Last updated on March 27, 2019
1. Who are we?
2. What data do we collect about you?
3. Do we collect data from children?
4. Why do we process your personal data?
6. Your rights
7. Communication and marketing
8. Who do we share your data with?
9. International transfers
10. How long do we store your data?
11. Technical and organisational measures and processing security
12. Links to third-party websites
15. Contact details
Services mean any products, services, content, features, technologies, or functions, and all related websites, applications, and services offered to you by us.
Platform means the websites, mobile apps, mobile sites or other online properties through which we offer our Services.
1. Who are we?
KOMBACK IS AN ONLINE Marketplace BASED IN USA AND Africa (NIGERIA).
2. What data do we collect about you?
We collect personal data to provide and improve our Services and operate our Platform. The types of data we collect, how we collect it and why are described below
2.1.1. Data provided through direct interactions
Depending on the choices you make when registering for or during the process of engaging our Services, you may opt to give the following personal data:
- your name;
- e-mail address;
- mobile number;
- your credit card details;
- preferences (such as the preferred method of communication);
- Current city
- profile picture
- user ID
- list of friends/followers (such as on a social media account)
- Facebook or Google account details; and
- Any other information you choose to provide in connection with your account
In addition, when you use our chat feature to communicate with other users, we collect the information that you provide and communicate with other users through this feature.
Please note that your user name and your profile picture will be made available to the other users and the public when you engage with some of our Services. For example, when you post a product some of your information will be available to Platform users, so you should exercise discretion when using the Services to post personal data.
Please note, other users and community members may be able to collect your information through the Platform. While we protect the information you share with KOMBACK, we are not responsible for protecting such information that you choose to share with third parties through our Services and Platform (e.g., sending your telephone number to another user through the Services).
You may choose to access some parts of the Services as a guest. However, some features are reserved for users with registered accounts and guests may not be able to access and use all content and features of the Services.
2.1.2. Data we collect automatically when you use our Services
When you interact with our Platform or use our Services, we automatically collect the following information about you:
- Device Information. We collect device-specific information such as operating system version and unique device identifiers. For example, we collect the IMEI number of your device and name of the mobile network that you are using. We associate the device identifiers with your KOMBACK account.
- Location information. Depending on your device permissions, if you post an item on our Platform, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and mobile towers. Your location data allows you to see user items near you and helps you in posting items within your location.
- Client and Log data. Technical details, including the Internet Protocol (IP) address of your device, time zone, and operating system. We will also store your login information (registration date, date of last password change, date of last successful login), type and version of your browser.
- Usage Information. We collect information about your activity on our Platform which includes the sites from which you accessed our Platform, date and time stamp of each visit, advertisement banners or content that you clicked, your interaction with such advertisements, clickstream information, duration of your visit and the order in which you visit the content on our Platform.
Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Platforms. Please note that not all tracking will stop even if you delete cookies.
Some browsers have a Do Not Track (“DNT”) feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to DNT features.
2.1.3. Data from third parties or publicly available sources.
To the extent permitted by law, we may also collect personal data from third parties including from publicly available sources and third-party companies or entities.
We may collect personal data about you from our group companies.
3. Do we collect data from children?
Our Services are not intended for children under 13 and we do not knowingly collect data from anyone under 13. If a parent or guardian becomes aware that his or her minor child of any age has provided us with personal data without their consent, please contact us at [email protected] If we become aware that a minor under 18 has provided us with personal data without the consent of their parent or guardian, we will delete it immediately.
4. Why do we process your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the Terms of Service contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests to improve our Services and to provide you a safe and secure Platform.
- Where we need to comply with a legal or regulatory obligation.
In certain circumstances, we may also process your personal data based on your consent. If we do this, we will let you know the purpose and the category of personal data to be processed at the time we seek your consent.
We have set out below a description of the ways we use your personal data.
4.1 For providing access and delivering Services through our Platform
i. If you log in using your email id, we use your first name and last name and/or e-mail address to identify you as a user and provide access to our Platform.
ii. If you log in using your Google or Facebook account, we use your first name and last name from your Google or Facebook profile and the e-mail address to identify you as a user on our Platform and to provide you access to our Platform.
iv. We use your e-mail address to make suggestions and recommendations to you about our Services that may be of interest to you.
We process the above information for the adequate performance of our contract with you and on the basis of our legitimate interest in providing the Services and undertaking marketing activities to offer you Services that may be of your interest.
4.2 For improving your experience on the Platform
We use clickstream data to
- offer you tailored content, such as giving you more relevant search results when using our Services.
- to determine how much time you spend on our Platform and in what manner you navigate through our Platform in order to understand your interests and to improve our Services based on this data. For example, we may provide you with suggestions on content that you can visit based on the contents you have clicked.
- to monitor and report the effectiveness of the campaign delivery to our business partners and for internal business analysis.
- to prevent repeatedly displaying the same items to the same user.
We use your location data for the following purposes:
- to compile anonymously and aggregated information about the characteristics and behavior of KOMBACK users, including for the purposes of business analysis, segmentation and development of anonymous profiles.
- to enhance the performance of our Services and to personalise the content we direct towards you. For example - with the help of location data we display ad listings which are in your vicinity to improve your buying experience.
- to measure and monitor your interaction with the third-party advertisements banners we place on our Platform.
We process the above information on the basis of our legitimate interest to improve your experience on our Platform and market our Services and for adequate performance of our contract with you.
