Users of Xwift Nigeria's ("Xwift," "we," "us," or "our") platform may order meals from the Xwift App and have them delivered right to their door ("Services"). Transparency is one of Xwift's major beliefs, and we owe it to you (the "User") to explain how we manage your personal information. When combined with other information, personal information may be used to identify you as a live human being. Personal information can also be unique information or aggregated data. You should carefully read this privacy notice ("Notice") to comprehend your rights, our obligations regarding managing your personal data, and our Terms of Use. Please email [email protected] if you have any questions concerning either of these papers.
2. Version control for documents
This Notice may be amended and subsequently reviewed in response to changes in our operating operations, new laws, or other exigencies. The authorized officers must approve any modifications made to this Notice.
3. The reason we require your private information
We mainly gather information about you so that we can
3.1. provide Xwift Services and let you get the best meal delivery service;
3.2. advise you of available products;
3.3. uphold our legal and regulatory responsibilities;
3.4. expand, upgrade, amplify, change, supplement, and further develop our services;
3.5. confirm your identify, that the information supplied is accurate, and stop fraud;
3.6. provide you customer service;
3.7. to safeguard you and to aid in the investigation or prevention of fraud;
3.8. For any further reason with your permission.
4. Consent
We mainly gather information about you so that we can:
By choosing to utilize our platforms, services, features, technologies, or functionalities made available on our website or other digital platforms, or by visiting one of our offices for business or pleasure, you agree to the terms of this privacy notice by clicking the "accept" button. If you change your mind, you can opt out by contacting us at [email protected]. The Xwift Services are governed by this privacy notice, and you are not permitted to use our Services if you are uncomfortable with the way we handle your data.
5. How we obtain information about you
We obtain information about you directly from you, automatically through your use of our Services, and, occasionally, with your permission, from third parties.
We require your information whenever you fill out a form, take part in a campaign or contest, contact customer care, or otherwise interact with us so that we may better understand your needs and meet them by offering you the services that are right for you.
Along with the information we directly collect, we could also obtain information about you from other sources. Examples of information we could get from external sources include updated delivery or payment details needed to update our records, purchase or redemption details, customer support and enrollment details, as well as information on purchases or redemptions.
6. What private data do we gather about you?
We only gather the data required for you to enjoy our services and register for an account with Xwift.
The data we gather consists of:
6.1 Your name, age, gender, address, zip code, email address(es), and mobile contact number are personal data related to your account. If you give us information on third parties linked to you or their use of our services, we may also gather their names, addresses, phone numbers, and other details;
6.2. information about when and where you request our services, as well as information about any orders you place or receive related to our services, including information about your location (which may be determined using the data gathered in subsection (8.3) of this section below);
6.3. information on the computer or other mobile device that any of our Platforms or applications have been installed on or accessed from, such as the operating system and version, serial numbers, and other unique device identifiers;
6.4. personal data gathered and kept by financial or third-party payment systems regarding your potential payment method (including credit card information) and any payments you might make for our services or other products or services you order or obtain that are associated with the services we offer;
6.5. Your relationship to other people whose personal information we may gather or keep, such as relatives, friends, or referral sources;
6.6. information on your membership in any loyalty programs connected to or made accessible by us or any of our partners, affiliates, or subsidiaries;
6.7. Any information that you permit the social media platform and/or the other third-party website to share with us if you utilize social media to communicate with us or other services offered by third parties through the Xwift;
6.8 Any address you may use for delivery services,
6.9. Demographic data, including age, marital status, ethnicity, occupation, and income, if you reply to optional survey queries.
7. How we make use of your personal data
Your personal information will be gathered in order to provide you with Service that is effective, satisfying, and secure. Your information could be utilized for the following purposes:
7.1. provide you our services;
7.2. Communicate with you,
7.3. alert you to any significant data or stuff you might be interested in;
7.4. for development and research;
7.5. Ensure and improve User and pertinent third parties' safety and security;
7.6. for customer service functions including enabling replies to your questions or grievances;
7.7. carry out market research and consumer surveys;
7.8. engage in marketing, advertising, and promotional efforts;
7.9 Complete our obligations or assert our rights in court;
7.10. encourage user-to-user contact;
7.11. authenticate users ;
7.12. look into and stop potentially fraudulent and unlawful behavior;
7.13. handle and enable payment for services that we facilitate;
7.14. resolve disagreements and grievances;
7.15. adhere to laws, rules, and regulations, including helping with government and law enforcement investigations;
7.16. report on regulatory compliance to regulatory agencies or government bodies;
7.17. Use or disclose it in accordance with other legal authorizations or approved uses.
7.18. reach you at any time by the phone number, email address, or other method you have provided.
