These definitions should
help you understand this policy. When we say “we,” “us,” “our,” and “Nokmail,”
we are referring to Mycoremobile Nigeria Limited d/b/a Nokmail, a Nigerian
limited liability company. We provide online platforms that you may use to
market to or stay in contact with others, including creating, sending, and
managing emails and other information related to your Subscribers (the
“Services”). When we say “Member,” we are referring to the person or entity
that is registered with us to use the Services. When we say “you,” we are
referring either to a Member or to some other person who visits any of our Websites.
A “Subscriber” is a person you contact through our Services, or a person who
you might choose to contact at some point in the future through the use of our
Services. In other words, a Subscriber is anyone on your Distribution List or
about whom you have given us information. “Personal Information” means any
information that identifies or can be used to identify you or a Subscriber,
directly or indirectly, including, but not limited to, first and last name,
date of birth, email address, gender, occupation or other demographic
information. A “Distribution List” is a list of Subscribers and all associated
information related to those Subscribers (for example, email addresses). We offer the Services on at least our websites https://www.nokmail.net.
This Privacy Policy applies to these specific websites, as well as any other
sites or mobile applications owned or operated by us (each a “Website” and
together the “Websites”). The “Websites” include the Websites themselves, and
any web pages, interactive features, applications, widgets, blogs, social
networks, social network “tabs,” or other online, mobile, or wireless offerings
that post a link to this Privacy Policy, whether accessed via computer, mobile
device, or other technology, manner or means. While providing the Services, and
as described in more detail below, we may collect Personal Information about a
Website visitor, Member, person or email address on or related to a
Distribution List, or Subscriber. We may change this Privacy
Policy at any time and from time to time. The most recent version of the
Privacy Policy is reflected by the version date located at the bottom of this
Privacy Policy. All updates and amendments are effective immediately upon notice,
which we may give by any means, including, but not limited to, by posting a
revised version of this Privacy Policy or other notice on the Website. We
encourage you to review this Privacy Policy often to stay informed of changes
that may affect you, as your continued use of the Website signifies your
continuing consent to be bound by this Privacy Policy. Our electronically or
otherwise properly stored copies of this Privacy Policy are each deemed to be
the true, complete, valid, authentic, and enforceable copy of the version of
this Privacy Policy which were in effect on each respective date you visited
the Website. This Privacy Policy is effective with respect to any data that
we have collected, or collect, about and/or from you, according to our Terms of Use. If you have any questions or comments, or if you want to update,
delete, or change any Personal Information we hold, or you have a concern about
the way in which we have handled any privacy matter, please contact us by email
at: Nokmail (a) Information you voluntarily provide to us: When
you sign up for and use the Services, consult with our customer service team,
send us an email, post on our blog, integrate the Services with another website
or service (for example, when you choose to connect your e-commerce account
with Nokmail), or communicate with us in any way, you are voluntarily giving us
information that we collect. That information may include either your or your
Subscribers’ name, physical address, email address, IP address, phone number,
credit card information, as well as details including gender, occupation,
location, purchase history, and other demographic information. By giving us
this information, you consent to this information being collected, used,
disclosed, transferred to the United States and stored by us, as described in
our Terms of Use and in this Privacy Policy. (b) Information we collect automatically: When
you use the Services or browse one of our Websites, we may collect information
about your visit to our Websites, your usage of the Services, and your web
browsing. That information may include your IP address, your operating system,
your browser ID, your browsing activity, and other information about how you
interacted with our Websites or other websites. We may collect this information
as a part of log files as well as through the use of cookies or other tracking
technologies. Our use of cookies and other tracking technologies is discussed
more below, and in more detail in our Cookie Statement. (c) List and email information: When you add a
Distribution List or create an email with the Services, we have and may access
the data on your list and the information in your email. If a Subscriber
chooses to use the ‘forward to a friend’ (FTF) link in an email campaign you
send, it will allow the Subscriber to share your email content with individuals
not on your Distribution List. When a Subscriber forwards an email to a friend,
we do not store your Subscriber’s email address or their friend’s email
address, and no one is added to any Distribution List as a result of the FTF.
