Privacy Policy
Effective Date: 2024-05-25

At Midatalinks ("we," "our," or "us"), safeguarding your privacy is our priority. This Privacy Policy outlines the ways in which we gather, utilize, and share your personal information.

This policy is specifically related to our application, Midatalinks. By using or accessing our Service, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy and our Terms of Service, including our practices concerning the collection, storage, use, and disclosure of your personal information.

Definitions and Key Terms
• Cookie: A small piece of data generated by a website and stored by your web browser, used to identify your browser, provide analytics, and remember information about you such as language preferences or login details.
• Company: Refers to ELEIDE, Ota, Ogun state when mentioned as "Company," "we," "us," or "our" in this policy, responsible for your information under this Privacy Policy.
• Country: Indicates Nigeria, where Midatalinks or its owners/founders are based.
• Customer: The company, organization, or individual that registers to use Midatalinks's Service to manage relationships with consumers or service users.
• Device: Any internet-connected device like a phone, tablet, computer, or any other device used to access Midatalinks and its services.
• IP Address: A number assigned to every device connected to the Internet, usually allocated in geographic blocks, which can often be used to identify the location of a connecting device.
• Personnel: Individuals employed by Midatalinks or contracted to perform services on behalf of one of the parties.
• Personal Data: Information that directly or indirectly identifies or makes identifiable a natural person, including through a personal identification number.
• Service: The service provided by Midatalinks as detailed in the relevant terms and on this platform.
• Third-Party Service: Advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we believe may interest you.
• Website: The Midatalinks website, accessible at https://midatalinks.com.ng.
• You: Any person or entity registered with Midatalinks to use the Services.

What Information Do We Collect?
We gather various types of information from you in the following scenarios: when you visit our app, register on our site, place an order, subscribe to our newsletter, respond to a survey, or fill out a form. The information we collect includes:

• Name / Username
• Phone Numbers
• Email Addresses
• Mailing Addresses
• Password
Additionally, to enhance your user experience, we collect certain information from mobile devices. These features are optional:
• Phonebook (Contacts List): Access to your contacts list makes the app easier to use by saving you time typing out recipient phone numbers.
• Camera (Pictures): Granting camera permission enables you to upload pictures directly from your phone. You can choose to deny camera permissions if desired.
• Photo Gallery (Pictures): Allowing access to your photo gallery lets you upload pictures from your gallery. This permission is also optional and can be denied.

When Does Midatalinks Use End User Information from Third Parties?
Midatalinks collects End User Data as necessary to deliver our services to customers. End users may choose to provide us with information available on social media websites. If such information is provided, we may collect publicly accessible data from the specified social media platforms. You have the ability to manage the visibility of your information on social media by adjusting your privacy settings on those platforms.

When Does Midatalinks Use Customer Information from Third Parties?
We sometimes receive information from third parties when you interact with us. For example, when you submit your email address to express interest in becoming a Midatalinks customer, we may receive information from third-party services that provide automated fraud detection. Additionally, we occasionally gather publicly available information from social media websites. You can control the extent of information shared on these platforms by modifying your privacy settings.

Do We Share the Information We Collect with Third Parties?
We may share the information collected, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who contribute to our content or whose products and services might interest you. This information may also be shared with our affiliated companies and business partners. In the event of a merger, asset sale, or other business reorganization, your personal and non-personal information may be transferred to our successors-in-interest.
We may engage trusted third-party service providers to perform functions and offer services such as hosting, maintaining servers, database management, email management, marketing, credit card processing, customer service, and fulfilling product and service orders made through our app. To facilitate these services, we may share your personal and possibly some non-personal information with these third parties.
For analytics purposes, we might share portions of our log file data, including IP addresses, with third parties such as web analytics partners, application developers, and ad networks. Shared IP addresses may be used to estimate general location, connection speed, shared location visits, and device type. These third parties may aggregate information about our advertising and app content and provide auditing, research, and reporting for us and our advertisers.
Additionally, we may disclose personal and non-personal information to government or law enforcement officials or private parties as deemed necessary or appropriate. This may be in response to claims, legal processes (including subpoenas), to protect our rights, interests, public safety, or any person’s safety, to prevent illegal or unethical activities, or to comply with legal obligations, court orders, laws, rules, and regulations.

Where and When Is Information Collected from Customers and End Users?
Midatalinks collects personal information directly submitted by you. Additionally, we may receive personal information about you from third parties, as previously described.

How Do We Use the Information We Collect?
The information we gather from you may be utilized in various ways, including:
• Personalizing your experience to better meet your individual needs.
• Enhancing our app based on your feedback and the information we receive.
• Improving customer service to more effectively address your service requests and support needs.
• Processing transactions.
• Administering contests, promotions, surveys, or other site features.
• Sending periodic emails.