8. Independent technologies
On occasion, we reserve the right to offer or incorporate third-party items or services on our Platform. These external websites each have their own privacy rules. As a result, we are not accountable or responsible for the actions or content of any connected websites. Nevertheless, we work hard to preserve the integrity of our Platform and appreciate hearing from you regarding these sites.
9. Location Services
We will ask you to select whether to grant Xwift access to your location and under what conditions before you may use our Platform for the first time. In order for us to provide you our Services, location services must be enabled. On your smartphone, you may alter these settings whenever you want. With your consent, we will use your IP address, GPS, and other sensors to determine your position in order to deliver our services.
We may gather Wi-Fi metadata from your device, such as the Media Access Control (MAC) address of your device, the Set Service Identifier (SSID) and signal strength of Wi-Fi networks in your device's range, the GPS location of your device in relation to Wi-Fi networks in your device's range, and the time the metadata was collected. Our main purpose in using the data is to suggest eateries to you that are nearby.
10. Interaction
Once the food has been ordered, the Xwift Platform enables you to phone or message us anonymously to help with the delivery services. If you use this feature, you agree that Xwift may monitor and record all voice and text communications sent and received through the Xwift Platform for security, monitoring, and quality assurance, fraud prevention, and for analytical purposes to enhance our services, including customer service, policies, and procedures, and/or to investigate and resolve disputes and complaints. By utilizing this feature, you agree that Xwift may record and use your messages in accordance with this Privacy Notice.
11. Utilizing social media
In order to engage with users and facilitate interactive information exchange, Xwift utilizes third-party websites like Facebook and Twitter. We advise you to carefully read any terms and conditions (including privacy statements or policies) that apply to any third-party web services regarding the handling and management of your personal information because they might use it differently and for different purposes than Xwift does.
We advise you to contact them by direct or private messaging, email, or the customer support hotline in order to maintain the privacy of your personal information.
12. Polls
To help us better understand our Services and make them better, we might ask you to take a survey. If you decide to take part in any optional survey, we may gather demographic data about you, which may contain sensitive information, like your age, marital status, ethnicity, occupation, and income. We may also compile data on your usage patterns and interactions with our services. You agree to the collecting and use of your information by us in line with this privacy notice if you take part in any survey.
13. Your personal information being disclosed
13.1 Xwift won't give out your information to other parties for sale or rent. However, we reserve the right to disclose your information to related corporate bodies, business partners, service providers, or vendors we engage, like customer service providers, in order to help us provide our Services or to carry out data processing on our behalf. These disclosures may be made for any of the reasons listed in section 7 above and for related purposes that you would reasonably expect. These organizations could have a foreign base of operations. Subject to any restrictions in your information permission and settings, we may disclose your information for our regular business objectives, such as processing your purchases and shipping purposes, unless an exception under the Nigerian Data Protection Regulation Legislation applies;
13.2 In relation to any such disclosures, Xwift will adhere to its obligations under the applicable privacy laws, including making commercially reasonable efforts to ensure that such third parties only use your personal information as reasonably necessary for the purpose of disclosure and in a way that complies with the privacy laws. By inserting appropriate privacy and confidentiality terms in our contract with such third parties, for instance (where financially feasible).
13.3 While signed into your account, you may change your privacy and information rights and settings at any time via the Xwift mobile application.
14 Disclaimer.
After payment has been confirmed, Xwift is entirely responsible for purchasing the client's product and delivering it to the address the customer has specified.
15. Security and Storage
We utilize administrative, technological, and physical security measures to safeguard your data against loss, theft, and unauthorized access personal data that we gather is stored in electronic databases on servers in Ireland that are run by our affiliated companies and/or service suppliers.
To preserve and protect the information we gather about you, as well as to lower the risks of loss, misuse, disclosure, modification, and unauthorized access to your personal information in our possession, we have implemented necessary physical, electronic administrative policies and safeguards. Data isolation technology is used to keep encrypted personal information and related data on servers. We restrict access to personal information to those who work for us, for our affiliated companies, or for our contracted service providers and who, in our judgment, need access to it to carry out their jobs or to provide you with the goods or services that you or we have requested. Firewalls, data encryption, physical access restrictions for our data centers, and information access authorisation controls are a few of the security measures we employ. At both the technological and operational levels, we have put in place strict controls and security precautions to prevent unauthorized access to your information. Your Personal Data is transmitted securely over our website thanks to Secure Sockets Layer (SSL). When visiting our website, the URL address bar should display the padlock sign. Additionally, the URL will begin with https://, signifying a secure website. Between two places, such as your PC and the connected server, SSL adds encryption. All session-related data will be encrypted before to transmission and decoded upon receipt.