The Member who created the email campaign only sees an aggregate number of
times their email campaign was forwarded by a Subscriber and does not have
access to the email addresses used to share or receive that forwarded content. (d) Information from your use of the Service: We
may receive information about how and when you use the Services, store it in
log files or other types of files associated with your account, and link it to
other information we collect about you. This information may include, for
example, your IP address, time, date, browser used, and actions you have taken
within the application. This type of information helps us to improve our
Services for both you and for all of our users. (e) Cookies and tracking: We and our partners may
use various technologies to collect and store information when you use our
Services, and this may include using cookies and similar tracking technologies
on our Website, such as pixels and web beacons, to analyze trends, administer
the website, track users’ movements around the website, serve targeted
advertisements, and gather demographic information about our user base as a
whole. Users can control the use of cookies at the individual browser level. We
partner with third parties to display advertising on our website or to manage
and serve our advertising on other sites. Our third party partners may use
cookies or similar tracking technologies in order to provide you advertising or
other content based upon your browsing activities and interests. (f) Web beacons: We use web beacons on our
Websites and in our emails. When we send emails to Members, we may track behavior
such as who opened the emails and who clicked the links. This allows us to
measure the performance of our email campaigns and to improve our features for
specific segments of Members. To do this, we include single pixel gifs, also
called web beacons, in emails we send. Web beacons allow us to collect
information about when you open the email, your IP address, your browser or
email client type, and other similar details. We also include Web Beacons in
the emails we deliver for you. We use the data from those Web Beacons to create
reports about how your email campaign performed and what actions your
Subscribers took. Reports are also available to us when we send email to you,
so we may collect and review that information. (g) Information from other sources: From time to
time we may obtain information about you or your Subscribers from third party
sources, such as public databases, social media platforms, third party data
providers and our joint marketing partners. We take steps to ensure that such
third parties are legally permitted or required to disclose such information to
us. Examples of the information we may receive from other sources include:
demographic information, device information (such as IP addresses), location,
and online behavioral data (such as information about your use of social media
websites, page view information and search results and links). We use this
information, alone or in combination with other information (including Personal
Information) we collect, to enhance our ability to provide relevant marketing
and content to you and to develop and provide you with more relevant products
features, and services. For example, we use this information to develop Social
Profiles, a tool that helps you learn about your Subscribers and allows you to
send them more relevant content. (h) Information from the use of our Mobile Apps: When
you use our mobile apps, we may collect certain information in addition to
information described elsewhere in this Policy. For example, we may collect
information about the type of device and operating system you use. We may ask
you if you want to receive push notifications about activity in your account.
If you have opted in to these notifications and no longer want to receive them,
you may turn them off through your operating system. We do not ask for, access
or track any location-based information from your mobile device at any time
while downloading or using our Mobile Apps or Services. We may use mobile
analytics software to better understand how people use our application. We may
collect information about how often you use the application and other
performance data. We may use and disclose
Personal Information only for the following purposes: (a) To promote use of our services to you and others. For
example, if we collect your Personal Information when you visit our Website and
do not sign up for any of the Services, we may send you an email inviting you
to sign up. If you use any of our Services and we think you might benefit from
using another Service we offer, we may send you an email about that. You can
stop receiving our promotional emails by following the unsubscribe instructions
included in every email we send. In addition, we may use information we collect
in order to advertise our Services to you or suggest additional features of our
Services that you might consider using. In addition, we may use your Personal
Information to advertise our Services to potential or other users like you. (b) To send you informational and promotional content in accordance
with your marketing preferences. You can stop receiving
our promotional emails by following the unsubscribe instructions included in
every email. (c) To bill and collect money owed to us by our Members. This
includes sending you emails, invoices, receipts, notices of delinquency, and
alerting you if we need a different credit card number. We use third parties
for secure credit card transaction processing, and we send billing information
to those third parties to process your orders and credit card payments. To
learn more about the steps we take to safeguard that data, see Section 14
below. (d) To send you System Alert messages. For
example, we may inform you of temporary or permanent changes to our Services,
such as planned outages, new features, version updates, releases, abuse
warnings, and changes to our Privacy Policy. (e) To communicate with our Members about their account and provide
customer support. (f) To enforce compliance with our Terms of Use and applicable law. This
may include developing tools and algorithms that help us prevent violations. (g) To protect the rights and safety of our Members and third parties,
as well as our own. (h) To meet legal requirements, including
complying with court orders, valid discovery requests, valid subpoenas, and
other appropriate legal mechanisms. (i) To provide information to representatives and advisors,
including attorneys and accountants, to help us comply with legal, accounting,
or security requirements. (j) To prosecute and defend a court, arbitration, or similar legal
proceeding. (k) To respond to lawful requests by public authorities, including to meet
national security or law enforcement requirements. (l) To provide, support, and improve the Services we offer. This