How Do We Use Your Email Address?
By submitting your email address on our app, you consent to receiving emails from us. You can unsubscribe from these emails at any time by clicking the opt-out link or unsubscribe option included in each email. We only send emails to those who have explicitly opted in, either directly or through a third party, as we are committed to avoiding unsolicited commercial emails. By providing your email, you also agree that we can use it for customer audience targeting on platforms like Facebook, where we display custom advertising to those who have opted in. Email addresses submitted during order processing are used solely for sending information and updates related to your order. If the same email address is provided through other means, it may be used for additional purposes outlined in this Policy. Note: Detailed unsubscribe instructions are included at the bottom of each email.

How Long Do We Keep Your Information?
We retain your information only as long as it is needed to provide you with Midatalinks services and fulfill the purposes described in this policy. This also applies to third parties with whom we share your information to perform services on our behalf. Once we no longer need your information and it is not required for legal or regulatory compliance, we will either delete it from our systems or depersonalize it so that you can no longer be identified.

How Do We Protect Your Information?
We employ various security measures to protect your personal information when you place an order or enter, submit, or access your personal information. This includes using a secure server. However, we cannot guarantee the absolute security of any information you transmit to Midatalinks or ensure that your information on the Service will not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

Could My Information Be Transferred to Other Countries?
Midatalinks is based in Nigeria. Information collected through our application, direct interactions with you, or use of our help services may be transferred to our offices or personnel, or to third parties around the world, and may be viewed and hosted anywhere globally, including in countries without general data regulation laws. By using our services, you consent to the trans-border transfer and hosting of such information to the fullest extent allowed by law.

Is the Information Collected Through the Midatalinks Service Secure?
We take measures to protect the security of your information, employing physical, electronic, and managerial procedures to safeguard it against unauthorized access, maintain data security, and correctly use your information. However, no system is foolproof, including encryption systems. People can commit crimes, make mistakes, or fail to follow policies. While we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, our compliance will be measured by the standard of intentional misconduct.
Can I Update or Correct My Information?
The rights to request updates or corrections to your information depend on your relationship with Midatalinks. Personnel may update or correct their information according to our internal company policies.
Customers can request restrictions on certain uses and disclosures of their personal information. You can contact us to:
1. Update or correct your personal information.
2. Change your communication preferences.
3. Delete your personal information from our systems by cancelling your account.
These updates, corrections, changes, and deletions will not affect other information we maintain or information provided to third parties in accordance with this Privacy Policy before such changes. We may take reasonable steps to verify your identity before granting profile access or making corrections. You are responsible for maintaining the confidentiality of your password and account information.
It is not technically possible to remove every record of the information you have provided to us. Backup systems to protect against data loss mean that a copy of your information may exist in a non-erasable form. After receiving your request, we will update, correct, change, or delete your personal information in active databases and other readily searchable media as soon as reasonably practicable.
If you are an end user wishing to update, delete, or receive information about you, contact us at support@midatalinks.com.ng

Personnel
For those employed by Midatalinks or applying for a position, we gather information that you voluntarily provide. This data is used for Human Resources purposes, such as administering worker benefits and screening job applicants. You can contact us to:
1. Update or correct your information.
2. Change your preferences regarding communications and other information received from us.
3. Obtain a record of the information we hold about you.
Such updates, corrections, changes, and deletions will not affect other information we maintain or data provided to third parties in accordance with this Privacy Policy before such changes.
Sale of Business
In the event of a sale, merger, or other transfer of all or substantially all of Midatalinks's assets or those of any of its Corporate Affiliates, or if we discontinue our business or enter bankruptcy or similar proceedings, we reserve the right to transfer your information to the third party, provided they agree to adhere to this Privacy Policy.

Affiliates
We may share your information, including personal data, with our Corporate Affiliates. A "Corporate Affiliate" is any entity that directly or indirectly controls, is controlled by, or is under common control with Midatalinks. Any shared information will be treated in accordance with this Privacy Policy by those Corporate Affiliates.
Governing Law
This Privacy Policy is governed by the laws of Nigeria, without regard to its conflict of law provisions. You agree to the exclusive jurisdiction of the Nigerian courts for any dispute arising under this Privacy Policy, except for claims under Privacy Shield or the Swiss-US framework. Your use of the app may also be subject to other local, state, national, or international laws.
By using Midatalinks or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree, you should not use our app or services. Continued use after posting changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information indicates acceptance of those changes.

Your Consent
We have updated our Privacy Policy to provide transparency about what information is collected when you visit our site and how it is used. By using Midatalinks, registering an account, or making a purchase, you consent to our Privacy Policy and agree to its terms.

