Migo Privacy Policy

March 25, 2024

This Privacy Policy applies between you, the User of this product and Migo Technology Services Limited (hereinafter referred to as “Migo” or “us” or “we” or “our”). We take the privacy of your information very seriously. This Privacy Policy applies to your use of any and all Data collected by us or provided by you in relation to your use of Migo. Please read this Privacy Policy carefully.

1. DEFINITIONS AND INTERPRETATION

  1. In this Privacy Policy, the following definitions are used:

Data: collectively all information that you submit to Us. This definition incorporates, where applicable, the definitions provided in the Data Protection Regulation 2019 and in General Data Protection Regulation;

Cookies: a small text file placed on your computer when you visit certain parts of the Migo website and/or when you use certain features of the website. Details of the cookies used by this website are set out in clause 11 below;

User or You: any third party that accesses the Migo website and is not either (i) employed by Us and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Us and accessing the website in connection with the provision of such services; and

Website: the website that you are currently using, www.migo.money, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

Product: Migo

  1. In this privacy policy, unless the context requires a different interpretation:
  2. the singular includes the plural and vice versa;
  3. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

iii. a reference to a person includes individuals, firms, companies, government entities, trusts, and partnerships;

  1. “including” is understood to mean “including without limitation”;
  2. reference to any statutory provision includes any modification or amendment of it; and
  3. the headings and subheadings do not form part of this privacy policy.

2. SCOPE OF THIS PRIVACY POLICY

This privacy policy applies only to the actions of us and you with respect to Migo Technology Services Limited.

3. DATA COLLECTED

We may collect the following Data, which includes personal Data, from you:

  1. Name;
  2. Contact Information such as telephone numbers;
  3. Financial information such as credit/debit card numbers;
  4. IP address (automatically collected);
  5. Web browser type and version (automatically collected);
  6. Operating system (automatically collected); and
  7. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected)

in each case, in accordance with this Privacy Policy.

4. USE OF DATA

  1. For purposes of the Data Protection Regulation 2019, We are the “Data controller”.
  2. Your acceptance of this Privacy Policy is an acceptance of the provisions therein.
  3. Unless we are obliged or permitted by law to do so, and subject to any third-party disclosures specifically set out in this Privacy Policy, your Data will not be disclosed to third parties. This includes our affiliates and/or other companies within our group.
  4. All personal Data is stored securely in accordance with the principles of the Data Protection Regulation 2019 and General Data Protection Regulation. For more details on security see clause 10 below.
  5. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our product. Specifically,  Data may be used by us for the following reasons:
  6. internal record keeping;
  7. improvement of our products/services;

iii. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customize or update the product;

in each case, in accordance with this Privacy Policy.

  1. We use the information we collect to provide, maintain, protect and improve our services to develop new ones and to protect us and our users.
  2. We use your Personal Information to process and administer details of your account, to communicate with you, to provide you with opportunities, and to keep you up to date with new Migo Technology Services Limited developments.
  3. We also use and analyze the information we collect so that we can administer, support, improve and develop our business. We may contact you using the information you voluntarily provide. It’s important for you to understand that:
  4. Except as set forth herein, we do not share your information with unaffiliated companies for marketing purposes without your prior permission.
  5. Unless you opt-out, we may share information about you among companies affiliated with us to inform you about additional products, services or promotions that may be of interest to you.

iii. If you contact us for troubleshooting, we may also keep a record of that fact to

  1. better serve you and other customers in the future.

5. THIRD-PARTY SERVICES

We may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the product. The providers of such services do not have access to certain personal Data provided by Users of this product.

6. LINKS TO OTHER WEBSITES

We may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

7. CHANGES OF BUSINESS OWNERSHIP AND CONTROL

  1. We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Migo Technology Services Limited. Data provided by you will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
  2. We may also disclose Data to a prospective purchaser of our business or any part of it.
  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

8. CONTROLLING USE OF YOUR DATA

Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

  1. use of Data for direct marketing purposes; and
  2. sharing Data with third parties.

9. FUNCTIONALITY OF THE PRODUCT

  1. To use all the features and functions available on the product, you may be required to submit certain Data.
  2. You may restrict your internet browser’s use of Cookies. For more information see clause 11 below.

10. SECURITY

  1. Data security is of great importance to Migo and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this product.
  2. If password access is required for certain parts of the product you are responsible for keeping this password/pin confidential.
  3. We endeavor to do our best to protect your personal data. However, the transmission of information to us over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the product

11. COOKIES

  1. This website may place and access certain Cookies on your computer. We use cookies to improve your experience of using the Website. We have carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  2. All Cookies used by this Website are used in accordance with Nigeria Data Protection Regulation 2019 and General Data Protection Regulation.
  3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
  4. This Website may place the following Cookies:
  5. Strictly necessary cookies.

These are cookies that are required for the operation of this website. They include, for example, cookies that enable you to log into the secure areas of this website.