4.3 To provide you a safe and secure Platform
i. We use your email address and unique device identifiers to administer and protect our Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting and hosting of data).
ii. We analyze your communications done through our chat feature for fraud prevention and to promote safety by blocking spam or abusive messages that may have been sent to you by any other user.
We process the above information for the adequate performance of our contract with you, to improve our services and on the basis of our legitimate interest to prevent fraud.
In addition, we may aggregate and/or de-identify data about visitors to our Platforms and use it for any purpose, including product and service development and improvement activities.
5. Your rights
You may have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please go to your account/privacy settings or contact us.
Right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Right to request correction of any of the data we have about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where you believe our use of the data is unlawful; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that for certain purposes we may be legally obligated to retain your data.
Right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which you believe impacts your fundamental rights and freedoms. You may also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may deny your request if we have compelling legitimate grounds to process your information.
Right to request for the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a commonly used format.
Right to withdraw your consent to the processing of your personal data at any time. This does not affect the legality of any processing we have already carried out based on the consent given previously.
No fee usually required: 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. Alternatively, we may refuse to comply with your request in these circumstances.
Time to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
In addition to these rights, you have the right to make a complaint at any time to your Data Protection Authority.
However, before you make a complaint to the data protection authority, we would appreciate the chance to deal with your concerns in the first instance, please reach out to our Data Protection [email protected]
There may be instances where we cannot grant you access to the personal data we hold about you. If that happens, we will give you written reasons for any refusal. Where permitted by law, we may also disagree with your request to correct or update your personal data (for example, if we consider that your proposed update is incorrect).
In addition to the foregoing, you may have additional rights depending on your local law.
We reserve the right to verify your identity in connection with any requests regarding personal data to help ensure that we provide the information we maintain to the individual to whom it pertains, and allow only that individual or their authorized representatives to exercise rights with respect to that information. We will try to comply with your request as soon as reasonably practicable. Please note that your exercise of these rights is subject to certain exemptions and our interests.
6. Communication and marketing
We may communicate with you by email or in app notification in connection with our Services/Platform to confirm your registration, to inform you in case your product listing has become live/expired and for other transactional messages in relation to our Services.
We (or our service providers and advertising partners) may send you direct marketing communications and information about our Services that we consider may be of interest to you. We will provide an option to unsubscribe or opt out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “contact details” section below.
7. With whom do we share your data?
We may share your personal data with the parties set out below for the purposes set out above.
Corporate affiliates: We may share your data with other KOMBACK group companies which are located within as well as outside EEA.
Third Party Service Providers: We share your data with third party service providers that help us deliver certain aspects of our Services. For example, we use cloud storage facilities to store our data, we use customer support software providers to administer and respond to user inquiries and we use payment processors for certain services within the Platform. We need to share your data with these third parties otherwise we would not be able to provide the Service. Service providers may be located inside or outside of the “EEA”.
Advertising and analytics providers: In order to improve our Services, we will sometimes share your non-identifiable information with analytics providers that help us analyse how people are using our Platform/Service. We also partner with demand side platforms who buy our ad placements through auction and Double Click etc. We share your information with them in a deidentified and aggregated form for monitoring and reporting the effectiveness of the campaign delivery to our business partners and for internal business analysis.
Law enforcement authorities, regulators, grand juries, courts and tribunals, governmental or public bodies and others: We may disclose your data, including your personal data, to law enforcement authorities, regulators, grand juries, courts and tribunals, governmental or public bodies and other relevant third parties as we believe necessary or appropriate to protect people or property, to protect our services, rights or property, to comply with legal or regulatory requirements and to respond to legal process, law enforcement requests and requests from other public and government authorities.
Publicly available information: When you post an item for sale using our Services, you may choose to make certain personal data visible to other KOMBACK users. This may include your first name, last name, your email address, your location and your contact number. Please note, any information you provide to other users can always be shared by them with others so please exercise discretion in this respect.
8. International transfers
We take reasonable steps to ensure that the overseas recipients of your personal data do not breach the privacy obligations relating to your personal data. Where required by certain jurisdictions, we will transfer your information subject to jurisdiction-approved safeguards, such as standard contractual clauses.
9. How long do we store your data?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Please note that we often need to retain certain data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
10. Technical and organisational measures and processing security
We maintain administrative, technical and physical safeguards designed to protect personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Please note, despite the measures we have implemented to protect your data, the transfer of data through the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorised third parties.
11. Links to third-party websites
12. User submitted content
Some features of the Services allow you to post content on our Platform or social media pages, such as photos. We do not have control over how other users who have access to the Platform will use any content you post publicly or send to them privately. We urge you to exercise discretion when sharing personal information with other users.
We may also use any ad you post on KOMBACK, including the uploaded photo or image of the product as well as other data (including user name and location) associated with the ad, for our own advertising purposes, including social media, Facebook ads, newsletters and ads for any media.
To help protect your privacy, we allow only limited access to other users’ contact information as necessary to fulfill your transactions and collect payments. However, when users are involved in a transaction, they may have access to each other’s name, user ID, email address, and other contact information.
13. California privacy rights
California law permits residents of California to request notice of how their information is shared with third parties for direct marketing purposes or to opt out of such sharing. If you are a California resident and would like a copy of this notice or to opt out, please submit a written request to [email protected]
14. Contact details
If you have any questions or comments regarding this policy or wish to contact our Data Protection Officer, please contact us by email at [email protected] or by mail at P.O.BOX 66 AJALLI ORUMBA NORTH LGA ANAMBRA STATE. Please do not send sensitive information to us by email, as email communications are not always secure.