Links to Other Websites
This Privacy Policy applies only to our Services. Our Services may contain links to other websites not operated or controlled by Midalinks. We are not responsible for the content, accuracy, or opinions expressed on those websites, nor do we monitor or check them for accuracy or completeness. Once you leave our Services to visit another website, our Privacy Policy no longer applies. Your interactions on other websites are subject to their own policies and rules. Third parties may use cookies or other methods to collect information about you.

Advertising
Our app may feature third-party advertisements and links to third-party sites. Midatalinks does not guarantee the accuracy or suitability of the information in these ads or sites and is not responsible for their content or the quality of their products or services. Advertising helps keep Midatalinks and many of its services free. We strive to ensure that ads are safe, unobtrusive, and relevant.
Third-party ads and links to other websites are not endorsements or recommendations by Midatalinks. We are not responsible for the content of any ads, promises made, or the quality/reliability of the advertised products or services.
Cookies for Advertising
These cookies collect data over time about your online activity on our app and other services to make ads more relevant and effective. Known as interest-based advertising, they prevent the same ad from repeatedly appearing and ensure proper ad display. Without cookies, advertisers would find it challenging to reach their audience or track ad performance.

Cookies
Midatalinks uses "Cookies" to identify areas of our website you have visited. A Cookie is a small data file stored on your device by your web browser. We use Cookies to enhance the performance and functionality of our app, although they are non-essential. Disabling Cookies may prevent you from accessing certain functionalities on our website correctly or at all. We never place Personally Identifiable Information in Cookies.
Blocking and disabling cookies and similar technologies
Wherever you're located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser's help menu for more information.

Remarketing Services
We use remarketing services. What Is Remarketing? In digital marketing, remarketing (or retargeting) is the practice of serving ads across the internet to people who have already visited your website. It allows your company to seem like they're “following” people around the internet by serving ads on the websites and platforms they use most.

Payment Details
In respect to any credit card or other payment processing details you have provided us, we commit that this confidential information will be stored in the most secure manner possible.

Kids' Privacy
We collect information from kids under the age of 13 just to better our services. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data without your permission, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can contact us to remove your account.

Third-Party Services
We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third- Party Services").
You acknowledge and agree that Midatalinks shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. Midatalinks does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.
Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.

Facebook Pixel
Facebook pixel is an analytics tool that allows you to measure the effectiveness of your advertising by understanding the actions people take on your website. You can use the pixel to: Make sure your ads are shown to the right people. Facebook pixel may collect information from your device when you use the service. Facebook pixel collects information that is held in accordance with its Privacy Policy
Tracking Technologies
• Local Storage
Local Storage sometimes known as DOM storage, provides web apps with methods and protocols for storing client-side data. Web storage supports persistent data storage, similar to cookies but with a greatly enhanced capacity and no information stored in the HTTP request header.
• Sessions
uses "Sessions" to identify the areas of our application that you have visited. A Session is a small piece of data stored on your computer or mobile device by your web browser.

Information about General Data Protection Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how and why is this data collected, and how we maintain this data under protection from being replicated or used in the wrong way.

What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is protected by companies and enhances the control the EU residents have, over their personal data.
The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide.
What is personal data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity.

The Data Protection Principles include requirements such as:
• Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect.
• Personal data should only be collected to fulfil a specific purpose and it should only be used for that purpose. Organizations must specify why they need the personal data when they collect it.
• Personal data should be held no longer than necessary to fulfil its purpose.
• People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.

Why is GDPR important?
GDPR adds some new requirements regarding how companies should protect individuals' personal data that they collect and process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond these facts it's simply the right thing to do. At Help Scout we strongly believe that your data privacy is very important and we already have solid security and privacy practices in place that go beyond the requirements of this new regulation.

Individual Data Subject's Rights - Data Access, Portability and Deletion
We are committed to helping our customers meet the data subject rights requirements of GDPR. Midatalinks processes or stores all personal data in fully vetted, DPA compliant vendors. We do store all conversation and personal data for up to 6 years unless your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days.
We are aware that if you are working with EU customers, you need to be able to provide them with the ability to access, update, retrieve and remove personal data. We got you! We've been set up as self service from the start and have always given you access to your data and your customers data. Our customer support team is here for you to answer any questions you might have about working with the API.

California Residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.
We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:
• Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
• Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
• Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
• Request that a business that sells a consumer's personal data, not sell the consumer's
personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

We do not sell the Personal Information of our users.
For more information about these rights, please contact us.

California Online Privacy Protection Act (CalOPPA)
CalOPPA requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.
CalOPPA users have the following rights:
• Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
• Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
• Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
• Right to request that a business that sells a consumer's personal data, not sell the consumer's personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
We do not sell the Personal Information of our users.

For more information about these rights, please contact us.
Contact Us
Don't hesitate to contact us if you have any questions.
• Via Email: support@midatalinks.com.ng
• Via Phone Number: 07014455234