includes our use of the data that our Members provide us in order to enable our
Members to use the Services to communicate with their Subscribers. This also
includes, for example, aggregating information from your use of the Services or
visit to our Websites and sharing this information with third parties to
improve our Services. This might also include sharing your information or the information
you provide us about your Subscribers with third parties in order to provide
and support our Services or to make certain features of the Services available
to you. When we do have to share Personal Information with third parties, we
take steps to protect your information by requiring these third parties to
enter into a contract with us that requires them to use the Personal
Information we transfer to them in a manner that is consistent with this
policy. (m) To provide suggestions to you. This includes
adding features that compare Members’ email campaigns, using data to suggest
other publishers your Subscribers may be interested in, or using data to
suggest products or services that you may be interested in or that may be
relevant to you or your Subscribers. Some of these suggestions are generated by
use of our Data Science Projects. For more information about our use of cookies
and other tracking technologies for this purpose, and instructions about how to
opt out of having data collected through the use of cookies, please see our
Cookie Statement. (n) To transfer your information in the case of a
sale, merger, consolidation, liquidation, reorganization, or acquisition. In
that event, any acquirer will be subject to our obligations under this Privacy
Policy, including your rights to access and choice. We will notify you of the
change either by sending you an email or posting a notice on our Website. Combined Information: We may combine
Personal Information with other information we collect or obtain about you
(such as information we source from our third party partners), to serve you
specifically, such as to deliver a product or service according to your
preferences or restrictions, or for advertising or targeting purposes in
accordance with this Privacy Policy. When we combine Personal Information with
other information in this way, we treat it as, and apply all of the safeguards
in this Privacy Policy applicable to, Personal Information. As you use our Services,
you may import into our system Personal Information you have collected from
your Subscribers or other individuals. We have no direct relationship with your
Subscribers or any person other than you, and for that reason, you are
responsible for making sure you have the appropriate permission for us to
collect and process information about those individuals. Consistent with the
uses of Personal Information covered in Section 6, we may transfer Personal Information
of you or your Subscribers to companies that help us promote, provide, or
support our Services or the services of our Members (“Service Providers”). All
Service Providers enter into a contract with us that protects Personal
Information and restricts their use of any Personal Information consistent with
this policy. As part of our Services, we may use and incorporate into features
information you have provided, we have collected from you, or we have collected
about Subscribers. We may share this information, including Subscriber email
addresses, with third parties in line with the approved uses in Section 6. If you are a Subscriber
and no longer want to be contacted by one of our Members, please unsubscribe
directly from that Member’s newsletter or contact the Member directly to update
or delete your data. If you contact us, we may remove or update your
information within a reasonable time and after providing notice to the Member
of your request. We will retain Personal
Information we process on behalf of our Members for as long as needed to
provide our Services or to comply with our legal obligations, resolve disputes,
prevent abuse, and enforce our agreements. (a) Blog. We have public blogs on our Websites. Any information
you include in a comment on our blog may be read, collected, and used by
anyone. If your Personal Information appears on our blogs and you want it
removed, contact us via support@nokmail.net. If we are unable to remove your
information, we will tell you why. (b) Social media platforms
and widgets. Our Websites include social media features, such as the Facebook
Like button. These features may collect information about your IP address and
which page you are visiting on our Website, and they may set a cookie to make
sure the feature functions properly. Social media features and widgets are
either hosted by a third party or hosted directly on our Website. We also
maintain presences on social media platforms including Facebook, Twitter, and
Instagram. Any information, communications, or materials you submit to us via a
social media platform is done at your own risk without any expectation of
privacy. We cannot control the actions of other users of these platforms or the
actions of the platforms themselves. Your interactions with those features and
platforms are governed by the privacy policies of the companies that provide
them. (c) Links to third-party
websites. Our Websites include links to other websites, whose privacy practices
may be different from ours. If you submit Personal Information to any of those
sites, your information is governed by their privacy policies. We encourage you
to carefully read the privacy policy of any Website you visit. We may disclose Personal
Information to the following types of third parties for the purposes described
in this policy: (a) Service Providers.
Sometimes, we share your information with our third party Service Providers,
who help us provide and support our Services. For example, if it is necessary
to provide you something you have requested (like enable a feature such as
Social Profiles), then we may share your and/or your Subscribers’ Personal
Information with a Service Provider for that purpose. Just like with the other
third parties we work with, these third party Service Providers enter into a
contract that requires them to use your Personal Information only for the
provision of services to us and in a manner that is consistent with this
policy. Examples of Service Providers include payment processors, hosting
services and content delivery services. (b) Advertising partners. We may partner with third party
advertising networks and exchanges to display advertising on our Websites or to
manage and serve our advertising on other sites and may share Personal
Information with them for this purpose. All third parties with which we share
this information are required to use your Personal Information in a manner that
is consistent with this policy. We and our third party partners may use cookies
and other tracking technologies, such as pixels and web beacons, to gather
information about your activities on our Websites and other sites in order to
