Privacy Policy
Your privacy is important to us at Oditor. We respect your privacy regarding any information we may collect from you across our website.
This privacy policy (this “Policy”) explains how personal information is collected, used, stored, and disclosed by Lintint Technology Limited or any of its affiliate(s) (“we,” “us,” and “our”) which operates the website https://theoditor.com (“Website”), and the “Oditor” app available on Google Play Store, iOS (the “App”), and other similar platforms, along with other services inventory management, accounting and sales management via the Website, App, and other online services to which this Policy is posted (“Services”). This Policy applies to consumer users (individually referred to as “you”) of our Services.
This Policy is an integral part of our Terms of Use for the Services. By accessing or using our Services, you agree to this Policy and our Terms of Use. The provisions contained in this Policy supersede all previous notices and statements regarding our privacy practices with respect to our Services. If you do not agree to every provision of this Policy and our Terms of Use, you may not access or use our Services.
Application of this policy
This Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a mobile phone, tablet, or other consumer electronic device (each, a “Device”). This Policy stipulates the basis for the collection, use, and disclosure of personal information from users of our Services in line with the Nigeria Data Protection Act 2023, the Nigeria Data Protection Regulations 2019, and other relevant data protection laws that governs the collection and processing of personal information (collectively referred to as “Data Protection Laws”).
Information supplied by users:
In general, you can visit the Website without telling us who you are or revealing any information about yourself. When you submit an inquiry via our Services or download our App and sign up, we may collect personal information from you, which may include your name, email address, mobile phone number, business entity information, banking information, KYC details, and other information that identifies you (collectively, “Personal Information”). The provided Personal Information helps us deliver the Services and enhance the user experience. In some cases, we may require your contact address for specific services. Upon downloading the App, users are requested to share access to their contact list to share payment/credit updates with their customers. We may access a user's inventory of installed apps as personal or sensitive data subject to this Policy and prominent disclosure requirements.
All Personal Information is service-dependent, and we use it to provide the Services, maintain, protect, and improve the Services. By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Policy.
Information collected automatically:
We may, through the use of third-party infrastructure service providers collect information about your use of our Services in a cloud-based environment. This information may include credit/payment records and customer information.
Information that we automatically collect in connection with your access or use of our Services may include:
Log Information:
We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:
- The Device's Internet Protocol (“IP”) address.
- Identification numbers associated with your Devices.
- Device event information, such as crashes, system activity, and hardware settings.
- Location preferences.
- Date and time stamps of transactions.
- System configuration information.
- Other interactions with our Services.
How We Use Information:
Below are the reasons why we process your Personal Data and the applicable circumstances when we will do so:
- We may use Personal Information for the purposes described elsewhere in this Policy and internally for our general commercial purposes, including, among other things, to offer our products and services, deliver personalized services, perform contract obligations, provide support, conduct marketing activities, and improve the user experience. Our third-party service providers will only be permitted to use and have access to your Personal Information in distributing the offers or providing the products or services.
- We may use cloud storage solutions within or outside Nigeria to store your Personal Information. We chose our cloud storage service provider with the aim of ensuring efficiency and improved performance through up-to-date technology.
- Where we have a legal or regulatory obligation to use such Personal Information, for example, when our data protection regulator, Nigeria Data Protection Commission (NDPC) require us to maintain certain records of our dealings with you.
- To comply with local or foreign laws, regulations, voluntary codes, directives, judgments, court orders, and agreements between us and any authority, regulator, or enforcement agency; policies, good practice, government sanctions or embargoes, reporting requirements under the Money Laundering (Prohibition and Prevention) Act 2022 and any other applicable law; demands or requests of any authority, regulator, tribunal, enforcement agencies including but not limited to the Nigerian Financial Intelligence Unit (“NFIU”) and the Economic and Financial Crimes Commission (“EFCC”), or exchange bodies;
- Where we need to use your Personal Information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims or where we want to pursue any legal claims ourselves;
- Where we need to use your Personal Information in reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud, credit and anti-money laundering checks, identification checks;
- Where we need to communicate with you to resolve complaints or other issues;
- Where you have provided your consent to our use of your Personal Information. We will usually ask for your consent when providing marketing information to you (including information about other products and services). This will be made clear when you provide your Personal Information. If we ask for your consent, we will explain why it is necessary. Without your consent in some circumstances, we may not be able to provide you with our services or you may not be able to benefit from some of our services.
