1. Definitions

 For the purposes of this Privacy Policy,

“Personal Data” means any information relating to an identified or identifiable natural person

“Processing” refers to any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion

“Customer” refers to any organization that uses ALK

“Authorized Users” are individuals permitted by a Customer to access the Service. 

“Customer Data” includes all data, including Personal Data, submitted to or processed through the Service by or on behalf of a Customer

2. Information We Collect

We may collect the following types of information:

• Personal Information: Name, email address, contact details, and other identifying information.

• Usage Data: Information about your interactions with ALK, such as log data, device information, and cookies.

• Third-Party Data: Information received from third-party services if you choose to connect your ALK account to them.
  
  

3. How We Use Your Information

We use your information to:

• Provide and improve ALK services.

• Personalize user experiences.

• Communicate with you about updates and support.

• Comply with legal obligations.
  
  

4. Legal Bases for Processing

Where applicable, we rely on recognized legal bases for processing Personal Data.

Processing may be necessary for the performance of a contract, particularly where Personal Data is required to provide the Service to Customers and their Authorized Users.

In certain instances, processing is carried out to comply with legal obligations, including regulatory, tax, or law enforcement requirements.

We may also rely on legitimate interests, such as improving the Service, ensuring security, and preventing fraud, provided such interests do not override the rights and freedoms of data subjects.

Where required, we obtain consent before processing Personal Data, particularly in relation to optional features or marketing communications. Such consent may be withdrawn at any time.

These legal bases are applied in a manner consistent with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the Nigeria Data Protection Act 2023 (NDPA), and are intended to ensure that all processing activities carried out by Wamiri are grounded in recognized standards of lawfulness, fairness, and transparency. 

5. Sharing of Information

We do not sell your personal information. However, we may share your information with:

• Service Providers: Third-party vendors who assist us in operating ALK while adhering to strict data protection agreements.

• Legal Authorities: If required by law or to protect our rights.

• Business Transfers: In the event of a merger, sale, or asset transfer, with appropriate safeguards in place.
  
  

6. Data Security

We take the security of your data seriously and implement industry-standard encryption, access controls, and monitoring to protect against unauthorized access or breaches. While we employ rigorous measures, no system is completely impervious to threats. We continuously improve our security protocols to keep your data safe.

7. Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements.

Where we process Personal Data on behalf of Customers, retention periods are determined primarily by the Customer, subject to applicable legal requirements.

Certain data may be retained for longer periods where required for compliance, security, or legitimate business purposes. Data may also be retained in aggregated or anonymized form for analytical and improvement purposes.

8. International Data Transfers

Given the global nature of the Service, Personal Data may be transferred to and processed in jurisdictions outside the country in which it was collected.

We take appropriate steps to ensure that such transfers comply with applicable data protection laws. These safeguards may include the use of standard contractual clauses, data transfer agreements, or reliance on adequacy decisions where available.

By using the Service, you acknowledge that such cross-border transfers may occur.

9. Representative

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

• European Union (EU)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/19594248590.

10. Your Rights

You have the right to:

• Access and update your personal information.

• Request the deletion of your data, subject to legal and contractual obligations.

• Opt out of certain data collection practices while maintaining access to key services.

• Withdraw consent at any given time, where processing is based on consent.

Requests to exercise these rights may be subject to verification and applicable legal limitations. Where we process data on behalf of a Customer, such requests may need to be directed to the relevant Customer acting as Data Controller.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience. You can manage your cookie preferences through your browser settings.

12. Third-Party Links

ALK may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their policies.

13. Changes to This Policy

We may update this Privacy Policy periodically. We will notify users of significant changes via email or through ALK.

14. Contact Information

For any questions or concerns regarding this Privacy Policy, please contact us at compliance@wamiri.com