Privacy Policy

Introduction

Your privacy is important to us. We endeavour to ensure that our use of your personal information is lawful and relevant to our business activities with the aim of improving our services and your experience. This Privacy Notice is designed to help you understand our privacy practices and procedures regarding what information and personal data we collect when you use our services, why we collect it, and what we do with it, as well as your rights regarding the processing of your personal data by us.

Who are we?

Dellla (“Dellla”, “our”, “we” or “us”) is a product of Itiode in Nigeria. Itiode is technology company registered under CAC (Corporate Affairs Commision), with the business name registration number 3375505. Located at 59 C, ICE Road, Off Wire Rd, Benin City, Edo state, Nigeria. For questions specifically about this Privacy Notice, or our use of your personal information, please contact our Data Protection Officer by email at itiodecompany@gmail.com. The data controller of your personal information is Itiode. We will always process any Personal Data about you in compliance with applicable data protection laws including the Nigerian Data Protection Regulation 2019 or any other data protection law that may have the force of law in Nigeria from time to time, and only for the purposes set out in this Privacy Notice.

Application of this Privacy Notice

This Privacy Notice applies to you as an individual that uses the Dellla or Dellla Partner app.

What do we mean by personal information?

Personal information refers to information about an identifiable human being such as your name, contact address, email, phone number, identification card number, your picture, your bank details. Other information that qualifies as personal information include:

  • Device information: Internet Protocol address, unique device identifier, the nature and type of device you use, the geographical location of your device.
  • Log information: Information relating to how, when and for how long you access and use our app; screens you accessed, viewed, the time spent and what you did on the screens you accessed; your interests in terms of our service.
  • Location information: We try to ascertain your actual location, such as geographical data from your device.

The Personal Information We Collect

We receive and store information about you such as information you provide to us, we collect information you provide to us when you use our service which includes:

  • Your name, email address, contact address, bank account, valid means of identification, telephone number, your date of birth, email, password, other identifiers you might use, gender, picture.
  • Information when you choose to provide ratings, taste preferences, account settings or otherwise provide information to us through our service or elsewhere.
  • Location information: We try to ascertain your actual location, such as geographical data from your device.

We automatically collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your network, network devices, and your mobile or devices you may use to access our service. We collect this information using various technological means. This information includes:

  • Your activity on our site.
  • Your interactions with our emails and texts, and with our messages through any messaging channels.
  • Details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings.
  • Device IDs or other unique identifiers, including for your network devices.
  • Advertising identifiers such as those on mobile devices, tablets, and streaming media devices that include such identifiers.
  • Device and software characteristics (such as type and configuration), connection information, including type (wifi, cellular), statistics on screen views, IP address (which may tell us your general location), mobile and web server log information.

Information from partners: We collect information from other companies whose services have been integrated into our platform. These Partners may include (depending on what services you use): your device location, our business partners and affiliates, our payment service providers and our bank(s) and fraud prevention agencies.

Why and How We Use Your Personal Information

We will only process your personal information when the law allows us to, that is, when we have a legal basis for processing. We use your personal data in the following circumstances:

  • Establish and verify your identity.
  • Create an account for you and to ensure that your account does not duplicate an existing user account.
  • Provide you with our services.
  • Maintain and update our database.
  • Fulfil any contractual obligations we may have to you and to fulfil legal obligation we have to government agencies and third parties
  • Device and software characteristics (such as type and configuration), connection information, including type (wifi, cellular), statistics on screen views, IP address (which may tell us your general location), mobile and web server log information.
  • Secure our systems, prevent fraud and help us protect the security of your account.
  • Inform you of facts relating to your access to and use of your account and our site.
  • Inform you about our products and services which we think may interest you (as long as you have consented to this).
  • Inform you about any changes to our app, products, services, our terms of use, this Privacy Notice, or any other changes that may be relevant to you.
  • Improve your user experience and overall quality of our services.
  • Keep a record of our communication with you and of your communication with us.
  • Compile and use statistical information about you and other users and their access to and use of our app, browsing habits, click patterns and preferences, demographics etc. which we may use to develop, provide and improve our platforms, products and services.
  • Other activities not specifically mentioned which are lawful, reasonable and relevant to our business activities, and the minimum necessary and adequate for us to provide you with our services and products.