- Where we have an appropriate legitimate business need to use your Personal Information such as maintaining our business records, and developing and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.
How We Share Information:
Information (including Personal Information) collected may be shared with our affiliates, group companies, and third-party service providers for internal business purposes on a need-to know basis and subject to data compliance obligations with Data Protection Laws.
We may share your Personal Information with unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to: (a) comply with applicable laws, Data Protection Laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Use or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our users or others; (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (5) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) for our everyday business purposes; or (7) as permitted by Data Protection Laws, applicable law or otherwise described in this Policy.
Opt-Out Rights:
If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us as indicated at the end of this Policy or by following the “unsubscribe” instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your account or related transactions with us.
Accessing Your Information
You must notify us of any change in your Personal Information by updating your account profile through our Services. Any changes will affect only future uses of your Personal Information. We retain certain data on a cloud-based database for backup and analytics purposes.
Subject to Data Protection Laws, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Policy.
You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information, we hold about you.
Your Rights regarding your Data:
You can ask us to do various things with your Personal Information. For example, at any time you can ask us for a copy of your Personal Information, ask us to correct mistakes, change the way we use your information, or even delete it. We will either do what you have asked or explain why we cannot - usually because of a legal or regulatory issue.
You have the following rights in relation to our use of your Personal Information.
- The right to access your Personal Information: You are entitled to a copy of the Personal Information we hold about you and certain details of how we use it. Your Personal Information will usually be provided to you in writing unless otherwise requested. We may charge you a reasonable fee to cover the cost.
- The right to rectification: We take reasonable steps to ensure that the Personal Information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it.
- The right to erasure: In certain circumstances, you have the right to ask us to erase your Personal Information, for example where the Personal Information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of Personal Information we hold about you and why we have collected it, there may be some legal and regulatory obligations that preclude us from complying with your request.
- Right to restriction of processing: In certain circumstances, you are entitled to ask us to stop using your Personal Information, for example where you think that the Personal Information, we hold about you may be inaccurate or where you think that we no longer need to process your Personal Information.
- Right to data portability: You have the right to easily access and transfer your personal data between services. Upon request, we will provide you with a copy of your Personal Information in a structured, commonly used, and machine-readable format to facilitate this transfer. Where technically feasible, we can also directly transfer your data to a third-party service provider of your choice.
- The right to withdraw consent: For certain uses of your Personal Information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your Personal Information. Please note in some cases we may not be able to provide our services to you if you withdraw your consent.
Security:
We take reasonable measures such as secured data cloud storage, encryption to protect Personal Information from unauthorized access, disclosure, alteration, or destruction. These techniques help protect your Personal Information while enabling us to improve our Services.We have and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration.
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information.
Protecting Children’s Privacy:
Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.
Links to Third-Party Websites:
When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Policy only applies to our Services.
Breach Notification:
In the event of a data breach affecting your personal data and leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information, we shall within 72 (seventy-two) hours of having knowledge of such breach report the details of the breach to Nigeria Data Protection Commission. Furthermore, if the breach is likely to result in a significant risk to your rights, we shall within 7 (seven) days of having knowledge of the occurrence of such breach take steps to notify you without undue delay, providing details of the breach, its potential impact, and any necessary actions you should take.
We take all appropriate measures to prevent data breaches and respond swiftly to protect your personal data.
International Data Transfers:
Some of the recipients and technical solutions set out above may be in other countries outside Nigeria. In all cases where Personal Information is transferred to a country which is deemed not to have the same standards of protection for personal data as Nigeria, we will ensure appropriate safeguards have been implemented to ensure that your Personal Information is protected where standards are not the same or similar to those standards within Nigeria. Such steps may include placing the party where we are transferring Personal Information to under contractual obligations to protect it to adequate standards. Occasionally, there may also be some circumstances where we are required to transfer your Personal Data outside of Nigeria and we shall rely on the basis of processing it for being necessary for the performance of your contract.
Data Retention Period:
We keep your Personal Data for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy and in order to comply with our legal and regulatory obligations. The length of time we retain Personal Data depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. Upon the deletion of your account on our Platform, we cease to retain any Personal Information belonging to you in our database.
Changes to our Privacy Policy:
Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Policy, but accepting this Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Policy or any revised version of this Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Policy in effect at the time of access or use.
How can I contact us?
If you have any questions, comments, or concerns related to your information processing, contact our Grievance Officer at hello@theoditor.com or the provided address.
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