  1. Analytical/performance cookies.

They allow us to recognize and count the number of visitors and to see how visitors move around this website when they are using it. This helps us to improve the way this website works, for example, by ensuring that users are finding what they are looking for easily.

iii. Functionality cookies.

These are used to recognize you when you return to this website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  1. Targeting cookies.

These cookies record your visit to this website, the pages you have visited and the links you have followed. We will use this information to make this website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

  1. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  2. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalization settings.
  3. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

12. TRANSFERS OUTSIDE THE NIGERIA DATA PROTECTION REGULATION

  1. Data which we collect from you may be stored and processed in and transferred to countries outside of Nigeria. For example, this could occur if our servers are located in a country outside Nigeria or one of our service providers is situated in a country outside Nigeria. We also share information with our group companies, some of which are located outside Nigeria. These countries may not have data protection laws equivalent to those in force in Nigeria.
  2. If we transfer Data outside Nigeria in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy. You expressly agree to such transfers of Data.

13. GENERAL

  1. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.
  2. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other right or remedy.
  4. Where the Parties are unable to resolve any dispute amicably within fourteen (14) days of holding consultations after a dispute arises, such dispute shall be referred to a single arbitrator appointed by mutual agreement of the Parties; provided that where the Parties are unable to agree on a sole arbitrator within five (5) days, such dispute shall be referred to a single arbitrator appointed by the President of the Chartered Institute of Arbitrators Nigeria in accordance with the provisions of the Arbitration and Conciliation Act  Cap. A18 Laws of the Federation of Nigeria 2004. The decision of the arbitrator shall be final and binding on the parties and the unsuccessful party in any such arbitration shall be responsible for the payment of the arbitrator’s fees unless the arbitrator directs otherwise;
  5. This privacy policy is governed by and interpreted according to Nigeria law. All disputes arising under this Privacy Policy are subject to the exclusive jurisdiction of the Nigeria courts.
  6. No limitation clause in this Policy shall avail a Data Controller who is in breach of any provision of this Policy.

14. SECURITY & INFORMATION RETENTION

We employ security measures to protect your Personal Information both online and offline from access by unauthorized persons and against unlawful processing, accidental loss, destruction, and damage. We encrypt many of our services using SSL. We will retain your Personal Information for a reasonable period or as long as the law requires. If you cease to be a user of Migo or any affiliated product, we may retain your Personal Information for our business purposes provided that we will protect all such information about you in accordance with this Privacy Policy.

15. WHAT RISKS DO I TAKE BY SHARING INFORMATION?

Although we allow you to set privacy options that limit access to your personal information, no security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your personal information. We cannot ensure that the information you share on this website will not become publicly available. We are not responsible for third party circumvention of any privacy settings or security measures on this website. You can reduce these risks by using common sense security practices such as choosing a strong password and using up to date antivirus software.

16. THIRD-PARTY SITES

We are not responsible for the practices, privacy policies or the content of third-party sites, services and applications (“Third Party Services”) we link to or you elect to access through the Services, and have no control over the use or protection of information provided by you or collected by those Third Party Services. Whenever you choose to access a Third-Party Service, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third-party, and you should familiarize yourself with the privacy policy provided by that party.

17. WHAT INFORMATION OF MINE CAN I ACCESS?

If you are a customer, you can access information associated with your Account by logging into the Services. Customers and visitors can access and delete cookies through their web browser settings.

18. HOW CAN I DEACTIVATE MY ACCOUNT?

Should you ever decide to deactivate your account, you may do so by emailing support@migo.money. If you deactivate your Account, any association between your Account and information we store will no longer be accessible through your Account.

19. CHANGES TO THIS PRIVACY POLICY

  1. We reserve the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations.
  2. b. You may contact us by email at support@migo.money.

20. LEGAL BASIS FOR PERSONAL DATA PROCESSING

Our legal basis for processing your personal data is based on the following criteria(s)

  • You, the data subject, have given consent to the processing of your personal data for one or more specific purposes,
  • processing is necessary for the performance of a contract to which, you, the data subject are party or in order to take steps at your request prior to entering into a contract.

21. DATA SUBJECT RIGHTS

At any point while Mines.io Nigeria Limited (DBA Migo) are in possession of or processing your personal data, you, the data subject, have the right to:

  • Request a copy of the information that we hold about you
  • Correct the data that we hold about you that is inaccurate or incomplete
  • Ask for the data we hold about you to be erased from our systems/record
  • Restrict processing of your personal data where certain conditions apply
  • Have the data we hold about you transferred to another organisation
  • Object to certain types of processing like direct marketing
  • Object to automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling
  • Judicial review. If Migo refuses your request under rights of access, we will provide you with a reason as to why. And you have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded should there be a third party involved in the processing of your personal data.

22. WHAT SHOULD I DO IF I HAVE MORE QUESTIONS?

All comments, queries, and requests relating to our use of your personal information are welcomed and should be addressed to the email address support@migo.money

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