Disclosure of Information

We will not disclose, for commercial gain or otherwise, your personal information other than as set out in this Privacy Notice or with your consent. We may disclose or share your personal information to or with any of the following for certain purposes:

  • Our Affiliates: We may share your personal information with any affiliate of Dellla if it is deemed necessary for the performance of a contract you have entered into with us and for other purposes described in the Why and How We Use Your Personal Information section of this Privacy Notice.
  • Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage Service Providers to provide customer relationship management services, security, infrastructure and IT services, our payment processors and suppliers and any third parties who process transactions submitted by us. We do not authorize them to use or disclose your personal information except in connection with providing their services.
  • Partners: As described above, you may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing our service to you and providing information about the availability of our service.
  • Business transfers: In connection with any reorganization, restructuring, merger, acquisition, take over or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Notice.
  • Whenever in the course of sharing information we transfer your personal information to other countries, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection having the force of law in Nigeria.

Retention of Your Personal Information

We will not disclose, for commercial gain or otherwise, your personal information other than as set out in this Privacy Notice or with your consent. We may disclose or share your personal information to or with any of the following for certain purposes:

  • We retain all personal information which we collect from you unless there is a valid technical, legal or business reason for us to delete, destroy or de-identify it (“retained information”). We will keep all retained information as long as your account with us remains active or as long as you access our app.
  • When you permanently deactivate/delete your account, we will only retain your personal information for as long as necessary to fulfil the purposes such as satisfaction of any legal, regulatory, accounting, reporting requirements, for the establishment or defense of legal claims (“retention period”). After the retention period, we will delete/destroy your personal information in accordance with the applicable laws. To determine the appropriate retention period for your personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and the applicable legal requirements. If you would like to know more about the retention periods we apply to your personal data, please contact our Data Protection Officer.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. It is our policy to respect your rights and we will act promptly and in accordance with any applicable law, rule or regulation relating to the processing of your personal information.

Details of your rights are set out below:

  • Right to be informed about how your personal information is processed: you have a right to be informed about how we will use and share your personal information. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language. Please refer to the Why and How We Use Your Personal Information section of this Privacy Notice to see how we will use your personal information.
  • Right to access personal information: you have a right to obtain confirmation of whether we are processing your personal information, access to your personal information and information regarding how your personal information is being used by us, right to request a copy of the Personal Data that we hold about you. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of the request. Please note that there are exceptions to this right such as where making the data available to you would reveal Personal Data about another person or if we are legally prevented from disclosing such data or if there is no basis for your request, or if your request is excessive.
  • Right to have inaccurate personal information rectified: you have a right to have any inaccurate or incomplete personal information rectified. If we have disclosed the relevant personal information to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible.
  • Right to have personal information erased in certain circumstances: you have a right to request that certain personal information held by us is erased. This is not a blanket right to require all personal data to be deleted. We will consider each request carefully in accordance with the requirements of the applicable data protection law.
  • Right to restrict processing of personal information in certain circumstances: you have a right to block the processing of your personal information in certain circumstances. This right arises if you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead or if the personal data is no longer required by us, but you require the personal data to be retained to establish, exercise or defend a legal claim.
  • Right to data portability: in certain circumstances you can request to receive a copy of your personal information in a commonly used electronic format as well as the right to request that the personal information be transferred to another person. This right only applies to personal information that you have provided to us (for example information provided to us when signing up or subscribing to our service). Information about you which has been gathered by monitoring your behavior will also be subject to the right to data portability.

You may exercise any of your rights by contacting our Data Protection Officer. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may refuse to comply with your request in appropriate circumstances prescribed by the applicable data protection law.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Security

All personal information you provide to us is stored on our secure servers or those of our trusted Partners. We implement appropriate technical, organizational, administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Once we have received your personal information, we will use the procedures and security features described above to prevent unauthorized access of your personal information.

From time to time, we review our information collection, storage, and processing practices including the technical, organizational, administrative, logical, and physical security measures to keep up to date with industry best practice.

Protecting your personal data

We take all reasonable steps to ensure that both we and our third-party service providers protect your Personal Data. We use advanced technology, secure third-party suppliers and well-defined employee practices to help ensure that your Personal Data is processed promptly, accurately, completely and securely. We also ensure our staff are aware of their information security obligations, providing training, and limiting access to your Personal Data to staff who have a genuine business need to know.

We also take reasonable steps to protect your Personal Data from loss or destruction and have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach in the unlikely event that one occurs.

Changes to this Privacy Notice

We will update this Privacy Notice from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of our service after any such updates take effect will constitute acknowledgement and acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Notice, you may cancel your use of our service.

Complaints

If you have a concern about the way we process your personal information, please send an email to our Data Protection Officer stating your name, contact address such as your email and phone number, what you think we have done wrong, and all relevant information and evidence in support of the complaint. While we try to respond as promptly as possible, resolution time will vary depending on the nature of the complaint. You will be notified of the outcome of your complaint as well as any action taken.