16. Retention time
The following length of time shall apply to the retention of personal data of Xwift users, according to the rules of the NDPR 2019:
16.1. five (5) years following the last time our digital platform was used actively;
16.2 When a user's personal information is erased when a user's relative presents proof of death;
16.3. As soon as the Xwift user or his or her legal guardian requests it in the following circumstances:
In addition, the user is not the subject of any legal proceedings or investigations that would call for the preservation of the personal data that is being asked to be destroyed.
17 Direct marketing.
On occasion, we could get in touch with you personally to share relevant information and exclusive offers from our company and others. When you "Subscribe" to receive marketing messages from Xwift, you agree that we may send you such material through telemarketing, email, SMS, and other digital media.
You can choose not to receive marketing communications from us at any time by contacting us or using the "Unsubscribe" option in the marketing emails and texts. Even if you choose not to receive commercial communications from us, we may nevertheless get in touch with you or send you non-promotional materials, such as invoices for delivery services and restaurant directory reservations made via Xwift.
18. References to related websites
Links to third-party websites, third-party services, or web addresses may be included in Xwift and communications we send out. While we take the necessary precautions when publishing links to any third-party services, it is ultimately up to you whether or not to access those links or use those services. Regarding the correctness, comprehensiveness, sufficiency, and reliability of any information, data, views, photos, comments, or suggestions offered by such links, Xwift makes no representations or guarantees. Third-party websites, their content, and their data usage and retention policies and practices are not within the control of or for which Xwift is responsible.
19. Information on your personal data
19.1 You have the right to request any of the following in relation to your personal data that is in our possession:
In accordance with the Freedom of Information Act and other applicable laws, we must provide you with the following: confirmation that we collect and use personal information about you; access to the personal information we have about you; correction of or updates to the personal information we have about you; anonymization, blocking, or erasure of your personal information that is no longer required for us to provide services to you or is no longer necessary, portability of data. In some cases, you may expressly request that we give a third-party service provider a copy of the personal information we have on file about you in a format that is structured, machine-readable, and generally accepted, as determined by us, or that we otherwise comply with the requirements of the relevant law; deletion or erasure of personal information we have on file about you in cases where we relied on your consent to use your personal information, unless an exception applies, such as when the information was used for direct marketing purposes, withdraw your permission when we use and distribute your personal information with your permission;
19.2 You can reach us to make any of the aforementioned requests. When you attempt to make any of these requests, we may require you to complete a form and present acceptable identification in order to confirm your identity.
19.3 You may expect a response from us as soon as we can. Simple requests may receive a response within 2–3 days, however, more complex requests may take up to 20 working days to receive one. We will let you know if we are unable to fulfill your request for any reason, such as that we are not able to do so or are not obligated to under the applicable privacy laws.
19.4 If the personal information we provide in response to your request contains information that is the personal information of a third party, is confidential, or on which we have copyright (such as transcripts or recordings of customer service call records), we may redact that information where reasonably necessary. You are required to keep that information private and not disclose it to the public, including by posting it on social media, without our prior written consent.
19.5 Users can also remove their Xwift accounts. In accordance with our record-keeping procedures and duties as a facilitator of online restaurants and delivery services (where applicable), even if you remove your account, we will continue to preserve your personal information.
19.6. Xwift may keep your personal information after you ask us to delete it or de-identify it if: there is an unresolved account issue, such as an unpaid credit on your account or an unresolved claim or dispute; we are required to by any applicable law; and/or necessary for our legitimate business interests, such as fraud prevention and enhancing users' safety and security
19.7. When personal information is no longer needed, we shall make a reasonable effort to destroy it from our systems or de-identify it.
20. Updates to our privacy notice
We reserve the right to modify and amend our Privacy Notice and information handling procedures at any time and for any reason. Both the Xwift website and mobile apps provide a link to our privacy notice.
If we make substantial changes to our privacy notice, we'll let you know about them by email or the Xwift application. Additionally, we reserve the right to update this privacy notice at any time by publishing a new version on our website or mobile app. Seven days following publication, the updated version will go into effect.
We advise you to routinely examine this Privacy Notice so you are aware of any updates.
21. Governing law
The Nigeria Data Protection Regulation 2019 and any pertinent Nigerian laws, rules, or agreements that apply to Nigeria have prompted the creation of this privacy notice. Any part of this Notice that is found to be at odds with a rule, regulation, or convention will be subject to the rule, regulation, or convention that takes precedence.
Any User of Xwift's services is covered by this privacy notice, as is anybody else who contacts Xwift or gives the company their information in any other way.