provide you with targeted advertising based on your browsing activities and
interests. We may, from time to time,
offer surveys, contests, sweepstakes, or other promotions on our Websites or
through social media (collectively “Our Promotions”). Participation in our
Promotions is completely voluntary. Information requested for entry may include
personal contact information such as your name, address, date of birth, phone
number, email address, username, and similar details. We use the information
you provide to administer Our Promotions. We may also, unless prohibited by the
Promotion’s rules or law, use the information provided to communicate with you,
or other people you select, about our Services. We may share this information
with our affiliates and other organizations or Service Providers in line with
this policy and the rules posted for the Promotion. When you send an email
marketing campaign, it bounces from server to server as it crosses the
Internet. Along the way, server administrators can read what you send. Email
was not built for confidential information. Please do not use Nokmail to send
confidential information. Sometimes we review the
content of our Members’ email campaigns to make sure they comply with our Terms
of Use. To improve that process, we have software that helps us find email
campaigns that may violate our Terms. Our employees or independent contractors
may review those particular email campaigns. This benefits all Members who
comply with our Terms of Use because it reduces the amount of spam being sent
through our servers and helps us maintain high deliverability. A Distribution List can be
created in a number of ways, including by importing contacts, such as through
csv or directly from your email client. Your Distribution Lists are stored on a
secure Nokmail server. We do not, under any circumstances, sell your
Distribution Lists. If someone on your Distribution List complains or contacts
us, we might then contact that person. Only authorized employees have access to
view Distribution Lists. You may export (download) your Distribution Lists from
Nokmail at any time. We will use and disclose
the information in your Distribution Lists only for the reasons discussed in
Sections 6-9. We will not use and disclose the information in your Distribution
Lists to: ·
bill or collect money owed to us; ·
send you system alert messages; ·
communicate with you about your account; or ·
send you informational and promotional content. If we detect abusive or
illegal behavior related to your Distribution List, we may share your
Distribution List or portions of it with affected ISPs or anti-spam
organizations. If a security breach
causes an unauthorized intrusion into our system that materially affects you or
people on your Distribution Lists, then Nokmail will notify you as soon as
possible and later report the action we took in response. We take reasonable and
appropriate measures to protect Personal Information from loss, misuse and
unauthorized access, disclosure, alteration and destruction, taking into
account the risks involved in the processing and the nature of the Personal
Information. Our credit card processing vendor uses security measures to
protect your information both during the transaction and after it is complete.
Our vendor is certified as compliant with card association security
initiatives, including the Visa Cardholder Information Security and Compliance
(CISP), MasterCard® (SDP), and Discovery Information Security and Compliance (DISC).
We also perform annual SOC II audits. If you have any questions about the
security of your Personal Information, you may contact us at privacy@nokmail.net. Nokmail accounts require a
username and password to log in. You must keep your username and password
secure, and never disclose it to a third party. Because the information in your
Distribution Lists is so sensitive, account passwords are encrypted, which
means we cannot see your passwords. We cannot resend forgotten passwords
either. We will only reset them. Our servers and offices are located in Nigeria and the United
States, so your information may be transferred to, stored, or processed in the
United States. While the data protection, privacy, and other laws of the United
States might not be as comprehensive as those in your country, we take many
steps to protect your privacy, including offering a data processing agreement. By using our Websites, you
understand and consent to the collection, storage, processing, and transfer of
your information to our facilities in the United States and those third parties
with whom we share it as described in this policy. We do our best to keep
your data accurate and up to date, to the extent that you provide us with the
information we need to do so. If your data changes (for example, if you have a
new email address), then you are responsible for notifying us of those changes.
Upon request, we will provide you with information about whether we hold, or
process on behalf of a third party, any of your Personal Information. We will
retain your information for as long as your account is active or as long as
needed to provide you with our Services. We may also retain and use your
information in order to comply with our legal obligations, resolve disputes,
prevent abuse, and enforce our Agreements. We will give an individual, either you or a Subscriber, access
to any Personal Information we hold about them within 30 days of any request
for that information. Individuals may request to access, correct, amend or delete
information we hold about them by contacting us via
support@nokmail.net. Unless it is prohibited by law, we will remove any Personal
Information about an individual, either you or a Subscriber, from our servers
at your or their request. There is no charge for an individual to access or
update their Personal Information. “Do Not Track” is a
standard that is currently under development. Because it is not yet finalized, Nokmail
adheres to the standards in this policy and does not monitor or follow any Do
Not Track browser requests. That said, some of our features may have the
ability to monitor or follow Do Not Track browser requests. Thanks for taking the time
to learn about Nokmail’s Privacy Policy, and thanks for trusting us to handle
your email. Updated November 20, 2017 THE BASICS
1. Definitions
2. Changes
3. Scope
4. Questions &
Concerns
Attn. Privacy Officer
privacy@nokmail.net
YOUR INFORMATION
5. Information We
Collect
6. Use and Disclosure of
Personal Information
7. Data Collected for
and by our Users
8. Public Information
and Third Party Websites
9. Third Parties
10. Contest and
Sweepstakes
11. Content of Email
Campaigns
YOUR LISTS
12. Your Distribution
Lists
SECURITY
13. Notice of Breach of
Security
14. Safeguarding Your
Information
COMPLIANCE
15. We Operate in the
United States
16. Accuracy and Retention of Data
17. Access
18. Do Not Track
Disclosure