.com.ng/contact/ marked “Privacy-Urgent”.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.
At times, our Website may provide interactive areas, such as chat rooms, forums and message boards available to Users. You are not required to provide any personal information when using these areas, but you may choose to do so. We strongly recommend that you DO NOT use your personal information as your user name and DO NOT post any personally identifiable information on line, since such information will be publicly available. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.
Accessing and Correcting your Information
You may contact us at http://www.felfodigital.com.ng/contact/ to request access to, to correct, to update or to delete any personal information that you have provided to us. To protect your privacy and security, we will also take reasonable steps (including seeking additional information or documentation) to verify your identity before updating or removing your information. Upon receiving your email with the request to update or remove your information, our privacy team will log the receipt of your request and will contact the appropriate data holder within FELFO DIGITAL in order to enable them to process your request. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
FELFO DIGITAL understands that the safety of your personal information is extremely important to you. Accordingly, we work hard to protect FELFO DIGITAL and our Users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. In particular:
- All personally-identifiable information is hashed using the SHA-256 algorithm immediately upon receipt.
- FELFO DIGITAL relies upon the Amazon Web Services infrastructure for continuous auditing by security accreditation bodies, including ISO 27001, FedRAMP, DoD CSM, and PCI DSS.i.
- Personally-identifiable information is securely stored in an encrypted, distributed database, protected with Amazon’s Key Management Service.
- Data stored on Amazon S3 is encrypted both at rest and in transmission using AES-256
- Access to hashed personally-identifiable information is limited to FELFO DIGITAL’s engineering group. Outside of engineering, only our proprietary applications may access hashed bulk files on behalf of FELFO DIGITAL employees. Human access to raw personally-identifiable information is prohibited and restricted by our software.
Due to the nature of the Internet and related technology, we cannot guarantee the security of your personal information and FELFO DIGITAL expressly disclaims any such obligation.
Links to Other Websites
Compliance and Cooperation with Regulatory Authorities
Provisions Applicable to International Users
FELFO DIGITAL complies with the level of privacy protection as is required by the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from EEA member countries, the UK and Switzerland. To learn more about these Privacy Shield programs, please visit http://www.privacyshield.gov. To review FELFO DIGITAL’s privacy shield policies, please visit http://www.felfodigital.com.ng/privacy-policy/#privacy-shield-policy/.
Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at http://www.felfodigital.com.ng/contact/.
FELFO DIGITAL Privacy Shield Policy
FELFO DIGITAL recognizes that the EEA, the UK and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK and Switzerland. To provide adequate protection for certain Personal Data about consumers, clients, business, job applicants and employees received in the US from the EEA, the UK and Switzerland, FELFO DIGITAL has elected to comply with the level of privacy protection as is required by the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the U.S. Department of Commerce (“Privacy Shield”). FELFO DIGITAL adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, FELFO DIGITAL is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov.
Personal Data Collection and Use
Data Transfers to Third Parties
Third-Party Data Controllers. In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for the following purposes: business-intelligence analytics, data matching with other consumer-based databases, and targeted advertising. We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the Privacy Shield requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the Privacy Shield requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our company group, we will take steps to ensure that your Personal Data is protected with the same level of protection the Privacy Shield requires.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
FELFO DIGITAL maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at http://www.felfodigital.com.ng/contact/. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we agree to cooperate with the EU data protection authorities, the UK Information Commissioner or the Swiss Federal Data Protection and Information Commissioner. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities, the UK Information Commissioner or the Swiss Federal Data Protection and Information Commissioner for further information and assistance.
Binding Arbitration. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with FELFO DIGITAL and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authorities and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration). [https://www.privacyshield.gov/article?id=ANNEX-I-introduction]
If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows: http://www.felfodigital.com.ng/contact/
Changes to this Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
Effective Date: December 5, 2016
Last modified: October 21, 2019